The FTA Drug & Alcohol Audit Process George Gilpatrick & Michael Redington

What Should I Expect???

What You’ll Get Program Evaluation Technical Assistance Regulatory Training

Notification  When does it occur?  Why was I selected? (and did I do anything wrong?)  What does the audit team need?

The Schedule  Is the schedule flexible?  How long will the audit team be on-site?  Will the Region be involved?  What if we just got audited? From a different agency?

Pre-Audit Materials  What do I need to send?  Completed contact information & schedule  Copy of most current policy  ALL testing records from examination period:  Random  Pre-Employment  Post-Accident  Reasonable Suspicion  Return-to-Duty and Follow-Ups if done

Pre-Audit Materials  Names of all vendors (MRO, SAP, Collection Sites)  Laboratory data  Organization chart (if on hand)  Names of individuals relevant to the program (C/TPA officials)

Pre-Audit Materials  Optional Material:  Collector certificates  MRO certifications  SAP certifications

Pre-Audit Materials  Submit all materials on or before the listed submission date  Contractor data should come through Grantee  As much electronic information as possible

All Electronic Submissions  Approximately half of all pre-audit submission are entirely electronic

Pre-Audit Materials  2 Copies to Team Leader (Contractor)  1 copy to USDOT Volpe Center  Q: How long will the audit take?

On-Site Visit  “Whoa… Why the group?”  Entrance Conference begins Audit  If building is secured, auditors need access passes  Auditors need office or conference room  DAPM needs to be available for majority of time  Operations Chief or Supervisor may also be needed

4 Parts of the Audit

#1: Interviews with Transit System  DAPM/DER Interview (30-90 minutes)  Discussions with Operations Personnel  Discussions with HR

#2: Review of Records  Random tests  Pre-Employment tests  Post-Accident tests  Reasonable Suspicion tests  Return-to-Duty/Follow-Up tests  Training schedule  Route schedules

#2: Review of Records  Accident Reports and Files  Employee Rosters  Memos to and from Vendors  Arbitrations and Disputes  Internal Memos  MRO verifications  Lab reports

#3: Evaluation of Vendors  Phone interviews with:  MRO  SAP (Must be local!)  C/TPA Interviews are conducted in person when possible

#3: Evaluation of Vendors  Visit to Collection Site for MOCK Collection  Procedures at site closely evaluated  Collection site and enclosure inspected  Staff interviewed

CONTRACTORS Don’t Forget: Contractors are YOUR responsibility. This includes service providers and security firms, in addition to vendors.

Technical Assistance Ask audit team to show you what they are doing. Learn how to inspect Chains-of-Custody and other documents.

#4: Technical Assistance  Auditors identify deficiencies  Work with transit system to develop corrective actions  Help with operational difficulties  Help with administrative difficulties  Suggest additional assistance  Are available even after the audit ends

Exit Interview  Auditors generally leave the guestlist to the Grantee  Usually between 30 and 60 minutes  Report is an exceptions report

Will there always be findings?  State of Kansas  MUNI in San Francisco Audit Team issued compliance letter on the spot during the exit interview

Response Period  Either 45 or 90 days to submit corrective actions response  Generally, policy revisions may be submitted at any time  Stay in contact with Audit Team Leader  Ask questions

Response Period  Responses evaluated by auditors  May require additional corrective action

Compliance Compliance letter issued!

Am I Done?  Can still ask regulatory or compliance questions  Can still contact the audit team leader or team members  Can still ask for assistance

Common Pitfalls  Not calling the audit team leader back  Late pre-audit submission  Attempting to conceal or misrepresent elements before and during the audit  Not submitting a 90-day response  Not making any needed changes  Not following the response requirements carefully

Concealing  Attempting to conceal or misrepresent elements further lengthens the corrective period  Auditors can provide better technical assistance if all information is disclosed prior to or during the audit  Many problems can be remedied before auditors arrive

Communication  Audit team leaders may be contacted before, during, and after all audits, regardless of how long ago they occurred

Follow-up  Auditors may conduct clandestine collection site inspections after the 90-day response is received to gauge how well the stated changes were made  Re-audits may occur if responses indicate little or no improved safety

Thank you for attending.