Unique Situations for DAPMs How to Handle Them

Common Areas for Trouble Internally ◦ Operations ◦ City Hall ◦ HR ◦ Employees ◦ Management ◦ Consultants

Common Areas for Trouble Externally ◦ Collection Sites ◦ Mobile Collectors ◦ MRO ◦ TPA ◦ SAP

Common Areas for Trouble Externally ◦ Insurer ◦ Public ◦ Outside representation

Caught in the Middle DAPM & FTA Collectors Collection Site ManagementEmployees Vendors: MRO & TPA State or Grantee

Identifying Problem(s) Investigate for yourself Identify each deficiency Locate the specific rate-limiting step Rely on evidence

Analysis Mitigation likelihood ◦ Resources ◦ Support ◦ Level of effort ◦ Resistance ◦ Expertise

Mitigation

INTERNAL ISSUES

Areas for Issues Operations ◦ Supervisors ◦ Logistics for testing/service interruption ◦ Maintenance

Operations Identify, Analyze, Plan, Resolve Set VERY specific goals for Random Testing ◦ Actual dates and times for tests ◦ Don’t issue vague testing goals or theories ◦ Be hands-on if needed (go to the source)

Operations Identify, Analyze, Plan, Resolve Set VERY specific goals for Post-Accident Testing ◦ Go to the scene when possible ◦ Retrain in a brief gathering or formal meeting ◦ Full debrief after each accident ◦ Call the collection site

City Hall Billing Issues ◦ Vendor Invoices: Can you monitor them? Can you withhold payment? Can you be involved? Contracts/RFPs ◦ Do you have input into terms? Bid evaluations? Selection?

City Hall Billing Issues ◦ Vendor Invoices: Institute proactive memos of approval Contracts/RFPs ◦ Ask FTA for advice on language/pitfalls ◦ Push for involvement

Human Resources Understanding of the requirements ◦ Push/pull between Ops/HR/Exec ◦ Who is pushing for “efficiencies”? Closing the loop:  Accident information is critical to D&A program, but is often unavailable/difficult to receive  Random testing records  Pre-employment clearances

Human Resources Understanding of the requirements ◦ FTA can assist Closing the loop:  Proactively request records for debriefing and reviewing  Be a pest

Employees Notification vulnerabilities ◦ Are there internal vulnerabilities? ◦ How can you find out?

Employees At the collection site ◦ Waiting time before collection ◦ Waiting time during ◦ Total time of test

Employees Review the notification process for vulnerabilities Work with the collection site to reduce waiting times

Management Are you supported in your program? Are your supervisors supported? ◦ Post-accident testing thresholds ◦ Random spread requirements ◦ Return-to-duty ◦ Follow-up

Management Support for testing requirements: ◦ Post-accident: Present your side, but protect yourself in the documentation ◦ Random: Educate management, continue to work with Ops ◦ RTD & Follow-up: STAY ON TOP OF TESTING  NEVER fall behind & contact FTA immediately  Protect yourself

Consultants Authority Advice Changes Expertise/Grasp of Local Dynamics

Consultants Authority ◦ Are they clear about their authority/sponsor? Advice ◦ Is the advice correct? Is it personal preference or regulation? Which regulation? Fed/State/Local?

Consultants Changes ◦ Are the changes realistic? Overly burdensome? Do they have program health/regulatory compliance as a result? Expertise/Grasp of Local Dynamics ◦ FTA/FMCSA? Only one collection site?

Consultants Authority: Require articulation of authority before the visit. Contact FTA with concerns Advice: The changes required or suggested must be backed up by regulation. Require citations and read the citations yourself Changes: Require details about changes. Nothing is too specific Expertise/Grasp of Local Dynamics: Be firm with your local approach if there is more than one path to compliance

EXTERNAL ISSUES

Collection Site Limited hours/days Check-in times Collection process protocols ◦ Training ◦ The enclosure ◦ The CCF  Completeness & Accuracy

Collection Site Poor record transmittal Delays in reporting Inattention to small clients Complaints from employees/supervisors Repeated errors/affidavit requirements Mobile collector problems

Check Every CCF Completeness of the CCF ◦ Steps 1-5 Step 3 (unless the form is a Quest form) Accuracy of the CCF ◦ Time, date, test type, testing authority Timeliness of the collection process ◦ Start-to-finish times and wait times

Visit The Collection Site to Determine: The order in which the collection was performed The enclosure’s security The participation requirements/allowances of the donor ◦ Remove outer garments ◦ Pockets ◦ Wallet

Require Corrections Eliminating areas of concealment within the enclosure is the goal Ensuring the supervision of the donor is crucial Fatal flaws must be corrected by error correction training within 30 days

Tips Ask that responses from collection site personnel be sent to you by ◦ Time/date included ◦ Correspondence trail included ◦ Easier to distribute as needed ◦ You can ask for photos, etc.

Tips After daylight savings time adjustments, monitor your collection site for a clock adjustment on the EBT If faxes are unclear, require digital photos of the CCF itself which can be ed directly from a phone (8 megapixel or higher) while you await the paper copy

Tips If you like a particular collector, establish an on-call arrangement for late or early collections and pay them directly Delay payment if needed for collection site unresponsiveness

Tips Print bulletin cards for your collection site ◦ Multiple contact numbers ◦ Testing authority (you can pre-print these) ◦ Protocols

Tips Provide your collection site with SASEs in which to send your Employer Copies (Copy 4) from each CCF ◦ At the time of each collection ◦ Sent in batches at beginning of each testing period

Tips Check your ATF and CCF to determine which test occurred first Maintain a collaborative relationship (if possible) with your collectors Make appointments if possible (or needed) Monitor your employee’s wait time before the collection (after arrival)

The Required Order Step 1 The collection of the specimen Step 2 Step 3 Step 5 Step 4 The order is 1,2,3,5,4 and not 1,2,3,4,5

MRO/TPA/SAP Remember that THEY work for YOU You set the deadlines, dates, transmittal methods, and protocols in general If you get repeatedly poor service, drop them. If your employer is not assisting, contact the FTA

Insurer/Public/Representation Stay firm to the requirements ◦ Read them, ask the FTA, or ask internally for assistance Protect yourself with documentation Remain calm and articulate your stance Rely on evidence, not opinion or spin

Fixing Problems The FTA can assist with ◦ Policy ◦ New DAPM training ◦ Program evaluation ◦ Regulatory interpretation ◦ Regulatory application

Call the FTA Hotline (617) Or

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