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FTA D&A Audits: Tales from the Field and Experience of Your Peers Jack Mastrangelo, Senior Auditor John Spelman, Audit Team Leader FTA Drug & Alcohol Conference St Louis, April, 2011
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Notification When did it occur? Why was I selected? (And did I do anything wrong?) What did the audit team need?
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The Schedule Was the schedule flexible? How long was the audit team on-site? Was the region involved? Had you recently been audited? From a different agency?
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Pre-Audit Materials What were you asked to send? – Completed contact information & schedule – A copy of your policy – ALL testing records from examination period Random Pre-Employment Post-Accident Reasonable Suspicion Return-to-Duty and Follow-Ups (if done)
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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)
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Pre-Audit Materials Optional Material: – Collector certificates – MRO certifications – SAP certifications
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Pre-Audit Materials Did you submit all materials on or before the listed submission date? Did contractor data come through the grantee? How co-operative were your vendors/contractors during the pre-audit process?
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Electronic Submissions Approximately half of all pre-audit submissions are entirely electronic. – If you were notified next week, what percentage of your records would be electronic?* *There is no requirement that all records be electronic
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Pre-Audit Materials Two copies to Team Leader (contractor) One copy to USDOT Volpe Center How long did it take to assemble the required materials?
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On-Site Visit How did the audit effect your schedule? How did your agency react to the audit team?
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How did the audit components effect you?
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On-Site: Interviews with Transit System DAPM/DER Interview (30-90 minutes) – What was it like? Discussions with Operations Personnel Discussions with HR
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On-Site: Review of Records Random tests Pre-Employment tests Post-Accident tests Reasonable Suspicion tests Return-to-Duty/Follow-Up tests Training records
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On-Site: Review of Records Accident reports and files Employee rosters Memos to and from vendors Arbitrations and disputes MRO verifications Positives Lab reports
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On-Site: Evaluation of Vendors Phone interviews with: – MRO: Did they tell you what the conversation was like? – SAP: Do you speak regularly? – C/TPA: Did the audit change your professional relationship?
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On-Site: Evaluation of Vendors Visit to collection site for mock collection – Did you accompany the auditors? – How did your view of the collection site change? – What did you learn?
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Contractors How did the audit change your contractors’ understanding of the regulations? How did it affect your oversight of your contractor(s)? How did your contractor(s) do?
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Technical Assistance Did you receive adequate technical assistance before, during, and after the audit?
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Technical Assistance Did the audit team: Identify deficiencies? Work with the transit system to develop corrective actions? Help with operational difficulties? Help with administrative difficulties? Suggest additional assistance? Remain available even after the audit ended?
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Exit Interview Did the audit report accurately reflect the state of your drug and alcohol program?
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Response Period How did the response period go? Was the auditor available before the response date? Were the corrective actions adequate?
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Compliance When was the compliance letter issued? How many rounds did it take?
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Follow-up Have you been audited more than once?
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What was your overall impression of the process?
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Thank you for attending.
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