Consortium/Third Party Administrators (C/TPAs) provide a variety of drug and alcohol testing services to employers. These services are for DOT and Non-DOT programs. The variety of drug and alcohol testing services are provided by what we call Service Agents (SA). Many times, the C/TPA provides some of these services directly as the service agent and often some or all these services are outsourced to other service agents. Let’s discuss each of the service agents involved in the business of providing drug and alcohol testing and drug free workplace programs.
Drug Testing Specimen Collections
- Specimen Collectors (the collector) – These folks work from a brick and mortar facility and/or operate on a mobile basis traveling to and from client locations. The specimen collector works directly for the client, the laboratory, the third-party administrator (TPA), or others. The collector is collecting a biological specimen (urine, hair, blood, sweat, or oral fluid/saliva) for a testing device or a laboratory to determine the presence or absence of specified parent drugs or their metabolites.
- Collection Site: A facility where specimens are collected. This could be the employer’s place of business. Typically this is a brick and mortar facility. It could be a TPA office, medical facility, hospital, occupational health clinic, walk in clinic, doctor’s office – any type of business that might have a set up for urine collections and employ collectors to collect specimens. Major laboratories such as Quest Diagnostics and LabCorp operate brick and mortar facilities that employ collectors to collect specimens; these are commonly referred to as Patient Service Centers (PSCs). Other laboratories have contracts with occupational health clinics, walk in clinics, doctor’s offices, and other facilities that operate brick and mortar facilities to collect specimens.
- National Drug Screening provides over 10,000 collection sites throughout the United States. Mobile on-site collectors are also available. Training for specimen collectors is also available at http://www.mydrugtesttraining.com.
- Breath Alcohol Technician (BAT) and/or Screening Test Technician (STT) – commonly a collector also, the BAT or STT is a person who instructs and assists persons in the alcohol testing process and operates an evidential breath testing device (EBT or Breathalyzer) or an alcohol screening device. The technicians usually work at a brick and mortar clinic or collection site. These folks also operate on a mobile basis traveling to and from client locations. They work directly for the client, the laboratory, the third-party administrator (TPA), or others.
Is Testing Done at the Collection Site?
Before moving on to other service agents, it is important to discuss some key issues regarding specimen collectors, collection sites, and breath alcohol technicians. Often these service agents have been referred to as the weakest link in the drug and alcohol testing program.
As a C/TPA you need to avoid this weak link. If you employ your own collectors, training and DOT qualification are critical to your operation. Retraining is also critical. Mistakes and problems are eliminated with well-trained professional collectors. DOT requires training and proficiency demonstration for collectors and BATs. When you are outsourcing the collection or breath alcohol testing, things can get more challenging. As a TPA you must verify that the collectors you are utilizing are trained and qualified. This is a huge responsibility; your employer clients are counting on you to perform your services and those services you outsource efficiently, in compliance with regulations and with minimum exposure to liability.
SAMHSA Certified Labs for Actual Testing
- Laboratories (Lab) – After collection from the donor, a specimen is sealed with a tamper evident seal and sent to a laboratory for analysis. The primary advantages of utilizing a laboratory for testing include compliance with regulations, accuracy, legal defensibility, and the ability to customize tests for the needs of the client. A laboratory is a brick and mortar facility that does the testing, not the facility that collects the specimen. Folks get confused about this and say, “I’m going to the lab for my drug test.” They actually mean they are going to the collection site for specimen collection. A very big investment is required to own and operate a laboratory. Major laboratories currently involved with drug testing include Quest Diagnostics, LabCorp, MedTox, Alere Toxicology, and Clinical Reference Laboratory (CRL). There are many other laboratories, both regional and national.
Testing for federal agency employees, the DOT testing program, and many state laws stipulate using labs that are certified by the Department of Health and Human Services (DHHS). Commonly called SAMHSA certified labs, it is a best practice to always use these labs which have required quality control standards and a rigorous inspection process to ensure accurate test results. SAMHSA maintains a current list of certified laboratories available at: https://www.samhsa.gov/workplace/resources/drug-testing/certified-lab-list
Instant Testing or Point of Collection Testing (POCT)
- Instant Testing Manufacturers and Distributors – On-site instant or rapid drug testing is becoming more widely used as a cost-efficient method of effectively detecting drug abuse amongst employees, as well as in rehabilitation programs to monitor patient progress. These instant tests are available for both urine and saliva testing. These instant test kits are visually read and subject to interpretation by the collector. They provide an indication of drug use within minutes, but they are only equivalent to the immunoassay stage of laboratory testing; confirmatory laboratory testing is required for test results that are not negative.
- There are many industry players in the business of selling these test kits as a distributor of products. Also, many service providers use these kits in conjunction with other testing methods and services they make available to their clients. Note that under some state laws, DOT rules, and HHS rules for federal workplace drug testing, these instant testing devices cannot be used.
Certified Medical Review of Drug Test Results
- Medical Review Officer (MRO) – A Medical Review Officer (MRO) is a person who is a licensed physician and who is responsible for receiving and reviewing laboratory results generated by an employer’s drug testing program and evaluating medical explanations for certain drug test results. The MRO receives the laboratory drug test results from the lab and reports the results to the employer. Many TPAs have in house MROs working for them. For federal programs, DOT programs, and under many state laws and state law programs, the MRO must be trained, qualified, and certified by a nationally recognized MRO certification board or subspecialty board for medical practitioners in the field of medical review of DOT-mandated drug tests.
The MRO is required for testing for federal agency employees, DOT testing programs, and under many state laws and state law programs. It is a best practice to use an MRO for all workplace laboratory drug testing.
- Walk in Clinics, Hospitals, Doctors Offices, and Occupational Health Clinics – All of these types of facilities might be in the drug and alcohol testing business perhaps as collection sites, Third Party Administrators (TPA), and/or Medical Review Officers (MRO). Due diligence, care, and verification is required to ensure these facilities have the proper training and qualifications to provide any services you are requesting.
- Background Check Providers – most providers of background checks are also selling drug testing, so these vendors are also considered Consortium/Third Party Administrators (C/TPAs). Ask questions about qualifications for drug testing operations. Also look to use a professional company with knowledge and expertise with drug testing.
Assistance and Treatment
- Employee Assistance Program (EAP) Provider – EAPs are employee benefit programs offered by many employers, often in conjunction with a health insurance plan. EAPs help employees deal with personal problems that might adversely impact their work performance, health, and well-being. EAPs generally include assessment, short-term counseling, and referral services for employees and their household members. Employers will refer employees with drug and/or alcohol problems to the EAP.
- Substance Abuse Professional (SAP) – Under DOT regulations, the SAP is a person who evaluates employees who have violated a DOT drug and alcohol program regulation and makes recommendations concerning education, treatment, follow-up testing, and aftercare. There are credentials and certifications required by DOT for one to be qualified to act as an SAP (40.281).
Implementation of Drug Free Workplace
- Policy Consultant or Writer – A TPA often provides to employer clients a service of developing written drug and alcohol testing policies. TPAs sometimes have in house policy consultants or outsource this function. Having a policy and a comprehensive drug free workplace program will serve to limit exposure to liability for an employer’s drug testing program. Each company has unique circumstances for their drug free workplace programs. Seek an expert.
Putting It All Together
Third Party Administrator (TPA) – This is basically a service provider or service agent that provides two or more of the services involved in the drug testing process. A TPA or C/TPA might coordinate for an employer the entire process of the specimen collection: breath alcohol testing, laboratory testing, and review and reporting by the Medical Review Officer (MRO), thereby providing all of these services under a one stop shop. A TPA will typically provide everything to the employer client to keep the client in compliance with the applicable regulations and best practice – DOT, federal, and state laws, etc.
The word “Consortium” was added to the term “Third Party Administrator in 2001 by the United States Transportation when the drug testing rule 49 CFR Part 40 was rewritten. So now those providing a variety of services for employers for drug and alcohol testing are referred to as Consortium/Third Party Administrators or C/TPAs.