CONSORTIUM/THIRD PARTY ADMINISTRATORS, OR C/TPAS
The term “Third Party Administrator” in the drug testing business stands for an entity that coordinates several services for employers to maintain a drug testing and/or drug free workplace program. The term “Consortium” stands for a grouping of employers in the drug testing arena. The United States Department of Transportation (DOT) coined the phrase Consortium/Third Party Administrators, or C/TPA, when they rewrote the DOT drug and alcohol testing regulations (49 CFR Part 40) in 2001.
What Does C/TPA Stand For?
According the FMCSA website, “ Consortium/Third-Party Administrators (C/TPAs) manage all, or part, of an employer's DOT drug and alcohol testing program, sometimes including maintaining required testing records. They perform tasks as agreed to by the employer to assist in implementing the drug and alcohol testing program and to help keep the employer compliant with the DOT/FMCSA Drug and Alcohol Testing rules and regulations.”
Mostly, the C/TPA manages the DOT required random testing of multiple employers and owner operators in one random testing pool. Owner operators are required by regulation to be enrolled in a C/TPA Consortium for random drug and alcohol testing.
Non-DOT employers can also engage a C/TPA for management of non-DOT random testing programs. This usually occurs within an association of employers, a union, or other grouping.
It is the expectation that a C/TPA is a professional company with advanced knowledge and expertise in drug and alcohol testing regulation and best practices. Employers hire C/TPAs to keep them safe and in regulatory compliance. Some C/TPAs are local, some regional, and some national. National Drug Screening operates as a C/TPA in all areas of the United States.
Although an employer is hiring a C/TPA to manage and administer the aspects of the drug and alcohol testing program, compliance with regulation is ultimately the employers’ responsibility. Employers can be held responsible for service agent (including C/TPA) errors and resulting civil penalty actions for noncompliance.
What is a Service Agent?
The Service agents are the various entities that are involved in providing the various drug and alcohol testing services. These entities or vendors are companies that help the employer to implement the DOT regulations. These might include:
- Urine Collector
- Medical Review Officer (MRO)
- Screening Test Technician (STT)
- Breath Alcohol Technician (BAT)
- Substance Abuse Professional (SAP)
- Drug Free Workplace Policy Consultant
Consortium/Third Party Administrator (C/TPA) is also considered a service agent. The TPA coordinates a variety of drug and alcohol testing services for employers. These services can include random selections; preparation of annual Management Information System (MIS) reports; and coordinating urine collections, laboratory testing, MRO services, alcohol testing, and SAP evaluations. A C/TPA must ensure the services it provides comply with DOT regulations and that its service agents are qualified.