In October, the Department of Health and Human Services approved the first laboratory for the processing of Department of Transportation drug tests. As the DOT begins its roll out of the electronic chain of custody (eCCF) and the non-regulated industries continue to expand the use of eCCF, it is important to evaluate the pros and cons and the impact of its use in your drug testing program.
Electronic chain of custody offers many benefits to employers:
- Online scheduling of drug tests
- Ability for the donor or the company representative to enter the required identifying information prior to arrival at the collection site
- Less data entry errors resulting in lost or mismatched specimens
- The ability to track specimens from offer through reporting
- Less administrative costs locating paper chain of custody forms, ordering and storing forms
- Managing multiple accounts without the hassle of juggling multiple sets of paper chains
- Avoiding the cost of shipping paper chains to candidates and employees
The list of benefits is long and as the Department of Transportation gets closer to approving electronic chain of custody for regulated employees at more laboratories, it is important to understand the impact it will have on your DOT drug testing program before you begin implementation.
First, expect some resistance from the field. Recruiters, hiring managers, and supervisors who opt to fill out the form will need to collect and enter all of the required information from the donor and may argue that the time it takes to fill out the form online is longer than handing out a paper chain of custody. While true, on average, it takes less than two minutes to fill out the required information on an electronic chain. This time needs to be weighed against the time saving benefits gained by eliminating the search for paperwork, locating missing or mismatched records, collection sites using another company’s paper chain, supply ordering and filing. Often companies solve this issue by sending the link to the eCCF to the donor allowing him/her to fill in most of the required information. This saves time for the manager and provides a seamless candidate experience. It has the added benefit of allowing the donor to identify collection sites close to home, school, or their current employer, making the process convenient and easy. Ease in hiring and collecting often results in faster hiring and turnaround of drug test results.
Second, understanding the donor experience is critical. As you roll out eCCF in your workplace, remember that some of the benefits require re-processing of some of your current operating procedures. Allow time to train your team on the process and be certain to provide a demonstration from the perspective of the donor. Review the “what-ifs” and create a process for handling them. How will you handle a candidate without internet access? One who is not computer savvy? Who states he/she didn’t get the link? Who arrives at the wrong collection site? Anomalies and exceptions will not increase but they will be different, and being prepared in advance of the roll out will be important to your overall success.
Third, consider the compliance and program benefits of eCCF and update your policy to reflect any new rules related to them. Once updated, make certain to publish any changes before they go into effect.
- If the eCCF will “expire” after 48 hours, how will the recruiter or manager be notified?
- Are there acceptable exceptions and if so, how do you ensure that they are applied organization-wide and uniformly?
- How do weekends and holidays impact your expiration processes?
The eCCF makes post-accident, reasonable suspicion, and random testing much more flexible by “locking in” test panels by reason for test. Are you interested in expanding your panels? If so, decide this before you roll out the electronic chain of custody and make sure any policy updates are made prior to rolling out the changes. Your random program becomes much easier to manage if you fill out the electronic chain when you receive the list and either send it to the selected employee or supervisor so the information is pre-populated with the correct reason for test.
Finally, remember that it is unlikely that you will go 100% electronic at one time. Consider a pilot program in a region where there are multiple accounts to manage, where it is difficult to meet face to face with the candidate or employee or with a team who is willing to evaluate the potential for the organization as a whole. Measure the results and enjoy the benefits of this exciting new industry advancement!