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reviews that complacency is one of the biggest enemies to a compliant collection. A drug user intent on cheating the testing system can do so if the collection site fails basic security or integrity procedures. Drug users have the most to lose—in most cases employment—so the motivation to cheat in these cases is strong. Reviewing a collection site’s practices is the best way to ensure the integrity of the testing process. Poor procedures can result in positive results being overturned. Tere are two types of audits—announced

and clandestine. Te announced audit is an open process, scheduled with the collection site. Te players are identified and the intent of the review is made clear. Interviews with collectors are conducted, certifications and equipment records are examined, and issues are addressed on the spot using a coaching process. Disadvantages of the announced method can include the collection site sending their best collector to the auditor. Knowing that the mock collection is being observed also can put collectors on their toes and result in a process that is not typical for the collector. Certain aspects of a collection cannot be properly evaluated during a mock collection—the collector may be told that the specimen is too cold (what do you do?) but would it be noticed in ‘real life?’ A clandestine audit is typically not

scheduled in advance, or if an appointment is needed the collection site is not told it is a compliance review. Clandestine audits use the “Mystery Shopper” process, disclosing neither the identity of the donor nor the true purpose of the collection. Tis is an investigative process to verify if regulated procedures are being followed, and an actual test is submited. Disadvantages to the undercover method include the inability to request certifications, calibration records, etc. One collector having a bad day can taint a collection site and lead to a loss of business. An undercover method also cannot fully

10 datia focus

discuss problem collections, such as refusals or out of temperature range samples. I used the clandestine method, as

mentioned earlier. Because I am conducting these reviews on behalf of my employer and third party administrator (TPA)—not the government, I have several ground rules. Number one is simply to never atempt to tamper with the specimen, have any contraband on my person, interfere with the collector, or do any action, which could be categorized as a refusal to test. My own license is on the line! I’m not trying to cheat—I’m evaluating the process and noting security flaws which may allow cheating. Most recently I completed 15 audits in 2015 in Florida, Mississippi, Illinois, Pennsylvania, Georgia, Missouri, Wisconsin, Indiana, and Michigan (I conducted multiple audits in some states with different collection sites). I’ve checked collection practices in five national urgent care clinics, four regionally-based facilities, one hospital-based collection site, and five local or independent facilities. I’ve found that neither geography nor size seems to mater. Some of my best and worst collections have taken place in national chains. My company has three regions and nine districts (3 each) and I review a collection site in each district a minimum of once per year, depending on the size of the district or notification of problem collection sites. I submit to at least one alcohol test per region per year, and have begun occasionally incorporating a short-term possible “shy bladder” scenario. I’m typically in standard driver work

clothes, complete with steel-toed boots. I place a large handkerchief or bandanna in my pocket, keep a large cell phone in a holster on my hip, always wear a jacket of some sort, carry a small purse, and clip with a number of keys on my belt, which always includes a CPR barrier keychain in a small cloth pouch (innocent in itself, but *could* contain something to adulterate the specimen). I approach the test with an overall clueless

demeanor, as though I have never taken a test before. All tests use either my TPAs CCF, or are transferred to another account aſter the fact to avoid impacting MIS stats. I follow all instructions given to me by the

collector, and do not mention any missed steps such as ID checks or washing hands. If I’m leſt with my phone, I will take photos of anything interesting in the enclosure. I complete the paperwork as directed; if the collector instructs me to initial the seals while they are still on the form, that’s when I initial. I leave the collection site as I entered—

undercover. I don’t disclose why I was there at the time. I then document my findings on a modified version of the Federal Transit Administration (FTA)) Urine Collection and Breath Alcohol Technician Interview Questions found at htps://transit-safety. ſ Tese forms provide the regulatory citation for each part of the process. Te original documents are designed for an announced review and have more detail that cannot be covered during a clandestine collection, such as the proper steps to complete an alcohol confirmation test. Aſter the findings are documented, I

send the paperwork, copies of the CCFs, and photos (if any) to my TPA who trains her own collectors and so she is beter able to address collection issues and training needs. Usually the conversation with the TPA leads the collection site to take corrective action, though there have been a few instances where the decision has been to switch to a new collection facility. Findings are categorized into security

issues, which can allow cheating, and paperwork issues, which can call into doubt the chain of custody. Security findings for the 15 most recent audits reviewed for this article revealed the following: 1. Bluing issues—3 2. Potential smuggled items— Keychain CPR pouch—8, cell phone—7

summer 2016

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