BEST PRACTICES BY HEATHER THOMPSON, SUBSTANCE ABUSE PROFESSIONALS OF TEXAS
Partnering with Substance Abuse Professionals in the Return to Duty Process: Best Practices for Best Outcomes
It is in your best interest to have a working knowledge of what a SAP can and cannot do in the RTD process.
Y
ou, the Designated Employer Representative (DER) for your company, are being audited by
the US Department of Transportation (DOT). Te administration’s field representative informs you that you are out of compliance with the Follow-up Test Plan you received from the Substance Abuse Professional (SAP). You may be faced with a fine. You have made frequent atempts
to contact the SAP that conducted the Return to Duty (RTD) analysis with your employee, to no avail. Te Follow-up Test Plan from the SAP
was so formidable that you decided to forego hiring a potentially great employee. Your new hire had been on a Follow-up
Test Plan for nine months with another company that has now gone out of business. Te employee doesn’t remember how many observed Follow-up tests they have done and did not keep a copy of their Chain of Custody Form (CCF). Te SAP’s report is out of compliance
with the DOT format. You need a copy of the SAP’s credentials,
the compliance report, and the Follow-up Test Plan for your new hire, but cannot obtain the information because the employee’s former employer and the SAP are now out of business. Tese are real life scenarios I have
encountered. Because I am able to maintain good working relationships with DERs, Tird Party Administrators (TPAs), and Medical Review Officers (MROs), I have been able to help resolve issues like these that I have seen in my SAP career. It begs the question: How important is it for DERs, TPAs, MROs, and SAPs to have a good working relationship?
10 datia focus Does DOT allow you, the DER, to
refer to a SAP with whom you have a relationship? Te answer is “Yes!” SAP RTD case management services must be financially separate from referral sources and from education and treatment resources to which the SAP refers. However, networking is the key to successful RTD case management. Without a collaborative relationship,
you, as the DER, can be at a loss to comply with DOT requirements. It is in your best interest to have a working knowledge of what a SAP can and cannot do in the RTD process. Conversely, it is imperative that the SAP understand your role, the regulations you must follow, and your industry’s unique situations that can create hurdles in the RTD process. Each DOT Administration has some variations to the compliance rules. Some of these differences may be subtle, at times. Te SAP needs to be well-versed in the unique circumstances you face in your industry. I am grateful to DERs that help me learn
about their industry, so I can fulfill my role in the RTD process more effectively. Likewise, I appreciate MROs who take the time to explain the meaning of a drug level count so I can provide a more accurate evaluation. And when a TPA talks to me about a case prior to the initial appointment I have with the employee, I can step into the counseling office to conduct the RTD evaluation with more confidence, having the corroborative information about the case in hand. I need to have the correct information, in
a timely manner, to do my job as a SAP— and so do you. Tere are some things you need to know before referring to a SAP: • When did they take the SAP examination? • Have they kept up with 12 hours of DOT-specific training every three years?
spring 2018
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