WASHINGTON REPORT BY TAMIKA CARTER, DATIA
In a letter to Senator Thune, DATIA supported all aspects of the proposed bill, including, but not limited to, the inclusion of hair and oral-fluid testing and 100% use of electronic, federal Custody and Control Forms (CCFs), both of which DATIA has supported since the early 2000s.
O
n May 21, 2018, U.S. Senator John Tune of South Dakota introduced a bill (S. 2848) to improve U.S.
Department of Transportation (DOT) controlled substances and alcohol testing. If enacted as proposed, the bill, known as the Fighting Opioid Abuse in Transportation Act, will: • create a database of all DOT drug-test statistics by March 2019;
• add fentanyl to the testing panel; • require the U.S. Department of Health and Human Services to publish reports on its progress in developing hair- testing guidelines;
• require oral fluid guidelines by December 31, 2018;
• ensure a completely electronic CCF system—not a combination of electronic and paper forms; and
• ensure that the Federal Motor Carrier Safety Administration (FMCSA) National Clearinghouse is operational by January 2020. In a leter to Senator Tune, DATIA
supported all aspects of the proposed bill, including, but not limited to, the inclusion of hair and oral-fluid testing and 100% use of electronic, federal Custody and Control Forms (CCFs), both of which DATIA has supported since the early 2000s.
Use of New CCF Required as of July 1, 2018 As of July 1, 2018, the new 2017 CCF must be used, and laboratories must treat the use of the expired federal CCF as a correctable discrepancy. Te requirement to use the new form is a result of the Health and Human Services (HHS) Mandatory Guidelines that took effect October 1, 2017. As of the July 1 effective date,
laboratories must take the following actions for a specimen received with an expired federal CCF:
• Access and test the specimen while atempting to obtain a memorandum for the record (MFR) from the collector to explain the use of the incorrect form.
• Hold the specimen report for at least five business days from the first atempt to contact the collector. If the laboratory cannot obtain an MFR from the collector aſter this time, the laboratory must report the specimen as Rejected for Testing.
• Be proactive and take steps to ensure that the collector/collection site has 2017 federal CCFs for use with regulated specimen collections. To download the new form, visit htp://
www.datia.org/datia/advocacy/regulatory/ FedCCF.pdf. For guidance on how to use the new form, visit htps://
www.samhsa. gov/workplace/resources.
Labs Required to Have HHS Approval Prior to Using eCCFs On May 30, 2018, the National Laboratory Certification Program (NLCP) reminded stakeholders that laboratories must receive approval from the U.S. Department of Health and Human Services’ Substance Abuse and Mental Health Services Administration (SAMHSA) prior to accepting regulated specimens collected using an eCCF). If a laboratory receives a specimen that was collected using an eCCF that has not been approved by SAMHSA for that laboratory, the laboratory must reject the specimen. Te laboratory must also notify the collection site that the eCCF cannot be used for regulated specimen collections because it has not been approved by SAMHSA for the laboratory. For more information on the chain of
events that led to this announcement, download the NLCP notice at htp://datia. org/datia/eNews/UnapprovedECCFs.pdf. ❚
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datia focus
summer 2018
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