COMPLIANCE CORNER BY COLINDA HOWARD, DISA


HR 101: Your Drug Testing Program is Being Audited, What Now?


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reating a drug testing program is just the first step in maintaining a safer working environment.


Proper program management and regularly occurring audits are vital to maintain compliance and best practices. An audit can sound scary and you might feel some anxiety after experiencing or hearing about other companies that went through difficult audits which resulted in fines or lost work. If you are participating in a random


drug or alcohol testing program, the question isn’t “if,” but “when” you’ll be audited. Audits come in a variety of forms, and from a variety of authorities. The U.S. Department of Transportation (DOT) and its many modes require companies with safety-sensitive positions to either store or report statistical data every year. This data is analyzed to determine trends and program shortcomings which can lead to your company being audited. Alternatively, your company might


work with a third-party auditing agency to maintain compliance or meet an


owner-facility requirement. An auditing agency safeguards operators, their employees, contractors, and various industries by helping them maintain a drug-free workplace. These audits ensure that companies are testing in conformity with requirements. For most safety-sensitive industries, contractors are audited to ensure they conform with their operator’s requirements, which are often set in place by the owner-facility. Audits help employers understand what they could be doing better, challenge procedures, and ensure compliance standards. Depending on the industry, audits are performed at different times; for example, some audits are conducted routinely, such as quarterly or monthly for random pool selections and statistics. There is only one part of the process that is under your control, which is how prepared you are. If your drug testing program is audited,


here are a few things to expect, how you can prepare, and how to maintain industry best practices.


How to Prepare for Audits


When it comes to any type of compliance audit, the old saying, “an ounce of prevention is worth a pound of cure” rings true. Pre-audit preparation will guarantee a smoother ride once it is time for a real audit. DOT audits and Non-Regulated Program audits can vary wildly. Non-Regulated Program audits run by third-party auditing agencies can also vary from company to company or auditor to auditor. Here are some preparation tactics that are true across all programs and auditors:


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1. Be Aware. The best way to prepare your company is to be aware of exactly what the auditing agency’s expectations are. Employers should reach out to the auditing agency and confirm all applicable guidelines and requirements before the audit process ever begins. If something about your program or your statistics looks strange or your company doesn’t seem on track, your awareness will allow you to have the time to reach out, get help, and get you back on the right path.


2. Be Accurate. Use all available tools and resources to get compliant and track your results. Many third-party administrators offer compliance training, electronic record manage- ment software, and even system generated statistical reporting. If your company’s records don’t match what you see in your TPA’s software or on your statistical report, reach out and determine the cause of the apparent mix-up before an auditor ever has to ask you to.


3. Ensure Accessibility. Troughout the year, ensure that all of your necessary records are easy to access and readily available. If you switched third-party administrators, signed up for the first time, or were part of any other significant business decision, your records might be more confusing to an auditor than you think. Make sure that during each of these business changes your records remain accessible to you, and that you know where and how to retrieve them. If for some reason your records are no longer accessible, get it all in writing. Your TPA should be able


summer 2019


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