Drug and Alcohol Audit Services
for Public Transit Systems

ICF International evaluates the compliance of drug and alcohol testing programs for transit systems to help clients identify and resolve deficiencies. Ensuring compliance with U.S. Federal Transit Administration (FTA) regulations maintains public confidence in the safety of your system, protects against serious liability, and ensures federally-protected worker rights. Over time, all grantee testing programs will be audited, and many will be re-audited. ICF International offers a customizable approach that can meet the needs of any transit system or contractor. We can interview your staff, evaluate your testing program management and quality assurance program, and educate your staff on methods to improve compliance and perform self-auditing.

Fact Sheet on Drug and Alcohol Audit Services for Public Transit Systems

U.S. Federal Transit Administration (FTA) regulations mandate that all transit systems receiving FTA grants (5307, 5309, and 5311) must test safety-sensitive employees for drugs and alcohol. FTA’s Office of Safety and Security audits these testing programs for compliance with regulatory standards. Each audit concludes with a final audit report detailing all noncompliance issues. This report is publicly available via the Freedom of Information Act (FOIA) and is therefore accessible to interested parties such as newspapers, public interest groups, and unions.

Our Capabilities

ICF International has proven experience with the FTA drug and alcohol auditing process. ICF International was the prime contractor of FTA’s drug and alcohol auditing program from its inception in 1997 through September 2005. ICF International was instrumental in helping FTA design and implement the program and has led or participated in more than 400 grantee and contractor testing program audits. Our seasoned auditors are fully versed in the FTA audit process and FTA and U.S. Department of Transportation (DOT) drug and alcohol testing regulations (49 CFR Parts 655 and 40). We know how to rapidly identify and efficiently resolve any potential audit deficiencies.

With our in-depth knowledge and field experience, ICF International is uniquely positioned to provide the technical assistance, best practice suggestions, and process improvements necessary to:

• Obtain full regulatory compliance
• Improve detection and deterrence of employee drug and alcohol use
• Reduce program operating costs and liability risks

Some of our customizable service offerings include:

• Assistance in preparing for an FTA drug and alcohol testing program audit
• On-site audit of programs, collection sites, and contractors
• Assistance in responding to FTA audit findings and reports
• Drug and alcohol policy review and policy creation
• Implementation of best practices
• Providing technical assistance and answering questions
• Drug and Alcohol Program Managerm (DAPM) training
• Reviewing forms, procedures, and practices

Key Questions

• Is your staff knowledgeable about the current FTA drug and alcohol regulations, interpretations, and program updates?
• Have you evaluated your drug and alcohol policy for compliance within the past two years?
• Have you evaluated your collection sites and contractor testing programs in the last year?
• Has your system had any accidents involving operator impairment from alcohol or drugs?
• Does your system have post-accident positive tests and no random positive tests—an indication that your “random” testing program might be predictable?
• Have you received adulterated, substituted, or fatally-flawed drug test specimen results?
• Does your staff have a reliable source of up-to-date information to answer testing program questions quickly and accurately?
• If your system was notified of a pending FTA audit tomorrow, could you produce the necessary materials within 3 weeks?

The FTA Auditing Process

An FTA field audit has three components:

1. pre-audit

2. on-site audit

3. post-audit

PRE-AUDIT

Seven weeks prior to an on-site audit, FTA notifies a grantee of the audit. The letter proposes a schedule and requests specific information on the grantee and covered contractors that must be submitted within 3 weeks of receiving the letter. As part of this component, FTA conducts a review of the system drug and alcohol testing policy.

ON-SITE AUDIT

The FTA contractor audit team extensively interviews the testing program staff, including the Drug and Alcohol Program Manager (DAPM), the Medical Review Officer (MRO), the Substance Abuse Professional (SAP), and the Consortium/Third Party Administrator (C/TPA), if applicable. The audit team visits the collection site(s) and conducts mock urine and breath collections. The team also evaluates testing records including chain of custody forms; employee training records; former DOT employer testing records requests; and records regarding pre-employment, random, post-accident, reasonable suspicion, return-to-duty, and follow-up testing.

POST-AUDIT

At the completion of the onsite audit, the grantee receives a final audit report identifying each item of non-compliance. The transit system is given 90 days to resolve all items. If any item is not resolved in 90 days, FTA issues subsequent reports with shorter response times. For a re-audit, faster responses are required.

Complexities of Managing a Drug & Alcohol Testing Program

ICF International understands the obstacles that transit systems face in managing their programs. For example:

• DAPM turnover is often high, which makes ensuring compliance challenging. Each new DAPM has a lot to learn about the complicated rules.
  
  
• Contractor oversight is difficult and time consuming, in terms of both the number of covered contractor testing programs and program components to review.
  
  
• Many systems depend heavily on a C/TPA to manage essential program functions, but the ultimate responsibility for compliance remains with the grantee.
  
  
• Suburban and rural systems may have staff resource constraints and difficulty identifying compliant collection sites and SAPs.
  
  
• State DOT employees often must cover vast distances to assist and audit FTA grant subrecipients.

Whether you need help preparing for an upcoming audit, evaluating your existing testing program, responding to audit findings, re-training your staff, or refining your program, ICF International has the solutions and can deploy them quickly.