The FTA Drug & Alcohol Audit Process

George Y. Gilpatrick Jr. & John B. MorrisonSenior Auditors

What Should I Expect?

What You’ll GetProgram EvaluationTechnical AssistanceRegulatory Training

Notification

When does it occur?

Why was I selected? (and did I do anything wrong?)

What does the audit team need?

The Schedule Is the schedule flexible?

How long will the audit team be on-site?

Will the Region be involved?

What if we just got audited? From a different agency?

Pre-Audit Materials

What do I need to send? Completed contact information & schedule Copy of most current policy ALL testing records from examination

period: Random Pre-Employment Post-Accident Reasonable Suspicion Return-to-Duty and Follow-Ups if done

Pre-Audit Materials

Names of all vendors (MRO, SAP, Collection Sites)

Laboratory data Organization chart (if on hand) Names of individuals relevant to the

program (C/TPA officials)

Pre-Audit Materials

Optional Material:

Collector certificates

MRO certifications

SAP certifications

Pre-Audit Materials

Submit all materials on or before the listed submission date

Contractor data should come through Grantee

As much electronic information as possible

All Electronic Submissions

Fort Wayne, IN

Santee Wateree, Sumter, SC

State of Tennessee

Pre-Audit Materials

1 Copy to Team Leader (Contractor)

1 copy to USDOT Volpe Center

Q: How long will the audit take?

On-Site Visit “Whoa… Why the group?” Entrance Conference begins Audit If building is secured, auditors need

access passes Auditors need office or conference room DAPM needs to be available for majority

of time Operations Chief or Supervisor may also

be needed

4 Parts of the Audit

#1: Interviews with Transit System

DAPM/DER Interview (30-90 minutes)

Discussions with Operations Personnel

Discussions with HR

#2: Review of Records

Random tests Pre-Employment tests Post-Accident tests Reasonable Suspicion tests Return-to-Duty/Follow-Up tests Training schedule Route schedules

#2: Review of Records

Accident Reports and Files Employee Rosters Memos to and from Vendors Arbitrations and Disputes Internal Memos MRO verifications Lab reports

#3: Evaluation of Vendors

Phone interviews with:

MRO SAP (Must be local!) C/TPAInterviews are conducted in person when

possible

#3: Evaluation of Vendors

Visit to Collection Site for MOCK-Collection

Procedures at site closely evaluated Collection site and enclosure

inspected Staff interviewed

CONTRACTORS

Don’t Forget:

Contractors are YOUR responsibility. This includes service providers and security firms, in addition to vendors

Technical Assistance

Ask audit team to show you what they are doing. Learn how to inspect

Chains-of-Custody and other documents

#4: Technical Assistance

Auditors identify deficiencies Work with Transit system to develop

corrective actions Help with operational difficulties Help with administrative difficulties Suggest additional assistance Are available even after the audit

ends

Exit Interview

Auditors generally leave the guest-list to the Grantee

Usually between 30 and 60 minutes Report is an exceptions report

Will there always be findings?

State of Kansas

MUNI in San Francisco

Audit Team issued compliance letter on the spot during the exit interview

What Constitutes a Finding?

A direct violation of the federal regulations (49 CFR Parts 40 & 655)

Includes failure to submit pre-audit information

Does NOT include best-practices interpretations

Does NOT include any auditor preference

Transit System Rights

As the audited entity, you are entitled to know the citation for each finding.

Ask EVERY auditor, trainer, consultant, or “expert” to cite the regulation when a requirement is mentioned.

If a citation can not be found, it is NOT a finding.

Transit System Rights

As the audited entity, you are entitled to present information that will mitigate findings before the final report.

Response Period

Either 45 or 90 days to submit corrective actions response

Generally, policy revisions may be submitted at any time

Stay in contact with Audit Team Leader

Ask questions

Response Period

Responses evaluated by auditors

May require addition corrective action

Compliance

Compliance letter issued!

Am I Done?

Can still ask regulatory or compliance questions

Can still contact the audit team leader or team members

Can still ask for assistance

Questions & Answers

George Gilpatrick & John Morrison

will be available for questions

immediately following this presentation

Room 209-210