Aug. 17, 2020, the Office of Management and Budget (OMB) approved the revised Federal Drug Testing Custody and Control Form (CCF). DOT employers and their service agents (collectors, laboratories, MROs) are required to begin using the revised CCF by August 31, 2021.
The revised CCF can be viewed here.
What Updates were Made to the Revised CCF?
The majority of the changes to the revised CCF were made to accommodate the use of oral fluid specimens for the Federal drug testing program.
Oral fluid drug testing has been approved for U.S. Federal Workplace testing, but is not authorized under the DOT’s current drug testing program.
Other updates made to the revised CCF include:
- “CDL State and No.” have been added to the donor identification line (FMCSA only)
- A field for “other” has been added to the Collector Contact Info line to allow for an email address
- A field for the donor’s email address has been added
- The instructions on how to complete the CCF have been removed from the back of the form
Instructions for completing the CCF are now posted on the SAMHSA and ODAPC websites.
What is the Timeline for the Revised CCF?
While DOT-regulated employers and service agents were authorized to begin using the revised CCF starting September 1, 2020, the DOT has recommended that laboratories do not mail any of the revised CCFs to DOT-regulated clients or their service agents until after June 1, 2021.
The goal of this is to avoid confusion regarding whether oral fluid testing is authorized in the DOT program and to allow existing supplies to be utilized.
The revised CCF must be used after August 30, 2021.
If an old CCF is used after August 30, 2021, collectors must complete an MFR per 49 CFR § 40.205(b)(2).
If using an old CCF between now and the August 30, 2021 deadline:
No specific action is required. The new information required to be provided on the revised CCF (i.e., collector and donor e-mail addresses) may be included when using the old CCF, but it is not required.
What do DOT Employers Need to Do?
Now:
At this time, no action is required by DOT employers. Employers can continue using the old CCF until August 30, 2021.
By mid-year 2021:
Employers should coordinate with their third-party administrator and laboratory to ensure they have the updated Federal CCFs. Again, using the old CCFs after the August 30, 2021 deadline will require the collector to sign an MFR and will cause a delay in results.
No action will be required by clients of TEAM Professional Services.
As your partner in workplace compliance, we will coordinate with all non-electronic clinics to ensure they have the updated chain of custody forms available for our clients.
For more information on the revised CCF, review the Department of Health and Human Services Substance Abuse and Mental Health Services Administration’s guidance here.
