1. The FTA Drug & Alcohol Audit Process George Y. Gilpatrick Jr. & John B. Morrison Senior Auditors

2. What Should I Expect?

3. What You’ll Get  Program Evaluation  Technical Assistance  Regulatory Training

4. Notification  When does it occur?  Why was I selected? (and did I do anything wrong?)  What does the audit team need?

5. 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?

6. 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

7. 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)

8. Pre-Audit Materials  Optional Material: Collector certificates MRO certifications SAP certifications

9. 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

10. All Electronic Submissions  Fort Wayne, IN  Santee Wateree, Sumter, SC  State of Tennessee

11. Pre-Audit Materials  1 Copy to Team Leader (Contractor)  1 copy to USDOT Volpe Center  Q: How long will the audit take?

12. 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

13. 4 Parts of the Audit

14. #1: Interviews with Transit System  DAPM/DER Interview (30-90 minutes)  Discussions with Operations Personnel  Discussions with HR

15. #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

16. #2: Review of Records  Accident Reports and Files  Employee Rosters  Memos to and from Vendors  Arbitrations and Disputes  Internal Memos  MRO verifications  Lab reports

17. #3: Evaluation of Vendors  Phone interviews with: MRO SAP (Must be local!) C/TPA Interviews are conducted in person when possible

18. #3: Evaluation of Vendors  Visit to Collection Site for MOCK- Collection  Procedures at site closely evaluated  Collection site and enclosure inspected  Staff interviewed

19. CONTRACTORS Don’t Forget: Contractors are YOUR responsibility. This includes service providers and security firms, in addition to vendors

20. Technical Assistance Ask audit team to show you what they are doing. Learn how to inspect Chains-of-Custody and other documents

21. #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

22. Exit Interview  Auditors generally leave the guest-list to the Grantee  Usually between 30 and 60 minutes  Report is an exceptions report

23. Will there always be findings?  State of Kansas  MUNI in San Francisco Audit Team issued compliance letter on the spot during the exit interview

24. 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

25. 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.

26. Transit System Rights  As the audited entity, you are entitled to present information that will mitigate findings before the final report.

27. 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

28. Response Period  Responses evaluated by auditors  May require addition corrective action

29. Compliance Compliance letter issued!

30. 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

31. Questions & Answers George Gilpatrick & John Morrison will be available for questions immediately following this presentation Room 209-210