How Does eCCF Affect Workplace DOT Drug and Alcohol Testing?
While it may seem daunting to transition from paper forms to electronic documentation, in the case of eCCFs, the benefits are enormous.
The electronic Custody and Control Form (eCCF) is an electronic method of collecting information on drug test ordering and specimen collection processing, and acts as a chain of custody for workplace drug testing. It digitizes the paper Custody and Control Form along with all related documentation. The eCCF is the chain of custody and provides an automatic paper trail for testing.
The eCCF replaces the traditional paper Custody and Control Form (CCF), although it can also be used in conjunction with the CCF in a hybrid model that requires hard copies of certain documentation. The eCCF generally involves the use of a computer program and wizards, which walk users through the process of form completion. Collection sites use barcode scanners to both record and retrieve confidential data. Electronic signature pads automatically sync signatures to the eCCF. (Learn more in 8 Things Employers Should Know About DOT Drug and Alcohol Testing).
The eCCF can be used for a variety of tests including regulated urine drug tests and non-regulated drug tests as well as oral fluid, hair follicle and other testing. Breath alcohol testing, however, cannot utilize the eCCF. Ultimately, the eCCF is designed to improve the efficiency and speed of the employer’s drug testing process. To this end, the eCCF incorporates a number of specific efficiencies. These include:
Online drug test ordering and emailed authorization forms.
Paper-based records, which can be misplaced, damaged or even lost, are often the cause of major delays and errors. With the eCCF, these errors and delays can be either reduced drastically or eliminated altogether.
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The elimination of ordering and storing of paper copies of Custody and Control Forms (CCFs) and related documentation.
This means companies no longer have to dedicate resources to ordering, updating or storing the traditional five carbon copy version of the Custody and Control Form (CCF). Online storage is far less costly and allows for copies to be made at a fraction of the cost of paper copies.
It is no longer necessary for Medical Review Officers (MROs) to track down paper CFFs, thereby improving speed of results delivery to the employer.
Copy 2 can be immediately sent to the MRO of record with the laboratory. Reviews can be conducted quickly because donor identification and contact information is easy to access and easy to read.
Improved transparency allows the employer to quickly gauge where the specimen is in the process.
This means fewer phone calls, at all stages of the process, to track down tests and results. Since every step is logged and confirmed online, everyone is provided with real time information regarding the status of the test sample. This process is further simplified if only one identifying number is needed for the eCCF as is the case with most eCCF systems. In the past with paper CCFs, multiple identifiers and barcodes were used including requisition numbers and document IDs.
Immediate release of data from the eCCF will assist with improving outdated account and MRO demographic data.
Additionally, as all data is already logged digitally, compilation of demographic data will be much easier and will not require the labour-intensive efforts with respect to data entry that paper CCFs currently do.
Elimination of common recoverable flaws and the most common fatal flaw
Because eCCF uses computer programs which guide collectors and laboratory technicians and prompt them to fill out forms correctly and to provide all necessary information and signatures, numerous flaws are eliminated. These include common recoverable flaws such as temperature not indicated and missing collector name or signature and the most common fatal flaw, no printed and signed collector name. If a flaw does occur, the software used with the eCCF will prompt the user to follow the correct protocols.
Eliminate the issue of difficult to decipher written forms, signatures and reporting
Online documentation with fillable forms or typewritten responses eliminates the typical problems that arise when attempting to read forms or reporting that is completed entirely by hand. It also eliminates most of the errors that can occur in terms of interpreting dates and other information that is critical to establishing chain of custody.
In the United States, Department of Transportation (DOT) employers who use the eCCF must first ensure the laboratory they use for drug testing has been officially certified to use the eCCF through the Department of Health and Human Services National Laboratory Certification Inspection process. (Learn more in DOT vs. Non DOT Testing: What's The Difference?).
Employers must also ensure that they, the collection site, laboratories and the MRO are all using a compatible system. Electronic signatures may be used with the eCCF although a wet (handwritten) signature is required of the collector if the donor refuses to sign. Look for systems that provide alerts if a donor fails to show up for collection. A system that includes pre-populated data and is completely automated will also save time, streamline the process and help users avoid errors. Barcode enabled systems allow for a more simplified verification process. And finally, an eCCF system that enables companies to monitor the status of requested tests will provide immediate information on whether the test was completed, if the donor refused the test, or where exactly the test results are in the process.
As with any electronic record, privacy is a concern, but with appropriate security measures in place the eCCF is as safe as paper records. In April 2015, the U.S. Federal Government issued a ruling that has declared the eCCF appropriate for use in DOT regulated drug testing programs, a ruling that has added further credibility to the eCCF. Expectations regarding security and confidentiality remain the same for the eCCF as they are for the CCF, including the security of records and controls regarding access.
The collection process and the documentation requirements for the eCCF are also identical to those required for the CCF. The only difference is that the former is in electronic rather than hard copy (paper) form. Record retention requirements including the length of time and types of records that must be kept has not changed for the eCCF. There is also no need to update existing policy or notification requirements for workplace drug testing.
Making the switch to an eCCF is largely seamless. The first point of contact should be the drug testing provider to ensure they have eCCF available. Assuming they do, it is then a matter of ensuring collection sites are given access to, and are fully integrated with, the laboratory. Electronic forms along with the required software are typically given to workplaces by the testing provider. Training on the system is also typically provided by the testing provider. The learning curve for these systems is not steep and although there may be some initial resistance to giving up the traditional paper copies the payoff for the workplace can be invaluable in terms of time, cost and efficiency.