Collection site proof of qualifications
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I am updating our DOT Substance Abuse Program, and I can't figure out just what records we are required to get from our collection site in order to verify that the collectors are qualified.
I have the list from the Federal Register that shows our testing lab meets minimum standards, and the MRO sent us a copy of his MRO certificate verifying his certification.
But we use a medical clinic for our collections, and in the past we have asked them to have every collector they employ (that could possible do our collections) sign a long list verifying their certifications and stating that if they leave the employment of the medical clinic that they will notify us. This form just doesn't seem reasonable to me (really - who is really going to notify us if they leave the clinic's employment?) Also, this is so much to keep updated, constantly checking to see if they have new staff!
It seems to me that we should have just one general agreement signed by an authorized rep. of the clinic stating that they will only employ collectors who meet the qualfications, and that the clinic will follow all procedures as outlined by FMCSA, including any new regulations that occur. This should not need to be updated.
But I can't seem to find any documentation saying specifically what we are required to have. Anybody else know? What do others do with their DOT programs if you use an outside collection site?
I have the list from the Federal Register that shows our testing lab meets minimum standards, and the MRO sent us a copy of his MRO certificate verifying his certification.
But we use a medical clinic for our collections, and in the past we have asked them to have every collector they employ (that could possible do our collections) sign a long list verifying their certifications and stating that if they leave the employment of the medical clinic that they will notify us. This form just doesn't seem reasonable to me (really - who is really going to notify us if they leave the clinic's employment?) Also, this is so much to keep updated, constantly checking to see if they have new staff!
It seems to me that we should have just one general agreement signed by an authorized rep. of the clinic stating that they will only employ collectors who meet the qualfications, and that the clinic will follow all procedures as outlined by FMCSA, including any new regulations that occur. This should not need to be updated.
But I can't seem to find any documentation saying specifically what we are required to have. Anybody else know? What do others do with their DOT programs if you use an outside collection site?
Comments
Don't get tied up in knots with certificatiions upon certifications it is not necessary, as long as the physician is a licensed physician in practice within your state.
Good luck!
PORK
Disclaimer: This message is not intended to offend or attack. It is posted as personal opinion. If you find yourself offended or uncomfortable, email me and let me know why.
I've found that collection sites can be wiley - they don't want to do everything they're supposed to do. They lose the ccf or give it to the employee directly. Or they don't want to stay open in the case of an insufficient sample. It helps to have a contract with them and also to have alternative collection sites available that you can use if the first one is not cooperative.
Half HR
Thanks to everyone for the info.
Half HR