A new Department of Health and Human Services Federal Drug Testing Custody and Control Form (CCF) for DOT urine collection was mandated on Oct. 1, 2010, with an extension provided for using the old CCF until Nov. 30. This extension helped to minimize costs by allowing employers to use up their supply of old forms rather than discarding them.

But, starting Dec. 1, the new CCF must be used or else the drug test will be cancelled. The laboratory, consortium/third party administrator (C/TPA) or other party that provides CCFs to employers and collection sites must no longer provide copies of the expired forms to employees or applicants.

The revised CFF now has a line for the medical review officer (MRO) to note the drug(s) for which a positive result is verified and a new line item, “other,” for documenting other refusal-to-test situations. There is also a new section that spells out, in one place, the information that employers and their C/TPAs must routinely provide to collectors.

Another amendment filed Tuesday changes the definition of “continuing education” contained in the final rule. Now, it is defined as “training for substance abuse professionals (SAPs) who have completed qualification training and are performing SAP functions, designed to keep SAPs current on changes and developments in the DOT drug and alcohol testing program.” Last year, DOT eliminated the requirement for the MRO to complete continuing education units to satisfy the re-qualification training requirement but failed to amend this definition. Other amendments to the final rule were minor.