FTA D&A Audits:Tales from the Field and Experience of Your Peers

Jack Mastrangelo, Senior Auditor John Spelman, Audit Team Leader

FTA Drug & Alcohol ConferenceSt Louis, April, 2011

Notification

• When did it occur?

• Why was I selected? (And did I do anything wrong?)

• What did the audit team need?

The Schedule

• Was the schedule flexible?

• How long was the audit team on-site?

• Was the region involved?

• Had you recently been audited? From a different agency?

Pre-Audit Materials

• What were you asked to send?– Completed contact information & schedule– A copy of your policy– ALL testing records from examination period• Random• Pre-Employment• Post-Accident• Reasonable Suspicion• Return-to-Duty and Follow-Ups (if done)

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)

Pre-Audit Materials

• Optional Material:

– Collector certificates

– MRO certifications

– SAP certifications

Pre-Audit Materials

• Did you submit all materials on or before the listed submission date?

• Did contractor data come through the grantee?

• How co-operative were your vendors/contractors during the pre-audit process?

Electronic Submissions

• Approximately half of all pre-audit submissions are entirely electronic.– If you were notified next week, what percentage

of your records would be electronic?*

*There is no requirement that all records be electronic

Pre-Audit Materials

• Two copies to Team Leader (contractor)

• One copy to USDOT Volpe Center

• How long did it take to assemble the required materials?

On-Site Visit

• How did the audit effect your schedule?

• How did your agency react to the audit team?

How did the audit components effect you?

On-Site: Interviews with Transit System

• DAPM/DER Interview (30-90 minutes)– What was it like?

• Discussions with Operations Personnel

• Discussions with HR

On-Site: Review of Records

• Random tests

• Pre-Employment tests

• Post-Accident tests

• Reasonable Suspicion tests

• Return-to-Duty/Follow-Up tests

• Training records

On-Site: Review of Records

• Accident reports and files• Employee rosters• Memos to and from vendors• Arbitrations and disputes• MRO verifications• Positives• Lab reports

On-Site: Evaluation of Vendors

• Phone interviews with:– MRO: Did they tell you what the conversation was

like?

– SAP: Do you speak regularly?

– C/TPA: Did the audit change your professional relationship?

On-Site: Evaluation of Vendors

• Visit to collection site for mock collection

– Did you accompany the auditors?

– How did your view of the collection site change?

– What did you learn?

Contractors

• How did the audit change your contractors’ understanding of the regulations?

• How did it affect your oversight of your contractor(s)?

• How did your contractor(s) do?

Technical Assistance

• Did you receive adequate technical assistance before, during, and after the audit?

Technical Assistance

Did the audit team:• Identify deficiencies?• Work with the transit system to develop

corrective actions?• Help with operational difficulties?• Help with administrative difficulties?• Suggest additional assistance?• Remain available even after the audit ended?

Exit Interview

• Did the audit report accurately reflect the state of your drug and alcohol program?

Response Period

• How did the response period go?

• Was the auditor available before the response date?

• Were the corrective actions adequate?

Compliance

• When was the compliance letter issued?

• How many rounds did it take?

Follow-up

• Have you been audited more than once?

What was your overall impression of the process?

Thank you for attending.