Unique Situations for DAPMs How to Handle Them

Common Areas for Trouble

Internally◦Operations◦City Hall◦HR◦Employees◦Management◦Consultants

Common Areas for Trouble

Externally◦Collection Sites◦Mobile Collectors◦MRO◦TPA◦SAP

Common Areas for Trouble

Externally◦Insurer◦Public◦Outside representation

Caught in the Middle

DAPM & FTA

Collectors

Collection Site

Management

Employees

Vendors:MRO &

TPA

State or Grantee

Identifying Problem(s)

Investigate for yourself

Identify each deficiencyLocate the specific rate-limiting

stepRely on evidence

Analysis

Mitigation likelihood◦Resources◦Support◦Level of effort◦Resistance◦Expertise

Mitigation

INTERNAL ISSUES

Areas for IssuesOperations

◦Supervisors◦Logistics for testing/service

interruption◦Maintenance

Operations

Identify, Analyze, Plan, Resolve

Set VERY specific goals for Random Testing◦Actual dates and times for tests◦Don’t issue vague testing goals or

theories◦Be hands-on if needed (go to the

source)

Operations

Identify, Analyze, Plan, Resolve

Set VERY specific goals for Post-Accident Testing◦Go to the scene when possible◦Retrain in a brief gathering or formal

meeting◦Full debrief after each accident◦Call the collection site

City HallBilling Issues

◦Vendor Invoices: Can you monitor them? Can you withhold payment? Can you be involved?

Contracts/RFPs◦Do you have input into terms? Bid

evaluations? Selection?

City HallBilling Issues

◦Vendor Invoices: Institute proactive memos of approval

Contracts/RFPs◦Ask FTA for advice on

language/pitfalls◦Push for involvement

Human ResourcesUnderstanding of the

requirements◦Push/pull between Ops/HR/Exec◦Who is pushing for “efficiencies”?

• Closing the loop: Accident information is critical to D&A

program, but is often unavailable/difficult to receive

Random testing records Pre-employment clearances

Human ResourcesUnderstanding of the

requirements◦FTA can assist

• Closing the loop: Proactively request records for debriefing

and reviewing Be a pest

Employees

Notification vulnerabilities◦Are there internal vulnerabilities?◦How can you find out?

Employees

At the collection site◦Waiting time before collection◦Waiting time during◦Total time of test

Employees

Review the notification process for vulnerabilities

Work with the collection site to reduce waiting times

ManagementAre you supported in your

program?

Are your supervisors supported?◦Post-accident testing thresholds ◦Random spread requirements◦Return-to-duty◦Follow-up

ManagementSupport for testing requirements:

◦Post-accident: Present your side, but protect yourself in the documentation

◦Random: Educate management, continue to work with Ops

◦RTD & Follow-up: STAY ON TOP OF TESTING NEVER fall behind & contact FTA

immediately Protect yourself

ConsultantsAuthority

Advice

Changes

Expertise/Grasp of Local Dynamics

Consultants

Authority◦Are they clear about their

authority/sponsor?

Advice◦Is the advice correct? Is it personal

preference or regulation? Which regulation? Fed/State/Local?

Consultants

Changes◦Are the changes realistic? Overly

burdensome? Do they have program health/regulatory compliance as a result?

Expertise/Grasp of Local Dynamics◦FTA/FMCSA? Only one collection site?

ConsultantsAuthority: Require articulation of authority

before the visit. Contact FTA with concerns

Advice: The changes required or suggested must be backed up by regulation. Require citations and read the citations yourself

Changes: Require details about changes. Nothing is too specific

Expertise/Grasp of Local Dynamics: Be firm with your local approach if there is more than one path to compliance

EXTERNAL ISSUES

Collection SiteLimited hours/daysCheck-in timesCollection process protocols

◦Training◦The enclosure◦The CCF

Completeness & Accuracy

Collection SitePoor record transmittalDelays in reportingInattention to small clientsComplaints from

employees/supervisorsRepeated errors/affidavit

requirementsMobile collector problems

Check Every CCF

Completeness of the CCF◦Steps 1-5

Step 3 (unless the form is a Quest form)

Accuracy of the CCF◦Time, date, test type, testing

authorityTimeliness of the collection

process◦Start-to-finish times and wait times

Visit The Collection Site to Determine:

The order in which the collection was performed

The enclosure’s securityThe participation

requirements/allowances of the donor◦Remove outer garments◦Pockets◦Wallet

Require CorrectionsEliminating areas of concealment

within the enclosure is the goalEnsuring the supervision of the

donor is crucialFatal flaws must be corrected by

error correction training within 30 days

TipsAsk that responses from

collection site personnel be sent to you by email ◦Time/date included◦Correspondence trail included◦Easier to distribute as needed◦You can ask for photos, etc.

TipsAfter daylight savings time

adjustments, monitor your collection site for a clock adjustment on the EBT

If faxes are unclear, require digital photos of the CCF itself which can be emailed directly from a phone (8 megapixel or higher) while you await the paper copy

TipsIf you like a particular collector,

establish an on-call arrangement for late or early collections and pay them directly

Delay payment if needed for collection site unresponsiveness

TipsPrint bulletin cards for your

collection site◦Multiple contact numbers◦Testing authority (you can pre-print

these)◦Protocols

TipsProvide your collection site with

SASEs in which to send your Employer Copies (Copy 4) from each CCF◦At the time of each collection◦Sent in batches at beginning of each

testing period

TipsCheck your ATF and CCF to

determine which test occurred first

Maintain a collaborative relationship (if possible) with your collectors

Make appointments if possible (or needed)

Monitor your employee’s wait time before the collection (after arrival)

The Required OrderStep 1The collection of the specimenStep 2Step 3Step 5Step 4

The order is 1,2,3,5,4 and not 1,2,3,4,5

MRO/TPA/SAPRemember that THEY work for

YOU

You set the deadlines, dates, transmittal methods, and protocols in general

If you get repeatedly poor service, drop them. If your employer is not assisting, contact the FTA

Insurer/Public/RepresentationStay firm to the requirements

◦Read them, ask the FTA, or ask internally for assistance

Protect yourself with documentation

Remain calm and articulate your stance

Rely on evidence, not opinion or spin

Fixing ProblemsThe FTA can assist with

◦Policy◦New DAPM training◦Program evaluation◦Regulatory interpretation◦Regulatory application

Call the FTA Hotline(617) 494-6336

Or EmailFta.damis@dot.gov

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