After August 30, 2021, using the old DOT CCF form will cause affidavits and result in delays.
The Department of Transportation (DOT) announced the updated and revised Federal Custody and Control (CCF) for DOT drug testing is available now and must be used by August 30, 2021. This is a required component of the DOT drug testing program.
If an old Federal CCF form is used after August 30, 2021 a memorandum for record (MFR), or an affidavit will be required by laboratories before DOT urine specimens are tested, which will ultimately cause delays.
Laboratories receive thousands of specimens each night and lab technicians review all chain of custody forms to make sure each chain does not have missing information. When it is determined that a chain is not complete, the lab then determines whether the flaw is correctable or fatal.
If one of the seven fatal flaws are committed, the test is canceled and reported to the MRO as a fatal flaw.
One example of a fatal flaw is when the collector does not print their name and sign the chain.
In the case of a correctable flaw, the lab sends a memorandum of record (or affidavit) to the collector to be completed and sent back to the lab.
An example of a correctable flaw is when the lab receives an old CCF and requests an affidavit to be fixed. The lab cannot proceed with testing the sample until they receive the completed memorandum, which delays the overall resulting times.
Some common questions surrounding the New CCF Form
Who do these form changes affect?
- Consortia/Third Party Administrators (C/TPAs)
- Collection sites
- Medical Review Officers (MROs)
How do I know if I have the old DOT CCF form or the new DOT CCF form?
The easiest way to know the difference is that Copy 1 Lab copy in Step 2 has information about ORAL FLUID testing. The old form does not mention Oral Fluid.
Is Oral Fluid testing now authorized?
No. DOT has not yet authorized Oral Fluid testing, do not collect oral fluid using these new DOT CCF forms.
What should I do with the old CCF forms?
As soon as you have the new DOT CCF’s, throw away the old DOT CCF’s, this is critical.
Where can I find official information on this?
Where do I get the new CCF forms?
Whoever manages your drug testing account, Lab or TPA can assist you so that you receive the new DOT CCF form before August 30, 2021. Many labs are saying to order the new forms in July.
Another option is to work with a third-party administrator (TPA) that can provide you with electronic ordering (eCCF) with no paper drug testing forms.
How can I stay compliant with this change?
Our Compliance Specialists can assist you with any questions you might have.