U.S Department of Health and Human Services has issued a revised Custody and Control Form (CCF) for federal testing programs, including DOT-mandated drug testing. After August 30, 2021, only the new CCF can be used. If the previous version is used after this date, results may be delayed and memoranda for record (MFR) will be required.
What is the difference?
The revised CCF is designed to accommodate the use of oral fluid or urine specimens. . Today, oral fluid is not an authorized specimen type for DOT (e.g. FMCSA, FAA, FRA, FTA, PHMSA, or USCG) testing.
The new Federal CCF changes include:
- Copies 1-5, Step 1: Added “CDL State and No.” to donor identification (FMCSA only);
- Copies 1-5, Step 1: Added “Other” (i.e., e-mail) to Collector Contact Info;
- Copy 1, Step 5a: Removed analyte names and checkboxes; repositioned results and checkboxes; and added a line for the certifying scientist to record the positive analyte(s) and concentration(s) if a positive result is recorded;
- Copies 2-5, Step 5: Added a line for the donor e-mail address;
- Copy 5: Removed instructions for completing the CCF from the back of the form. Instructions for completing the CCF are posted on the SAMHSA.
What will happen if I use an old CCF?
Not using the revised federal CCF might result in delays and potential canceled tests.
If an old CCF is used, a Memorandum for Record (MFR) or affidavit must be signed by the collector and provided to the laboratory for test results to be reported. The MFR must state that the old form contains all the information needed for a federal (e.g. DOT) drug test and explain why the old CCF was used. The MFR must also list the steps taken to prevent this from happening again.
How to avoid the use of an old CCF?
- Request new paper CCFs from your TPA/MRO and/or laboratory and have them ready by August 31.
- Make the transition to the eCCF (electronic version of the CCF). Changes to the CCF will be automatic on September 1, 2021 – no need to order new paper forms!