Implementation Guidelines - Federal Transit Administration - U.S. ...

test and the administrative costs. Given
the existing demands on your staff, it
may be less expensive in the aggregate
to purchase administrative services from
another entity rather than providing
those services on an in-house basis. You
should also consider if your agency has
the necessary legal resources and
expertise available to guide the
development and implementation of
your program. Is it better to have an
independent, professional third party
involved to help with program
compliance?
Exhibit 11-3 (located in the Sample
Documentation section) defines
consortium responsibilities for the four
major program parts. Which of these
functions can your agency perform?
Which should be left to a C/TPA?
After evaluating your needs and
available resources, then decide if
consortium membership is the best
option for your organization. There are
no uniform criteria for answering this
question. In the end, your agency is
responsible for full implementation of
your drug and alcohol testing program,
regardless of whether or not you contract
for individual testing services.
If, after weighing the advantages and
disadvantages, you determine a
consortium membership is the best
approach, decide whether to join an
existing consortium, or if you need to
work with others to develop a new
consortium to meet your specific needs.
The Drug and Alcohol Consortia
Manual, prepared for the Ohio
Department of Transportation in 1996
and reprinted and distributed by the
FTA, provides guidance on how to
design, establish, and administer a drug
and alcohol testing consortium. This
publication should be consulted for
additional background information,
sample procurement documents,
contracts, and a member agency
Memorandum of Agreement.
Section 6. THE IMPORTANCE
OF YOUR CONSORTIUM
CONTRACT
Regardless of the consortium model
you select, you should realize that you
are entering into a contractual
relationship, and your interests should be
protected. Although you are following
the regulations through a consortium,
you remain responsible to FTA for
compliance. This means that if the
consortium is implementing some aspect
of the program incorrectly, your system
is implementing it incorrectly. You
should exercise due diligence in
selecting a consortium, and in
monitoring its operations.
Federal law prohibits FTA from
funding your transit system if it is out of
compliance with alcohol misuse or
prohibited drug regulations. Therefore,
you must exercise your best
management practices both before and
after you select or establish a
consortium.
Depending on your needs and those
of other consortium members, you may
purchase a variety of required or
optional services offered by the
consortium. Some consortia require
members to purchase all their services,
where others allow you to buy only
those you need. Consortium assistance
might include the following:
• Policy development
Chapter 11. Joining a Consortium 11-12 August 2002