With the Federal form change deadline of August 2023 quickly approaching, we want to ensure you know that using the ‘old’ version of the paper Custody and Control Form (CCF) may result in significant delays of drug test results.
Old forms used after August 2023 will require a Memorandum for Record (MFR), also referred to as an affidavit, be sent proactively to resume specimen processing. This additional step may create lab processing delays, and may have a negative impact on specimen turnaround times.
To avoid these occurrences, we ask that you stop using and purge the old DOT paper CCF and begin strictly using the new forms as soon as possible to avoid any delays in your specimen testing results.
Learn more about the U.S. Department of Transportation’s guidance to the revised Federal drug testing custody and control form.
Stay compliant with new forms
While more than one-third of the regulated drug tests that our laboratories process are accompanied by an electronic CCF, the majority are still driven by paper-based documentation.
While we’ve seen the balance of old-to-new forms gradually shift throughout 2023, many regulated tests received in our laboratories include Federal CCFs that are set to expire in August, which will soon render the documentation non-compliant with the current regulations, may cause significant delays to testing, or if not rectified by an affidavit may result in a specimen fatal flaw.
Using an old form after its expiration in August may result in unnecessary processing delays and potential fatal flaws if a specimen is not accompanied by a corrective memorandum for record (MFR).
What if I used an ‘old’ CCF?
DOT-regulated employers and their service agents (collectors, laboratories, Medical Review Officers) may not use the current ‘old’ version of the CCF for U.S. Department of Transportation (DOT)-mandated drug test collections after August 2023.
If, as a collector, laboratory, Medical Review Officer, employer, or other person implementing these drug testing regulations, you become aware of the use of a non-Federal form or an expired Federal form, you must provide a signed statement (i.e., a memorandum for the record or MFR). It must state that the incorrect form contains all the information needed for a valid DOT drug test, and that the incorrect form was used inadvertently or as the only means of conducting a test, in circumstances beyond your control. The MFR statement must also list the steps you have taken to prevent future use of non-Federal forms or expired Federal forms for DOT tests.
Download our MFR collector’s certification statement.
We encourage you to proactively prepare for this change and double-check your paper CCF inventory today.
Read our FAQs about regulated drug testing.
Additionally, consider switching to eCCF for both Federal and non-federal drug testing. As an eCCF-approved laboratory, Quest Diagnostics always uses the most current CCF.
Paper is the past – go green with eCCF!
Electronic Custody and Control forms (eCCF) for Federal drug testing programs is available today from Quest Diagnostics at no additional cost. Don’t hassle with another paper form expiring when eCCF is always a seamless and paperless transition.
Benefits of adopting eCCF:
- Send drug test authorization forms by email to donors
- Less storage of unused paper forms
- Decrease possibility of manual form fill errors and better legibility
- Consistent and predictable experience with this digital solution
Lean more about eCCF through your account manager or our national customer support team at 1.800.877.7484.