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

Section 2. CONSIDERATIONS
IN ESTABLISHING
CONSORTIA
Although there are many advantages,
particularly for small transit operators, to
establish consortia, the advantages have
a “cost.” Consider those costs to your
organization prior to establishing or
joining a consortium and allow for the
following:
• Shared design
• Reduced control
• Financial considerations
• Administrative burden
Shared Design. Often, employers
establish the consortium’s operating
policies and procedures by consensus.
This process enables the consortium to
achieve its various goals while
addressing the needs of its individual
members, which will require some level
of compromise. Consequently, you may
need to compromise on some elements
of your program design and conform to
the design wishes of other consortium
members. For example, you may join a
consortium that provides services that
comply with the FTA and DOT
regulations, but may not provide other
elements that you consider important
(e.g., monthly random number selections
rather than quarterly). Accordingly, you
may need to contract for these services
on your own, or settle for a less than
optimum design.
Reduced Control. By joining a
consortium, each employer loses
operational autonomy over its testing
program. If you operated your own
program, your agency’s DAPM would
be solely responsible for its
administration following policies and
procedures under your sole control. This
will not be the case in a consortium. As
a result, it will be more difficult and time
consuming to effect changes in the
program. Conversely, the consortium
may make changes that you do not agree
with, but are powerless to avoid. In
addition, timely services may be difficult
to ensure, such as obtaining records or
resolving problems.
Your best protection against reduced
control is a sound contract with the
consortium. While you still may not be
able to effect changes by yourself, you
can ensure compliance with all
applicable laws and regulations. You
might also limit the consortium’s ability
to make changes without your approval
and provide for prompt withdrawal if
warranted.
Financial Considerations.
Although a consortium should reduce
your substance abuse program costs,
financial risks do exist. Failure of some
consortium members to pay their costs
may increase the burden on others under
some consortia models.
Consortia usually require a
membership fee when you join, in
addition to payments for testing services.
This fee may include the provision of
initial services such as policy
development or educational materials.
Charging a membership fee is a
reasonable and common practice, and in
virtually all cases the membership fee
will be less than the initial investment of
an in-house program. Nonetheless, the
membership fee may be several times
the cost of a single drug test, and small
agencies that anticipate joining consortia
should expect the fee and budget
accordingly.
Chapter 11. Joining a Consortium 11-5 August 2002