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

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complete drug and alcohol testing<br />

program, such as monitoring service<br />

agents, training, record keeping, etc.<br />

This model, although in use today by<br />

several transit agencies, is not<br />

technically considered a consortium<br />

under the FTA regulations, since the<br />

participating agencies have no ongoing<br />

relationship beyond the initial purchase<br />

arrangement.<br />

Separate Management Entity. In a<br />

separate management entity model, the<br />

consortium provides more extensive<br />

management functions for member<br />

agencies. The consortium may assist<br />

member agencies by monitoring and<br />

training employees, preparing reports,<br />

and procuring testing services at reduced<br />

prices. Member agencies sign an<br />

agreement, which specifies the<br />

management responsibilities of the<br />

consortium, how costs will be shared,<br />

and how testing will be achieved.<br />

Often, a state transit association or a<br />

state department of transportation takes<br />

the lead in establishing the consortium.<br />

The lead agency may hire staff and<br />

manage the program itself, or more<br />

commonly, contract with a TPA to<br />

perform management functions and<br />

procure testing services from individual<br />

service agents.<br />

This model requires strong<br />

leadership and agency commitment. A<br />

consortium administrator who is<br />

knowledgeable about the testing<br />

regulations, contracting, and the needs of<br />

the consortium members is required to<br />

provide oversight of the TPA or<br />

individual service agents. The cost of<br />

managing and operating the consortium<br />

is in addition to the cost of purchasing<br />

drug and alcohol testing services.<br />

However, the administrative costs are<br />

spread among the member agencies.<br />

Either consortium staff or a TPA<br />

obtain testing services. In-house<br />

management requires a staff large<br />

enough to oversee each of the individual<br />

service contracts, process billing, and<br />

perform administrative functions of the<br />

consortium. Hiring a TPA allows for a<br />

single point of control between the<br />

consortium and the individual service<br />

agents. The TPA should have<br />

demonstrated expertise with the DOT<br />

testing program. The TPA is essentially<br />

a general contractor, who subcontracts<br />

with other service agents to provide the<br />

full package of testing services required.<br />

The separate management entity<br />

model provides members with<br />

management expertise and avoids the<br />

costs each member would otherwise be<br />

forced to absorb in the hiring or training<br />

of its own expert. While this model<br />

provides expertise and flexibility in<br />

management, this high level of service<br />

may be expensive. Also, TPAs have<br />

limitations (previously discussed in<br />

Section 3) that must be taken into<br />

Chapter 11. Joining a Consortium 11-8 August 2002

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