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Frequently Asked Questions About Federal Workplace Drug Testing

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Mandatory Guidelines and Drug Testing Advisory Board

No. The Mandatory Guidelines for Federal Workplace Drug Testing Programs do not address the question of fitness for duty.

Source: DWP Staff, 240-276-2600

The Mandatory Guidelines for Federal Workplace Drug Testing Programs provide the scientific and technical structure for the drug testing of employees in all civilian positions in Executive Branch agencies. Among these are positions that affect public safety, public health, or national security in which even a momentary lapse of attention or judgment could result in significant harm and are therefore designated for random drug testing. Revisions to the Mandatory Guidelines are intended to enhance public safety. See (Guidance for the Selection of Testing Designated Positions (PDF | 262 KB)).

No. The Mandatory Guidelines for Federal Workplace Drug Testing Programs do not cover non-federal employees. They address only federal civilian employees and federal agencies required by law to use the Mandatory Guidelines for Federal Workplace Drug Testing Programs (e.g., the Department of Transportation and Nuclear Regulatory Commission. See (Mandatory Guidelines – Urine) and (Mandatory Guidelines - Oral Fluid), Section 3.4.

Source: DWP Staff, 240-276-2600

Revisions to the Mandatory Guidelines for Federal Workplace Drug Testing Programs cover all civilian employees in Executive Branch agencies. Employees should contact their federal agency employer or refer to their employer’s (agency’s) Drug-Free Workplace Program plan to learn how these revisions will affect them or their agency.

Source: DWP Staff, 240-276-2600

To continue serving as an MRO for federal agency specimens, certified MROs must have completed training prior to the October 1, 2017 effective date. See (Mandatory Guidelines – Urine), Section 13.3.

Four semi-synthetic opioids (hydrocodone, hydromorphone, oxycodone, oxymorphone) were added to the list of drugs for which federal civilian employees are routinely tested on October 1, 2017. See (Mandatory Guidelines – Urine), Section 3.4. The authority to use oral fluid, in lieu of urine, drug testing was effective on January 1, 2020. See (Mandatory Guidelines – Oral Fluid).

The Drug Testing Advisory Board (DTAB) advises the Assistant Secretary for Mental Health and Substance Use, SAMHSA, based on an ongoing review of the direction, scope, balance, and emphasis of the agency’s drug testing activities and the National Laboratory Certification Program (NLCP). See (Drug Testing Advisory Board).

The DTAB reviews the NLCP for federal workplace drug testing programs as required by Public Law 100-71 and as described in the Mandatory Guidelines for Federal Workplace Drug Testing Programs. See (Mandatory Guidelines – Urine) and (Mandatory Guidelines – Oral Fluid). It recommends areas for emphasis or de-emphasis, new or changed directions, and mechanisms or approaches for implementing recommendations. Periodically, the Board reviews specific science areas on new drugs of abuse and the methods necessary to detect their presence.

Source: Drug Testing Advisory Board (DTAB).

For information about DTAB meetings, please see the list of DTAB meetings at: (Advisory Council Meetings). When available, a link to register to attend the next open DTAB meeting, can be found at: (SAMHSA NACRegister). For further information about DTAB, please go to (Drug Testing Advisory Board). If there are further questions, please contact DWP (dwp@samhsa.hhs.gov or 240-276-2600).

Source: DWP Staff, 240-276-2600

The DTAB meeting schedule can be found at the SAMHSA Advisory Council Meetings webpage at (Advisory Council Meetings).

Specimens and Drugs Tested

No. Effective January 1, 2020, a federal agency may collect an oral fluid specimen for its workplace drug testing program. Oral fluid and urine are the only specimen types currently authorized for collection by the Mandatory Guidelines for Federal Workplace Drug Testing Programs. See (Mandatory Guidelines – Urine) and (Mandatory Guidelines – Oral Fluid).

Specimens collected and split according to the Mandatory Guidelines for Federal Workplace Drug Testing Programs, analyzed at a laboratory with National Laboratory Certification Program (NLCP) certification, and reviewed by a trained Medical Review Officer have very high reliability. Provision for testing the second split of the specimen adds a further safeguard.

Source: DWP Staff, 240-276-2600

Opioids

The misuse and abuse of psychotherapeutic prescription drugs, including opioid pain relievers, are issues of concern for all populations regardless of age, gender, ethnicity, race, or community. Opioid-related overdose deaths in the United States now outnumber overdose deaths involving all illicit drugs (e.g., heroin and cocaine) combined. See (Overdose Death Rates | National Institute on Drug Abuse). In addition to overdose deaths, emergency department visits, substance treatment admissions, and economic costs associated with opioid abuse have all increased in recent years.

The Mandatory Guidelines for Federal Workplace Drug Testing Programs and the Federal Drug-Free Workplace Program are deterrents to illicit use of opioid drugs and encourage federal civilian employees to seek treatment for opioid use disorders. The Mandatory Guidelines for Federal Drug Testing Programs framework with partners at the federal, state, and local levels to implement policies and programs to reduce prescription drug misuse and improve public health. Specifically, the Mandatory Guidelines for Federal Drug Testing Programs provide for screening for illicit opioid use among federal and civilian employees in safety and security sensitive positions.

Source: DWP Staff, 240-276-2600

The inclusion of the four most commonly misused Drug Enforcement Administration (DEA) Schedule II prescription medications (i.e., oxycodone, oxymorphone, hydrocodone and hydromorphone) in the list of authorized drug tests was recommended by the DTAB, reviewed by the Department of Health and Human Service’s Prescription Drug Subcommittee of the Behavioral Health Coordinating Committee, and approved by the SAMHSA Administrator in January 2012.

The inclusion of oxycodone, oxymorphone, hydrocodone and hydromorphone in the Mandatory Guidelines for Federal Workplace Drug Testing Programs for urine or oral fluid drug testing is supported by various data and seen in private sector experiences with current drug abuse trends. See (Mandatory Guidelines – Urine) and (Mandatory Guidelines – Oral Fluid). HHS is continuing its efforts to prevent opioid addiction in support of combating the opioid crisis. Implementing these revised guidelines will help ensure safety in the federal workplace and national security, public health, and public safety occupations.

Source: DWP Staff, 240-276-2600

Yes. Drug test panels currently test for the 6-acetylmorphine metabolite of heroin (6-AM). The expanded opioids drug test does not change the current testing profiles for 6-AM. See (Mandatory Guidelines – Urine) and (Mandatory Guidelines – Oral Fluid), Section 3.4.

No. Testing for the synthetic opioid, fentanyl, is not included in the revised urine Mandatory Guidelines for Federal Workplace Drug Testing Programs. However, fentanyl can be tested for on a case-by-case basis. SAMHSA’s Division of Workplace Programs (DWP) is reviewing the prevalence rate of fentanyl in regulated specimens. See (Mandatory Guidelines – Urine) and (Mandatory Guidelines – Oral Fluid), Section 3.2.

The term “opiates” is used to describe naturally occurring alkaloid substances derived from the opium poppy plant (e.g., codeine and morphine) that bind to specific receptors in the central nervous system and have analgesic as well as narcotic effects. Heroin is a semi-synthetic opioid that is manufactured by acetylating morphine.

The term “opioids” has expanded in scope over time and is broadly used to describe various compounds that bind to opioid receptors in the central nervous system and have analgesic as well as narcotic effects. The term “opioids” includes naturally occurring alkaloid compounds known as opiates (e.g., codeine and morphine); semi-synthetic compounds (e.g., heroin, oxycodone, oxymorphone, hydrocodone, and hydromorphone); and synthetic compounds (e.g., fentanyl). Opioids may or may not have structural similarity to the opium alkaloids. See (Medical Review Officer Guidance Manual), Appendix A: Glossary.

Positive drug test results that are explained by a legitimate medical explanation, such as a valid prescription, will not be reported to a federal agency. See (Medical Review Officer Guidance Manual), Chapter 4.5.

If a positive drug test result is not supported by a legitimate medical explanation (such as a valid prescription), the positive drug test result will be reported to the employee’s federal agency in accordance with the Mandatory Guidelines for Federal Workplace Drug Testing Programs. See (Medical Review Officer Guidance Manual), Chapter 4.5.

There is no deadline for agencies to submit updated/revised Drug-Free Workplace Program plans, but HHS requests that such plans be submitted as soon as practicable following any changes made in an agency’s plan.

Source: DWP Staff, 240-276-2600

Yes.

Source: DWP Staff, 240-276-2600

Yes. Review by the Interagency Coordinating Group Executive Committee (ICGEC) is not required for an agency with a certified plan to begin testing for the four semi-synthetic opioids (oxycodone, oxymorphone, hydrocodone, hydromorphone). If you do not have a certified plan, contact DWP at 240-276-2600 regarding the next steps.

Source: DWP Staff, 240-276-2600

No. The addition of the four semi-synthetic opioids (oxycodone, oxymorphone, hydrocodone, and hydromorphone) to the drug testing panel is not considered a “substantive change” to an agency’s plan.

A “substantive change” is any alteration to a federal agency’s drug-free workplace plan that affects the substance of the plan’s policy and/or procedures, such as adding or eliminating applicant testing. It does not refer to purely editorial changes, administrative updates, or exercises of authority under the Mandatory Guidelines for Federal Workplace Drug Testing Programs. Federal agencies should consult with their legal counsel and labor and employee relations staff to determine the impact of any changes on collectively bargained agreements and should contact DWP staff (dwp@samhsa.hhs.gov or 240-276-2600) to receive tailored guidance that is specific to their plans.

Source: DWP Staff, 240-276-2600

Yes. The decision if and when to add the four semi-synthetic opioids to the panel of drugs routinely tested for is an area of agency discretion. Effective October 1, 2017, federal agencies are required to test each specimen for marijuana and cocaine and are authorized to test each specimen for opioids, amphetamines, and phencyclidine. Additional semi-synthetic opioids now include oxycodone, oxymorphone, hydrocodone, and hydromorphone. See (Mandatory Guidelines – Urine), Sections 3.1 and 3.4.

Yes. Agencies are responsible for contacting their service providers to request expanded testing.

No. Agencies are not required to use the notification template. Since some agencies were not prepared to add the additional analytes by October 1, 2017, SAMHSA instructed those agencies to notify their service providers of the date they will begin testing their workplace specimens for these drugs and provided the template for the agency’s use. Subsequently, in a September 8, 2017, Federal Register Notice, SAMHSA instructed laboratories to contact federal agency clients that had not yet notified the laboratory of their decision. A letter was emailed to Drug Program Coordinators on August 16, 2017. An NLCP Notice to HHS-Certified and Applicant Laboratories and NLCP Inspectors was emailed September 8, 2017.

Source: DWP Staff, 240-276-2600

Yes. Agencies will report test results for the four newly added semi-synthetic opioids. Yes. The ASR has been revised to capture results of the added semi-synthetic opioids.

Source: DWP Staff, 240-276-2600

Marijuana, Hemp, and CBDs

Consult with your agency’s Ethics Office, Office of General Counsel, Human Resources, and Office of Safety and Security regarding your specific situation.

Source: DWP Staff, 240-276-2600

Consult with your agency’s Ethics Office, Office of General Counsel, Human Resources, and Office of Safety and Security regarding your specific situation.

Source: DWP Staff, 240-276-2600

There is no official definition at this time. There is, however, significant public discussion around marijuana, much of which includes the terms legalization, decriminalization, and medical marijuana. See: (DEA Marijuana Factsheet) (Marijuana is listed under DEA CSA 7360 as Cannabis, marijuana) and (DEA clarification of the new drug code) (7350) for marijuana extract.

No. The Mandatory Guidelines for Federal Workplace Drug Testing Programs analyte profile does not include the testing for the chemical compound delta-8-tetrahydrocannabinol. See (Mandatory Guidelines – Urine) and (Mandatory Guidelines – Oral Fluid), Section 3.4.

The chemical analyte tested for in both the initial screening and confirmation test is delta-9-tetrahydrocannabinol-9-carboxylic acid (THCA). See (Mandatory Guidelines – Urine) and (Mandatory Guidelines – Oral Fluid).

Urine Specimen Collections

Employees can expect to be received by trained professionals in a controlled collection setting and to receive an explanation of the process. See (Mandatory Guidelines – Urine), Subpart H.

The following privacy requirements apply when a donor is providing a routine urine specimen:

  1. Only authorized personnel and the donor may be present in the restricted access area where the collection takes place.
  2. The collector is not required to be the same gender as the donor.
  3. The collector must give the donor visual privacy while providing the specimen. The donor is allowed to provide a urine specimen in an enclosed stall within a multi-stall restroom or in a single person restroom during a monitored collection. See (Mandatory Guidelines – Urine) Subpart H.
  1. A direct observed collection procedure is the same as that for a routine collection, except an observer watches the donor urinate into the collection container. The observer must be the same gender as the donor with no exception to this requirement.
  2. The gender of the observer for purposes of a direct observed collection must be the same as the donor’s gender, which is determined by the donor’s gender identity.
  3. The gender of the monitor for a monitored collection must be the same as the donor’s gender, unless the monitor is a medical professional (e.g., nurse, doctor, physician's assistant, technologist, or technician licensed or certified to practice in the jurisdiction in which the collection takes place).
  4. The collector for an observed collection asks the donor to identify the donor’s gender on the Federal Custody and Control Form (CCF) and initials it. The collector then selects an observer whose gender matches the gender of the donor (as recorded on the Federal CCF).
  5. The collector documents the observer’s name and gender on the Federal CCF. The same procedure is used to select the monitor for a monitored collection unless the monitor is a medical professional.

See (Mandatory Guidelines – Urine), Subpart H, Sections 8.1, 8.10, and 8.12.

The collector notifies the federal agency for authorization to collect an oral fluid specimen or follows the federal agency’s standard protocol. If authorized, the collector will proceed with an oral fluid collection. If not authorized, the collector stops the collection and reports the donor’s inability to provide a sufficient urine specimen to the federal agency and the MRO. The MRO notifies the federal agency to direct the donor to obtain an evaluation from a licensed physician acceptable to the MRO of any pre-existing condition that prevented or will prevent the applicant or employee from providing sufficient urine for drug testing. The MRO may conduct the evaluation if qualified. Depending upon the MRO determination based on the medical evaluation, further actions may be warranted.

See (Medical Review Officer Guidance Manual), Section 6.2 and (Mandatory Guidelines – Urine), Sections 8.5, 8.6, and 13.6.

Observed Collections: When an observed collection is conducted, the observer is the person assigned to physically observe the collection of the specimen. The observer’s gender must be the same as the donor’s (which is based on the donor’s gender identity). The observer is not required to be a trained collector but must be trained as an observer. An observed collection is the same as a routine collection except the observer is in the restroom or stall and watches the donor urinate into the collection container. The observer maintains visual contact with the specimen until the donor hands the container to the collector. The collection container cannot be handled by the observer unless the observer is also serving as the collector.

Monitored Collections: When a monitored collection is conducted, a monitor is the person assigned to monitor collection of the specimen. The monitor’s gender must be the same as the donor’s (which is based on the donor’s gender identity) unless the monitor is a medical professional. The monitor is not required to be a trained collector. It is the same as a routine collection, except the monitor provides visual privacy while being alert for signs of tampering. The monitor must not touch or handle the collection container (unless the monitor is also serving as the collector) and must not watch the donor urinate into the collection container.

See Mandatory Guidelines – Urine and (Medical Review Officer Guidance Manual), Appendix A: Glossary.

Yes. HHS evaluated change proposal comments and concluded the change from pH 3.0 to pH 4.0 was acceptable for identifying adulterated specimens. The physiologically minimum achievable urine pH that can be produced by the kidneys is about pH 4.5. Further, HHS is not aware of any medical conditions or medications that would cause urine pH to be less than 4.5. See (Mandatory Guidelines – Urine), Subpart 3.6.

At the start of the Federal Drug-Free Workplace Program in 1986, urine was the only authorized drug testing matrix. HHS, by the authority of Executive Order 12564 and Section 503 of Public Law 100-71, 5 U.S.C. Section 7301, established the initial scientific and technical guidelines and published the first Mandatory Guidelines for Federal Workplace Drug Testing Programs in 1988.

With advances in science and technology, SAMHSA has been able to incorporate oral fluid, an alternative drug testing matrix, thereby increasing the deterrent effect of the program. The Mandatory Guidelines for Federal Workplace Drug Testing Programs for oral fluid became effective January 1, 2020. Source: (Mandatory Guidelines – Oral Fluid) and (Mandatory Guidelines – Urine).

Oral Fluid

Laboratories certified to conduct drug and specimen validity tests are listed on the latest monthly HHS certified laboratory list. See (certified laboratory list on the SAMHSA website).

Source: DWP Staff, 240-276-2600

Laboratories and Medical Review Officers

Yes. NLCP certified laboratories were challenged with performance test (PT) sets before they were approved to begin donor drug tests. Laboratories received one Practice PT sample set and three Qualifying PT sets. A Post-Implementation PT set was sent to those laboratories that successfully completed earlier PT sets. In addition, the reliability of the laboratories to meet Guideline requirements is assessed through Maintenance PT sets that are sent every three months. No significant delays are anticipated in test results for current federal employees or for individuals applying for federal employment.

Source: DWP Staff, 240-276-2600

The revised Medical Review Officer Guidance Manual is posted on DWP’s website at: Medical Review Officer (MRO) Resources.

Laboratories certified to conduct drug and specimen validity tests are listed on the latest monthly HHS certified laboratory list. See (certified laboratory list on the SAMHSA website).

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