The Physiotherapy Council S Urine Drug Testing (UDT) Policy, Applies to All Registrants

The Physiotherapy Council’s Urine Drug Testing (UDT) Policy, applies to all registrants with a condition on their registration that requires urine drug testing. You are expected to strictly comply with all the requirements set out in the Policy for each stage of the process. Compliance with the UDT Policy will be closely monitored by the Council.

The following information is highlighted to assist with your compliance with the Council’s UDT Policy:

1. Please read the UDT Policy carefully and discuss the requirement for urine drug testing with your treating health practitioners and/or staff at a Pacific Laboratory Medicine Services (PaLMS) collection site or local pathology practice.
2. As a registrant with conditions on registration which stipulate that you must attend for random urinalysis, you must bear the costs associated with urine collection and drug testing.
3. Collection of the urine sampleis to be directly supervised by a supervisor approved by the Council and who is aware of the Council’s UDT Policy. Your nominated supervisor may be your GP or a senior staff member at a pathology provider. Once you have located a suitable supervisor, please provide details of your nominated supervisor to the Council using the Notification of Nominated Urine Drug Testing (UDT) Supervisor form(available from the Council’s website). Your nominated supervisor will be required to contact PaLMS Toxicology on (02) 9887 5666 to inquire about collection kits which will be supplied directly to the supervisor.
4. Testing of the urine samplemust be undertaken by the PaLMS Toxicology Unit OR by an alternative pathology provider approved by the Council.

a. If you are using the services of the PaLMS Toxicology Unit, please contact PaLMS directly on (02) 9887 5666 prior to commencing urine testing so that invoicing arrangements can be put in place.

b. To obtain approval for an alternative pathology provider, you must provide sufficient information to demonstrate that the Policy will be followed including name and address details of a contact person at the nominated pathology practice.

1. Random urine drug testing means a minimum of 15 tests in a consecutive six (6) month period. You may, however, be required to provide tests for longer than a six month period.
2. You are required to telephone 1800 654 068 every Monday to Fridaybetween midnight and 5.00 pm to ascertain whether you are required to attend for urine testing. This number is a recorded message which applies specifically to a particular day. You will be instructed to attend (or not attend) on a specific day. You must attend on thespecified testing day. It is not acceptable to attend on other days in lieu of a specified collection day without prior Council approval.
3. You are to be tested for eight (8) nominated drugs – cannabis, opiates (morphine and codeine), cocaine, amphetamine, benzodiazepine, pethidine, oxycodone and tramadol.
4. You are required to contact the Council and provide an explanation in writing if you are unable to attend for urinalysis or other drug testing on any occasion (Fax: (02) 9281 2030 or ).
5. You are required to provide the Council with five (5) business days notice before any anticipated absence and provide evidence of your absence.
6. You are prohibited from self administering any drugs detailed in Schedule 1 of the Drug Misuse and Trafficking Act 1985, or Schedule 4D or Schedule 8 of the Poisons and Therapeutic Goods Act 1966. This includes any narcotic derivatives, non-prescription compound analgesics or cold medicines unless prescribed and taken at the direction of a treating practitioner.
7. You must notify the Council of any instance of illness requiring the administration of medications described above. You must also provide the Council with written confirmation of such treatment from the treating practitioner.
8. You must notify the Council of any procedures you are required to undergo which may involve the administration of drugs.
9. UDT results for the eight (8) nominated drugs listed at point 7 above must be forwarded directly to your treating practitioners and the Council within one (1) week of the testing being completed.

Please ensure that you provide your consent for your treating practitioners and the Council to receive the UDT results. Test results forwarded to the Council should be addressed to the Executive Officer, Physiotherapy Council, Locked Bag 20 Haymarket NSW 1238.

Physiotherapy Council of New South Wales

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Introduction

Urine drug testing (UDT) is an effective monitoring and rehabilitation tool in both managingdrug addicted health professionals and assuring the Physiotherapy Council of NewSouth Wales (the Council) that registrants about whom they may have received concernsregarding self administration, do not abuse prescribed or illicit substances. This UDT Policyapplies to all registrants with a condition on their registration that requires urine drugtesting. It has been developed to inform /students of the Council’s expectations and toensure consistency in the day-to-day running of the UDT Program.

The Health Professional Councils Authority (HPCA) manages the UDT Program on theCouncil’s behalf. Participation in the Program is a consequence of a condition imposed on apractitioner’s registration as the result of a hearing or inquiry.

Overall responsibility for decisions regarding the collection and testing policy, and aregistrant’s progress through the Program rests with the Council.

The practitioner (also referred to in this Policy as the “registrant”) bears the cost ofparticipation in the Program (both collection and testing). As this is a medico-legalinvestigation, it is not eligible for a Medicare rebate.

The Council is aware that collection and testing is inconvenient, intrusive and expensive andunderstands that many registrants regard this process as burdensome and embarrassingbut it is the best system currently available. It is the only reliable quantitative means bywhich the Council can be assured that the practitioner is well enough to participate in activepractice or training.

Negative tests are the best available evidence that the practitioner has his/her substanceabuse problem under control, provided that there is adherence to this Policy.

Breach of a condition relating to UDT in accordance with this Policy can result in the Counciltaking disciplinary action against the registrant and may directly affect progress through theCouncil’s Health Program.

Collection and Testing

Collection and testing must be in accordance with the Australian Standard AS/NZS 4308(the Standard) and meet its chain of custody requirements. The Council has somerequirements additional to those of the Standard, which must be complied with, asprescribed in this Policy.

The HPCA’s provider of urine drug testing services is PaLMS (Pacific Laboratory MedicineServices) Toxicology Unit (telephone 9887 5666). However, a practitioner may submit thename of an alternative pathology provider which meets the Testing Standard (Section 2.2)and the Supervised Collection Guidelines (Section 5) for approval by the Council.

Collection

There are three options for arranging supervised collection of urine samples:

1. Supervised collection at a PaLMS collection facility. A list of locations and operatinghours can be provided by PaLMS (see Section 6).
2. Collection supervised by a supervisor approved by the Council such as a GP, usingpostage paid collection kits provided by PaLMS directly to the approved supervisor. (Refer to Section 5, Supervised Collection Guidelines). Kits can be obtained by thesupervisor by contacting PaLMS on telephone (02) 9887 5666. The practitioner will beinvoiced for the collection kits by PaLMS. Under no circumstances may collection kitsbe supplied directly to the practitioner.
3. Collection supervised by another pathology provider approved by the Council. Othercollection centres are often prepared to supervise collection and forward the samplesto PaLMS Toxicology Unit for testing. Most pathology providers will have collection kitsthat satisfy the Standard.

Testing

In accordance with the Standard, drugs routinely tested for include cannabis, opiates(morphine and codeine), cocaine, amphetamine and benzodiazepines. In addition,specimens are tested for pethidine, oxycodone and tramadol. In certain cases, conditionsmay require samples to be tested for additional drugs.

Detailed Requirements

Strict compliance with the following general requirements is mandatory:

1. Within seven (7) days of the introduction of a condition requiring UDT, the registrant isrequired to advise the Council of the location of the PaLMS facility to be attended or thename, address and telephone number of the nominated supervisor or other pathologycollection centre.
2. The practitioner is required to meet the cost of testing by paying PaLMS or other Councilapproved pathology practice directly; and may also incur costs for supervised collection,at the discretion of the supervisor.
3. Urine samples are to be collected under directsupervision according to the proceduresdetailed in Section 5, Supervised Collection Guidelines. Direct supervision means thesupervisor must witness the urine passing from the urethra to the container.
4. Testing results must be forwarded to the Council, the treating medical practitioner(s) andthe Council-appointed practitioner(s). The registrant may find it helpful to also have theresults sent directly to him / her. The registrant must include the treating practitioner’sname and address on the request form.
5. The registrant is prohibited from self-administering any drugs detailed in the DrugMisuse and Trafficking Act 1985 Schedule 1 or the Poisons and Therapeutic Goods Act1966 Schedule 4D or Schedule 8 Drugs. This includes any narcotic derivatives, non-prescription compound analgesics or cold medications unless prescribed and taken atthe direction of a treating practitioner. The registrant must notify the Council of anyinstance of illness requiring the administration of medications described above. Inaddition, the practitioner must provide the Council with written confirmation of suchtreatment from the treating practitioner.
6. When consumed in a sufficient quantity, poppy seedsmay result in the presence ofmorphine and codeine metabolites in the registrant’s urine. The practitioner mustactively avoid the consumption of any food containing poppy seeds. Tests showingmetabolites for a known drug of addiction, for example morphine, may result in theCouncil convening an Impaired Registrants Panel to inquire into the matter or referringthe matter to the Council’s delegated Committee for formal disciplinary action. Inaddition, weight loss supplements and drugs are not recommended, as they may containamphetamines or other stimulants, resulting in a positive urine drug test.
7. Registrants must advise the Council of any procedures that they are required to undergowhich may involve the administration of drugs. Where administration of drugs hasoccurred in an emergency situation, the registrant must advise the Council as soon aspracticable in the circumstances and provide the Council with written confirmation ofsuch treatment from the treating practitioner.

Thrice-Weekly Testing

1. Testing is conducted on Monday, Wednesday and Friday of each week. It is notacceptable to present on other days without prior approval.
2. The decision to vary testing from thrice-weekly to random can only be made withendorsement from the Council. This decision will be made by considering therecommendations from the Council-appointed practitioner and / or the Council ReviewInterview Panel.

Random Urine Drug Testing

1. Random Urine Drug Testing means a minimum of 15 tests in each consecutive six (6)month period. The timing of the collection will be determined by the Council Secretariat.
2. The registrant is required to telephone the free-call number 1800 654 068everyweekday between midnight and 5.00pm to ascertain whether he / she is required toattend for testing and must attend on the specified day.
3. Cessation of urine drug testing can only occur with approval of the Council. This decisionwill be made by considering the recommendations from the Councilappointedpractitioner and/or Council review.

Absence from testing

1. Registrants are required to advise the Council, in writing, at least five (5) business daysbefore any anticipated absence (fax (02) 9281 2030 or email() notifications are acceptable). Onlyunder extraordinary circumstances will permission be given to abstain from testing oncertain days on a routine basis. In those situations, registrants may be required toundertake urine drug testing on the required days when the registrant is available andalso undergo an additional monthly hair drug test.
2. Registrants are required to provide evidence of absence within 10 working days (e.g,copies of boarding passes, hotel receipts or some other evidence).
3. Registrants are not required to provide a urine sample on a public holiday.

Missed tests

If a registrant is aware that a test has been missed, the registrant must immediately notifythe Council and provide an explanation in writing. Explanations may be considered by theCouncil which may view the matter as a breach of conditions and recommend disciplinaryaction.

Positive tests

If a positive test result is returned, the registrant will be required to provide a writtenexplanation. That explanation, together with any additional information obtained from thetesting laboratory, will be placed before the Council which may view the matter as a breachof conditions and recommend disciplinary action. Registrants subject to random urine drugtesting may be required to return to thrice-weekly urine drug testing.

Dilute samples

1. The Council considers a sample to be dilute when the urine creatinine is below 2.0mmol/l. Dilute urine suggests that the registrant has consumed a large volume of waterprior to passing the urine or that there has been adulteration of the sample aftercollection. This renders the test invalid as drug metabolites may be diluted toconcentrations below testing detection levels.
2. If dilute samples are received, the registrant will be notified and will be expected to takethe necessary action to avoid further dilute samples.
3. Should further dilute samples be received, the registrant will be notified in writing andrequired to provide a written explanation. That explanation will be placed before theCouncil which may view the matter as a breach of conditions and recommenddisciplinary action.

Sample adulteration or substitution

The Council may, at any time, conduct any test on a urine sample as may be required todetermine whether the sample has been adulterated or substituted. If a result indicatessample adulteration or substitution, the registrant will be notified in writing and required toprovide a written explanation. That explanation, together with any additional informationobtained from the testing laboratory, will be placed before the Council which may view thematter as a breach of conditions and recommend disciplinary action.

Registrants required to undergo urine testing as a result of Critical ComplianceConditions imposed on their registration by NCAT.

If the registrant is subject to a Critical Compliance Condition in relation to Urine DrugTesting and is in breach of this Policy, the discretion which the Council may exercise isseverely limited. The Council is required by the Health Practitioner Regulation National Law

(NSW) (the Law) to take the following action:

1. Convene proceedings pursuant to Section 150 of the Law. If the delegates of theCouncil conducting the proceedings are satisfied that the registrant has contravenedthe Critical Compliance Condition imposed on his or her registration, the registrant willbe suspended until a complaint concerning the matter can be dealt with by NCAT.
2. Refer a complaint concerning the registrant’s breach of the Critical ComplianceCondition to the NCAT. If NCAT is satisfied that the registrant has contravenedthe Critical Compliance Condition, NCAT must order the registrant’s deregistration.

Advice to Supervisors

1. Supervisors should be familiar with all aspects of the Council’s Urine Drug TestingPolicy, as well as the medical and behavioural consequences of drug addiction.
2. Supervisors should only have a professional doctor-patient relationship with aregistrant undertaking urine drug testing.
3. Supervisors should generally be available to supervise collection, and ensure that intheir absence, an alternative supervisor is available and informed of the Council’srequirements. The responsibility of securing an alternative supervisor is that of thepractitioner undergoing testing.
4. Payment for supervised collection is to be directly negotiated between the supervisorand the practitioner undergoing testing.
5. The Council is appreciative of the service that supervisors provide, but supervisorsshould be aware that failure to comply with the Supervised Collection Guidelines(Section 5) may be viewed unfavourably by the Council. Supervisors are stronglyadvised to comply with their obligations as supervisors.
6. Supervisors should contact the Council and discuss any queries or concerns with theCouncil’s Executive Officer or delegate.

Supervised Collection Guidelines

Supervisors must maintain a permanent record of specimen collection. The record is tocomprise the collection date, the nature of the specimen, the serial number on the specimenseal and the supervisor’s signature. Copies of this record, or part thereof, must be madeavailable to the Council on request. It is also recommended the registrant maintains his /her own diary that is signed by the supervisor on each occasion.

If the collection process in this Policy is correctly followed, including the collection procedureand preparation for dispatch set out below, there will be no opportunity for the urinespecimen to be adulterated, substituted or diluted by another person. Similarly, the urinecontainer and the request form will be correctly completed if the procedure is adhered to. The information recorded on the request form must be identical to that recorded on the urinecontainer.

Collection procedure

The following procedures will ensure that unadulterated specimens are obtained andcorrectly identified. Every effort should be made to minimise the number of personshandling specimens.

1. After washing hands, the registrant must remain in the presence of the supervisor andnot have access to any water fountain, tap, soap dispenser, cleaning agent or any othermaterials that might adulterate the specimen.
2. The registrant must provide the specimen under direct supervision. Direct supervisionmeans the supervisor must witness the passing of the urine from the urethra to thecontainer. This may include video supervision, where such facilities are available.
3. Upon receiving the specimen, the supervisor shall determine that there is a sufficientsample to enable all required testing to be performed. A sample of at least 20ml mustbe collected. In the event that insufficient urine is collected, an additional sample mustbe provided.
4. Immediately after the specimen is collected, the supervisor should inspect the urinespecimen to determine its colour and look for any indication of adulterants or diluents. Any unusual finding should be noted in the supervisor’s record.
5. If the integrity of the sample cannot be established, or if it is suspected that thespecimen may have been adulterated or substituted, then another specimen should becollected as soon as possible and both samples forwarded to the laboratory for testing. These specimens must be labelled and documented appropriately.
6. Both the registrant and the supervisor should keep the specimen in view at all timesprior to it being sealed and labelled.
7. The supervisor should request that the registrant observe the transfer of the specimenand the placement of the tamper-proof seals over the bottle cap and down the sides ofthe bottles. The registrant must sign the seals.
8. After the specimen has been provided and submitted to the supervisor, the registrantwill be allowed to wash his / her hands.

Preparation for dispatch by the Supervisor