To: Collection Site Partners

From: First Advantage

Re: Inadvertent Disclosure

Date: 12/17/09

First Advantagetakes the accuracy of Custody and Control Forms (CCFs) seriously. As a result, we are developing enhanced metrics for tracking the quality of the CCFs submitted by collections sites and individual collectors under contract with us. In the case of errors, collectors or collection sites will be required to take remedial action, as appropriate. Failure to take appropriate remedial actions, or chronic accuracy problems, may result in the termination or non-renewal of a collector and/or collection site’s service agreement with us.

Accurate and complete CCFs are essential to the successful completion of drug screens in a timely and efficient manner. Inaccurate, or incomplete, CCFs can lead to the incorrect processing or posting of drug screening results. In the case of “fatal” flaws, such as the failure of the collector to sign the CCF, mistakes can require that the testing process begin again, inconveniencing consumers, increasing costs, and delaying the receipt of drug test results by the intended recipients.

Accuracy is important with respect to all portions of the CCF, not only with respect to “fatal” flaws or other flaws referenced by the Department of Transportation or Department of Health and Human Services regulations. Accuracy begins with the selection and use of the appropriate CCF form necessary to route the test result to the proper recipient. Collections facilities should take steps to ensure that the correct preprinted CCF, identifying the correct recipient designated to receive the results, is used. Use of the wrong CCF (or submission of an illegible handwritten CCF) can resultin the disclosure of an individual’s drug test results to the incorrect recipient organization or the incorrect point of contact within an organization. This not only can have privacy implications for the individual, it also can delay transmission of the drug test result to the proper recipient.

If the correct CCF form is not available and an alternate form is used, it is imperative that

three items are completed:

  1. The barcode (lab account number) is completely blackened out and correct lab account number is legibly written on the form. The lab account number can be obtained by calling the employer or First Advantage customer service at (888) 939-4782.
  2. The Employer’s Name, address, telephone and fax number is printed legibly on the form.
  3. The name and contact info for our Medical Review Officer is legibly printed on the form:

Stuart B. Hoffman, MD,FACP
480 Quadrangle Drive, Suite D
Bolingbrook, IL 60440
PH 888-794-6574
Fax 866-355-1297

Thank you for your attention to this critical matter. Please contact us at (800) 873-3733 option 1 with any questions you may have regarding this communication.