Ensure Online Signature Legitimateness for Drug Testing Consent Agreement

How to eSign a document: online signature legitimateness for Drug Testing Consent Agreement

hello everyone and welcome to today's webinar of the FMCSA Clearing House update this will be presented by DISA if you have any questions throughout the webinar please feel free to write those down and we submit them we will be answering those all after the webinar and a separate email I'd like to introduce Justin Mills who will be presenting today's webinar he has been with the DISA team since August of 2018 as a senior compliance specialist he currently leads thesis Clearinghouse implementation project as well as the audit and monitoring program and the risk assessment program he also supports thesis clients with audit assistance and statistical reporting questions Justin yes thank you thank you everybody for joining us today I know there's been a lot of questions surrounding the FMCSA Clearing House you know what is it what does it do who's required to participate so we're just gonna go ahead and jump right into the presentation and we're gonna try to clear up some of those questions for you and make sure that we address you know who who's responsible for what and what diesel will be able to do to support you all you so again we'll be covering the FMCSA clearinghouse basics that will be the sort of the who what when where of the Clearinghouse itself we'll be talking about what this means for employers that would be our clients these are clients and what employers should expect in 2020 so first let's just cover what is the FMCSA clearinghouse what what even is it as they would say an online it is an online database that will give FMCSA stakeholders real-time access to drivers drug and alcohol program violations negative return to duty tests and completion of follow-up testing plans this initiative was required by some congressional legislation that came out a few years ago called map 21 so in that legislation it required the Federal Motor Carrier Safety Administration or the FMCSA to develop and maintain a clearinghouse to to track this drug and alcohol violation information it was created with the purpose of providing employers and other stakeholders efficient tools to identify drivers who are not eligible to perform safety-sensitive functions as you may be aware there's currently a process where employers of FMCSA CDL drivers are required to reach out to the previous safety-sensitive regulated employers of a driver over the last three years and reach out to those previous employers and determine if there's any drug and alcohol violation information for that driver and to insure that that driver went through the you know required return to duty process so currently a prospective employer of a CDL driver would actually have to reach out to a previous DoD regulated employer regardless of the agency even if they came from PHMSA or the Coast Guard or the FAA if their CDL driver looking to perform CDL functions they would actually have to reach out to those other employers as well and determine and ask if there is any drug and alcohol violation information that they need to be aware of the issues with the current process is is that the prospective employees do not always disclose previous employers or violations occurred that means that if the prospective employee hasn't disclosed that they work somewhere where there was a violation obviously the prospective employer doesn't even know to reach out to that employer at that employer and get that information so there's there's just a hole of information there's a gap there that they're not able to address previous employers even when a perspective employer does know to reach out to a previous employer that previous employer doesn't always respond to the request sometimes they ignore it sometimes they just flat-out reject it for other reasons the result is that drivers that are unfit for duty are hired in place behind the wheel of a truck which puts their prospective employer and the public at risk this process this new process under the Clearing House will affect several industry stakeholders so obviously employers of CDL drivers the CEO drivers themselves there are also requirements for medical review officers or MROs there are requirements for substance abuse professionals or si piece there are requirements for the state driver's license agencies so for Texas that would be some somebody like Texas Department of Public Safety in your respective state it may be a Department of Motor Vehicles or even a Department of Transportation depending on the individual state there are also some requirements for consortium or third-party administrators which in this case for us is obviously DISA the functions for each of these stakeholders will vary starting with the employer the employers are required to perform pre-employment and annual queries on drivers and they're required to report specific driver violations as needed the drivers are required to provide electronic consent or reject as the case may be for both pre-employment and full queries and they will also wind up providing consent directly to a employer for limited queries they'll be able to review the accuracy of the reports in the Clearing House Amaro's will be required to report specific driver violations as needed the SI PS will be reporting specific return to duty program information the state driver's license agencies are going to be performing queries prior to completing licensing transactions this piece has been delayed until 2023 the goal is however when a driver comes in to renew his CDL or to possibly even just change his address or update his medical medical card the state driver's license agencies by 2023 will be actually be querying the Clearing House to make sure that there are no unresolved drug and alcohol violations if there's a drug and alcohol violation and the driver has not completed that return to duty process then they would actually reject that transaction and they would not be eligible to maintain their CDL until that was corrected seat EPA's such as DISA may report violations or make queries on behalf of employers so let's talk about queries what is a query a query is an electronic check in the Clearing House to determine if current or prospective employees are prohibited from excuse me from performing safety-sensitive functions due to unresolved drug and alcohol program violations this is again just intended to replace that inquiry to individual employers once employers start reporting all the information at the Clearing House in 2023 you'll be able to do one query to the Clearinghouse and retrieve all the drug-and-alcohol violation information for a driver for one location there are two types of queries a limited query which satisfies the new annual query requirement and full queries which includes all pre-employment queries all the queries will require driver consent but the type of consent will depend on the query type which we'll cover in just a second employers must purchase query credits directly from the Clearinghouse in order to actually perform the query the query credits cost of dollar twenty five and they're used for both limited and full queries you can buy them in bundles information on that is available from the Clearinghouse and it is important to note that the CTA's whether it's diese or another another ctp a we cannot purchase those credits on behalf of an employer they have to be purchased directly by the employer so let's talk about those squeeze a little bit more if you look at the limited query this first off this graphic actually comes from the FMCSA itself they worked up this great graph that actually really breaks down the query types very well the limited query is used for annual checks currently employed driver or an ad hoc periodic check on a driver so even though you're required to do one a year you may you may be allowed to do a limited query more often if you so wish quarterly you could even do it daily as long as if you look to the next to the next column as long as you're limited consent form specifies the time range and the frequency you can set that on your own and you can you can check you can do limited checks as often as every day the consent is maintained outside the Clearinghouse it may be an electronic or a wet signature you can maintain that electronically in your files or you can maintain that as a pick excuse me as a paper file in the driver qualification file if the driver has not provided you consent to perform Limited queries on an annual about at least an annual basis then the query can't be conducted and the driver has to be removed from safety-sensitive functions so at any point if a driver is refusing to allow you to do queries they have to be removed from safety-sensitive functions if the consent is provided you're going to retain that via paper or electronically in the driver's qualification file and you will be able to request a limited query in the clearinghouse now if no records are found in the Clearinghouse for that query driver there's no follow-up action that's required at that point if there are records that are found in the Clearinghouse for the query driver a full query is required at that point you will need to conduct a full query based on the fact that the limited query has indicated that there are records to be reviewed in the Clearinghouse for that specific driver so a full query must be conducted for violation and will return to duty details and if that full query is not conducted within 24 hours of the limited query then the driver has to be removed from safety-sensitive functions including operating a CMV so if you do a limited query on one of your drivers and the query indicates that there are records in the clearinghouse then to be reviewed if you wait too long to conduct that full query as a follow-up that means you would then actually have to call that driver and then pull him off to the side of the road until you can finish the full query process now the full query is required for pre-employment checks it's required when a limited query returns records or you can actually skip the limited on the ad-hoc periodic check and just go straight to a full query if you wish now the consent requirements differ from the limited in that the consent for a full query is managed entirely by the Clearinghouse and it's entirely electronic when you perform a full query it's going to send an email to the driver indicating that you requested a full query and it's going to tell them to login to the Clearinghouse and provide that consent one of the issues that will come up is if the driver has not registered for an account with the Clearinghouse they won't have an email address to send that driver an email so they're going to take this the address the current address on their commercial driver's license and send them a letter and they expect that process to take ten to fourteen days for that letter to get out to that driver and that driver is then going to have to go on register for the Clearinghouse and either provide or reject consent if the driver refuses consent and the employer will be notified of that refused consent the query will not be able to be conducted and the driver cannot perform or must be removed from safety-sensitive functions so in the sense of a pre-employment if you do a pre-employment full query on a driver and they refused you cannot put that person in safety-sensitive functions you could technically hire them but they would not be able to perform FMCSA functions for you if they're already a driver for you and you've performed a full query and they've rejected it they have to be immediately removed as soon as you get that notification you need to remove them from safety-sensitive functions if the consent is provided you can continue with the query the query will be conducted for you the full violation and/or the return to duty details will be released if any if the driver has a violation and there is no negative return to duty test result associated with that violation that driver has to be removed from safety-sensitive functions and then start that return to duty process if a driver has no violations or violation and a negative return to duty test then there's no further action required so let's review the consent just one more time a pre-employment query is required for is required to be a full query if full query must be performed on all new hires starting January 6 2020 a full query releases drug and alcohol violations to the prospective employer and the drivers must provide electronic consent directly to the Clearing House the annual query can be limited and it must be performed on each driver on an annual basis either limited or full the limited query only indicates if there's information to be reviewed and for the limited queries the employer maintains their own written or electronic consent for limited queries and that consent for the limited is maintained outside of the Clearinghouse they do not maintain any records of a consent for limited queries if they need proof of that that will be done at a compliance review or a safety on it now an annual query could be a full if you wish again if the result of the limited query indicates there is information in the Clearinghouse or you choose to go for a full then that would be again an electronic process now the initial note on the side that the initial annual query for drivers that already work for an employer prior to January 6 2020 you must complete that initial annual query by January 5th of 20 that should say 2021 I apologize but you have the entire year to actually do your initial annual query for existing drivers again consent for full queries is managed electronically by the Clearinghouse not by the employer not by a CTP a it's a it's entirely between the Clearinghouse and the driver an employer only needs to maintain written consent for limited queries drivers are required to provide consent for a full pre-employment query before performing safety sensitive functions for the prospective employer and drivers are required to provide consent for full annual inquiries within 24 hours of receiving the consent request from the Clearinghouse or they have to be removed from safety sensitive functions outside of queries the employers are also required to start reporting certain violations if you notice there's a three business day time frame there if you are notified of an alcohol result Oh point zero four percent or greater or a negative return to D test result a refusal to take an alcohol test refusal to take a drug test that does not involve the MRO or a report that the driver has successfully completed all follow-up tests as prescribed by an S ap or actual knowledge violations you must report that to the Clearing House within three business days so if you're notified on Friday you wouldn't count Saturday and Sunday and that three-day three-day timeframe now actual knowledge if you're not aware of what actual knowledge is that is under part 382 actual knowledge is based on direct observation of the employee using alcohol or controlled substances or a traffic citation for driving a CMV under the influence of alcohol or controlled substances there are some parameters in there for when a driver admits to controlled substance use questions about driver self admission should be directed to the FMCSA it gets it can get very complicated when determining what part of the regulations to apply when a driver self admits to controlled substance uses and given that complication that is the one report that diesel will not be able to support reporting there are some affidavits that would need to be signed and provided to the Clearing House directly those violations tend to be rare but in that case that would actually have to be handled by the employer the driver has the responsibility to provide consent the driver needs to provide written general consent to the motor carrier for limited queries and drivers need to respond to electronic consent with queries from the Clearing House they'll also be able to access in the information in the Clearinghouse so they'll they'll be able to log in and they'll see what has been reported they'll be able to look at the factual accuracy they'll be able to challenge things like name spelling maybe the CDL number is wrong maybe the dates are wrong but they won't actually be able to to challenge the actual test result in other words they can't lodge a complaint with the Clearing House and say that the MRO made the wrong determination and saying that this was a positive test or that the collection site made the wrong determination and that it should not have been considered a refusal to test now the MRO will report verified positive adulterated or substituted test results and that's for controlled substances not alcohol they will report refusals to test requiring an MRO determination the s AP the substance abuse professional reports identification of the driver and the date of an issue of an initial si P assessment so this is part of that return to duty process successful completion of treatment or education and the determination of eligibility for return to duty testing now this doesn't require any additional actions by the employer the MRO and the si P make their own Clearinghouse accounts the employer does not have to designate the MRO or the si P once they receive the information they have a regulatory duty to report that information now the drivers have to designate the si P and the clearinghouse before they can submit a report but B MRO does not need to be designated by an individual employer see TPA may but is not required to make reports to the Clearinghouse on behalf of an employer and we may perform Clearinghouse driver queries both pre-employment and annual on behalf of an employer now if you know there's an important asterisk as usual with the FMCSA there's usually exceptions built into the regulation somewhere and for this case it's going to be owner operators owner operators they're required to designate a CTA to administer their drug testing program and complete reporting to the Clearing House when necessary also they can perform necessary queries to the Clearinghouse on themselves in other words DISA does not have to perform this for them but we do actually have to report for any owner operator clients we actually bear the regulatory responsibility to report on behalf of an owner operator now if there's any confusion about what an owner operator is under the FMCSA guidelines they define that as someone who hacks as both an employer and a driver at certain times so an example would be someone who owns a BC trucking and the MCS 150 is registered in their name and then they also hold a CDL and then they also perform as a driver for ABC trucking in that instance he is that individual she or she is both the owner and the operator for that one entity and in that instance the FMCSA has said that that that individual must designate a CTP a to administer that administer their drug testing and complete the necessary reporting to the Clearing House moving forward getting ready for 2020 employers should start preparing right now there are some steps that we would such a highly suggest that you take number one obviously would be to register with the Clearing House employers do need to register for a Clearing House account CT pas cannot register that employer account for their clients the employer has to register their own account and the dtpa registers their own individual account as well instructions for registration are available at Clearing House fmcs ADOT govt the Clearing House has provided very well produced instructions for the registration process for all entities so there will actually be you will actually find on the Clearinghouse website instructions for registering an employer registering the drivers the MRO has their own information the si P has known information there are job aides for all the different stakeholders that are very very well very well put together if an MC FMCSA employer plans to use a seat EPA for clearinghouse compliance they will need to designate that seat EPA during the registration process you'll need to ensure that diese is aware of what company name is registered with the FMCSA as it may not match your DISA account name as an example we're gonna go back to ABC trucking your name that FMCSA knows you buy it might be FMCSA I'm sorry ABC trucking but diese may know you as a client as Joe Smith Enterprises so Joe Smith Enterprises owns ABC trucking as far as DISA is concerned so far we only know you as Joe Smith so when we get the request to approve ABC trucking unfortunately the clearing house has not provided us with a lot of identifiers for these companies there's no email address there's no phone number they don't even show us the d-o-t number we only get the name so we would need to know what you're known - what you're known by - the FMCSA so that we can put those two entities together you'll need to begin purchasing queries in order to conduct those queries that are required starting January 6 2020 you need to purchase those query credits that we mentioned earlier the query bundles don't expire they come in a variety of sizes there are no discounts each query is still a dollar 25 but you can purchase them in bulk and bulk amounts and information for that is found at Clearinghouse FMCSA d-o-t govt / query / plan employers should also begin encouraging their drivers to register for an account prior to January 6 2020 it should be part of the onboarding process for prospective hires but it should also be something that you're you're encouraging your current drivers to do as well and the reason is is because of the 24 hour deadlines that kick in when full queries are conducted you want to make sure that your current drivers are ready so that if that actually becomes necessary you're not having to take people on the road because a 24 hour time frame was missed it will make that it will make meeting that 24 hour deadline a lot easier it will also streamline your processes when you're not waiting for people to actually go online and register for a Clearing House account drivers will register at the same web address as employers Clearing House FMCSA d-o-t govt now if you designate diese as your CTP in the clearinghouse you must also contact diese in order for the appropriate changes to be made in your Dieselworks account so what that means is there are some account settings that need to be made to make sure that when a test that required that is required to be reported comes in under your client ID number we need those settings to be activated so that it'll go to the work you and that the appropriate team will have visibility to that and make sure that they can get that that information off to the Clearinghouse now designating diese as your CTP in the Clearinghouse does not guarantee that you we will report on your behalf you must notify these an order for reports to be made if we don't know that you've designated us those account settings won't be made won't be changed and we won't know to report that information when it comes in now whether or not you designate diese as your CTP in the clearinghouse you must provide driver and company information to diese in order to maintain accurate FMCSA random drug and alcohol testing programs we'll cover that in a little more detail in just a minute starting January 6 2020 you will be able to begin ordering full pre-employment queries that diesel works in the same manner as ordering other background products if you already use those for background services you will probably be aware of how that looks when you select different products it will be a product just like the other background service products now at this time DISA does not perform queries on drivers automatically a client will need to place orders through our background services in order for that to happen if you've requested us to do so DISA will report violations to the Clearinghouse on your behalf in order to meet the three-day deadline for reporting violations clients will need to be prepared for some interaction with DISA personnel in terms of making sure that we have accurate information to report to the Clearinghouse you may receive emails or phone calls that would be it be very important for you to respond too quickly also beginning January 6 2020 all FMCSA a drug and alcohol test forms must be completed using the drivers CDL number and state of issuance instead of any other identifier there are no changes being made to the CCF the ECC F or the alcohol testing form there's no need for that to change the form has always allowed for employers to use whatever identifier they choose to they choose to use it's just never been required to use the CDL before and really quick on those annual queries currently Dieselworks does not notify users when annual queries are acquired clients will need to monitor the dates on the queries will be required internally until such features are developed annual queries for drivers are done are already employed prior to January 6 2020 will need to have an annual query either full or limited conducted prior to January 5th 2021 Dieselworks will offer the full queries as of January 6 2020 the limited queries will be available at a slightly later date now all diese clients with the FMCSA policies must provide the following information and this is regardless of whether you have opted to use this as your c TPA and have us make those reports on your behalf we need to have the driver's CDL number and stay the issuance especially we would also need the direct drivers date of birth the company d-o-t numbers for each FMCSA policy and location and confirmation of your status as an owner-operator if you're an owner operator we do need to know that so that we can make sure that we're in compliance and that you're in compliance as well now the key here really is the drivers CDL number and st. of issuance for all for all of our clients we are going to have to start matching the CDL number and standard issuance to the employee record rather than a social security number or any other employee ID so it's very critical that we get that information diese clients will be receiving an email later this week that will have information on how to contact client support for assistance and updating driver records if necessary or performing roster loads and going forward as mentioned earlier it is required that you start to use the CDL number in the state of issuance as the identifier on the federal forms for the FMCSA test you're not required to use the driver's license for phmsa for Coast Guard for FA Afra any of those other agencies only for FMCSA are you required to use that driver's license number you do need to use to utilize the two-digit state code as well and as an example if you look at this graph you see that the state code for Texas is of course TX and the number 1 2 3 4 5 6 7 8 on the CCF when you're processing a test of DISA you would need to enter that TX directly in front with no space the 1 2 3 4 5 6 7 8 so that it reads to TX 1 2 3 4 5 6 7 8 you can see Colorado's example but we'll skip down to Washington because it's one of the most unique if you see Washington state code is W a the CDL number is ABCD asterisk 1 2 3 4 5 that is actually a Washington driver's license it's based off of an actual Washington driver's license the state code waa goes right in front of that a so W a ABCD asterisk 1 2 3 4 5 and you can see a similar situation with the North Dakota example and these are all based off of actual CDL numbers that we have examples of so that we can actually show you this is what's required to be in there the reason that this is important is because once tests are being processed they're Dieselworks we're going to need to make sure that we have a uniform way to read that number and then match it to an employee record this is just an example CCF completed with CDL CDL state of issuance as you can see I used the Washington example from the previous slide so W a a b c d asterisk 1 2 3 4 5 if you can see my cursor right here by c donor SSN or employ employee ID number and we've entered the two digit state code and then the CDL number exactly as it appears on the license so just to review the suggested steps that an employer should take to prepare one register with the Clearinghouse to designate a CTA if desired three purchased query plans for encourage your drivers to register encourage I all we also encourage you to make that part of your onboarding process with prospective hires if they're not already registered with the Clearinghouse when they come to you you know ask them to do that as part of the as part of the process notified diese that you've designated us is as a CTA in the Clearinghouse provide that necessary information to us and then starting in 2020 you'll begin performing queries reporting violations those are things that we may be doing for you on behalf on your behalf if you've designated us in notified us and then of course starting January 6 2020 you will need to complete the CCF the ECC F and the ATF with a CDL and the CTO state of issuance so really briefly what should employers expect in 2020 this is a flowchart that I've put together to kind of help you get in a high-level view of what your hiring process will look like and what your ongoing maintenance will look like so applications for employment then the pre-employment Clearinghouse inquiry the pre-employment drug test now those don't have to be in that order you can perform either of those before the other you can do the drug test first and then the clearinghouse query the regulations don't they don't care which order you do them in as long as you've done both of those before that driver starts performing safety sensitive functions so you would not want to be in a position where you did a pre-employment drug test and then they started driving the truck and then the pre-employment clearinghouse query came after they've already been on the road you will continue doing the previous employer drug and alcohol queries the one where you reach out to the actual previous employers until January 2023 and then you'll continue obtain the limited consent for annual queries from the driver and then all the other DQ file requirements will still apply such as motor vehicle records a road tests commercial driver's license copies things of that nature maintain those records in the DQ file or other appropriate file and then you'll continue to monitor your driver qualification files and continue to monitor your drug and alcohol program or the annual and ongoing requirements you'll be performing the annual clearinghouse queries either limited or full the other annual DQ requirements like annual motor vehicle records and then you'll report drug and alcohol violations to the Clearing House if needed or diesel will do that if you've opted to do so and if the driver is terminated you'll need to make sure that you maintain the records for the required time some of those vary some of the retention times vary depending on the record all again all that information will be maintained in the record maintained at the DQ file or other appropriate file and again you're going to want to do continual monitoring of your DQ files and continual monitoring of your drug and alcohol program now it's important to note that there is no application programming interface or API for the Clearinghouse that's an IT term that essentially means there's no ability to automate any of these functions in the Clearinghouse there's no automated reporting there's no automated queries all tasks must be completed manually by interacting directly with the Clearinghouse website now the one the one good thing is and we didn't cover it because it we didn't we were trying to stick to the basics you are able to do batch queries you would have to put them in a specific Excel format excel file format called at TSV and you can upload a hundred drivers or so into the point you know into the Clearinghouse and they'll run each one but that's about as automated as it gets is putting some stuff into an excel file and then submitting that to the Clearinghouse and then having them run those sort of behind the scenes for you rather than entering them into the Clearinghouse one by one but in terms of actually just automating the report like clicking a button on your end or these are works or at any other CTP a there's nothing that actually automates those functions it's all manually you have to go direct to the Clearinghouse website and they have said that at this time they're not planning on automating any features they may visit that later on down the road but right now they needed to meet certain security parameters set by the federal government now it is important to note that we cannot operate as your CTP a visa cannot operate as your CTP a unless you are a diesel ient so if you want us to make reports we would need to actually have an FMCSA drug and alcohol policy if we're not processing your drug your drug tests we won't be able to make reports on your behalf if you want us to perform queries you would need to be signed up for background services and we would need our DQ service to help track the pre-employment and annual coria compliance there are some potential difficulties that we will face in January both diese and the clients and employers just in general this is going to be industry-wide the new requirement to use CDL numbers could cause roster duplication errors understand of course if you've been using the Social Security number as the record you know the employer record ID once we start processing tests for with the CDL numbers if there's a mismatch there what Dieselworks will do is potentially create a duplicate record for that employee so it's really important that we get that CDL number for those employees prior to January 6 2020 and that you get that information updated because it will reduce the potential for roster errors again identification of clients in the Clearinghouse is is sometimes difficult depending on what we know our clients as compared to what the FMCSA knows our clients and that doesn't mean that there's anything wrong with that we may know somebody as Joe Smith enterprises and they may be known to the FMCSA as a BC trucking that's completely legitimate we're just not aware of that change and again we're not given any other identifiers we're not given the d-o-t number we're not given the email or any other contact information for these employers so we're really having to work to scrub those lists of requests and make sure we reach out to everyone and identify who those clients are that have identified us as being there TPA in the Clearing House you could have some delayed queries due to lack of driver consent that that may be because they're not registered with the Clearinghouse or they're just ignoring their email it's a variety of things so just understand that you know if you perform a full query on a driver and they don't consent within a time frame you're gonna be required to pull that driver off the road so one of our one of our suggestions is to be very communicative with the drivers when you do a full query and let them know I've just asked for a full query you need to be watching your email so that you can provide that consent we don't have to pull you off the road I think most drivers would probably be open to that they're not on the road a lot of times they're not making money either so they're they're definitely gonna want to stay working as much you could see delayed queries due to lack of query credits available while diese cannot order query bundles for our clients we do see what your balance is so we will be trying to keep you aware of when there's no query credits available and make sure that that's worked out the Clearinghouse will be sending notifications to employers when their balance is low we have not been told what the trigger is for that notification it may be a percentage so that if you order a thousand queries perhaps it gives you an email at 10% so once you get down to a hundred it gives you an email they have not specified what that notification actually looks like so please expect to work closely with us and eat with diese in 2020 and order and smooth ensure a smooth implementation again we've been working very hard to try to keep up with it and to be in front of this to support our clients but just understand the Clearinghouse final rule was published in 2016 but we did not get any details about the actual operation of the system until early 2019 so we've been working very hard to stay on top of this and we will be working closely with you in 2022 and to ensure that smooth implementation so please start preparing now if you have any questions about the Clearinghouse regulations and implementation that should be directed to the FMCSA at eight five five three six eight four two zero zero or through the website listed on your screen questions about diese accounts these are products or adding driver information should be directed to client support at the number and email address listed questions about this specific presentation can be directed to compliance at DISA comm you can put attention Justin or just put Clearinghouse in the subject and it'll get directed to directed to me if you do not have an FMCSA drug testing policy or you need background services or d.q services with DISA and you're interested in obtaining those services please contact sales at D CENTCOM and that will conclude my presentation for today again if you have any questions please submit those online we will follow up with those offline through email thank you