On November 23, 2021, OMB extended the expiration of the 2017 paper CCF to August 31, 2023. This means that employers and specimen collectors may use the 2017 Federal CCF for urine specimens collected for federal workplace drug testing programs and those collected for testing under the Department of Transportation (DOT) without a requirement for an affidavit or memorandum of correction for using an expired federal CCF.
DHHS (SAMHSA) petitioned OMB to extend the expiration date of the 2017 federal CCF based on reports that materials for the paper CCF (carbonless paper, label/seals, etc.) are in short supply because of the pandemic and related supply chain issues. Thus, the laboratories have been unable to adequately supply the 2020 federal CCF. The previous expiration date for the 2017 CCF was August 29, 2021. Use of the 2017 CCF after August 29 required the laboratories to obtain a memorandum of correction from the collector concerning use of the expired CCF before reporting a drug test result. In a November 29 email to the HHS certified laboratories, the National Laboratory Certification Program (NLCP) announced the OMB extension of the 2017 CCF expiration date and directed the laboratories to release the results on specimens received after November 23, 2021 that were being held awaiting an affidavit/memorandum of correction.
Employers, collection sites, etc. may use either the 2020 Federal CCF or the 2017 Federal CCF. The 2017 CCF will only require a memorandum or affidavit of correction based on use of an expired federal CCF after August 31, 2023.
The November 29, 2021 NLCP notice:
ATTENTION: HHS-Certified Laboratories, Applicant Laboratories, and NLCP Inspectors
Subject: 2017 Federal CCF Use
HHS-certified laboratories: Please forward this email to Medical Review Officers (MROs), collection sites for federal workplace drug testing programs.
The Office of Management and Budget (OMB) has granted an extension for using the 2017 Federal Custody and Control Form (CCF) for urine specimens until August 31, 2023. With this extension, either the 2020 Federal CCF or the expired 2017 Federal CCF may be used for urine specimens collected for federal workplace drug testing programs and those collected for testing under the Department of Transportation (DOT) regulations. With this change, the use of the 2017 Federal CCF is now permitted (as of November 23, 2021) without a memorandum for the record (MFR). The use of the 2017 Federal CCF for specimens collected prior to that date requires an MFR.
The Substance Abuse and Mental Health Services Administration (SAMHSA) requested OMB approval for continued use of the 2017 Federal CCF due to a shortage of raw materials needed for the 2020 Federal CCF, reported to SAMHSA by DOT and HHS-certified laboratories. Short supplies include the carbonless paper used for CCF and the resins and plastics used for the labels directly affixed to the form. Items used for specimen collection kits (e.g., cardboard, shipping materials) are also in short supply. These shortages are attributed to the materials’ use for COVID-related activities. Additionally, it was noted there is only one supplier of the carbonless paper and the supplier has indicated they will not be increasing its production.
SAMHSA continues to support efforts to continue workplace drug testing during the COVID-19 pandemic to protect the health and safety of employees, maintain public safety, and sustain US workforce productivity. This change is intended to reduce burden on all drug testing service providers (e.g., collectors, laboratories, Medical Review Officers) and to preserve the supply use by the non-regulated sector, which uses the same materials as the federally regulated sector.
The OMB Notice of Action may be viewed here: View Information Collection Request (ICR) Package (reginfo.gov)