Recommendation

The Drug and Alcohol Testing Industry Association (DATIA) recommends that the Office of Management and Budget (OMB) make the Custody and Control Forms (CCF) electronic to increase the accuracy of the forms and help control against mistakes which are two of the biggest problems in using the forms today. The use of this technology however must remain optional and not be mandated in order to allow small businesses that may not have the capabilities for the technology to continue to operate.

Identification of Problems with the Current CCF

The two biggest problems with the current CCFs are accuracy and missing information. The purpose of the form is for a solidly defendable accountability of a donor's specimen as it goes through the testing process. The problem has become that sometimes the forms are not defendable because they have not been used properly or there is critical missing information. To ensure this quality, the form must be easy to use so that it is properly completed. According to several major laboratories, some of the most prevalent problems with the CCF include:

• 15% of the errors made to the CCF forms are that the donor signatures are not dated correctly
• 11% of the problems are that the forms have some sort of missing data (sometimes, but not always a fatal flaw)
• 8% of the problems come from no donor signature
• 8% of the problems are that the donors do not print their name on the forms.

How can Electronic Forms and the Electronic Signature Solve these Problems?

Clearly, the electronic forms can solve these critical problems of accuracy and missing information because it:

(1) Mitigates mistakes by not allowing you to enter an incorrect date or an incorrect response,
(2) Forces the collector to fill in all the information because it will not allow you to move to the next section until the previous one is filled,
(3) Saves pertinent information for the required amount of time.

In addition to solving these key problems, the technology is also a benefit to the industry because it reduces paperwork costs by sending the information through the use of on-line services, reduces storage space for the hard copies and speeds processing time.

Congressional/Administration Guidance and Support for Electronic Format

Both Congress and the Administration have issued their support for making Federal agencies responsive to these types of technologies. Last year, the Senate passed legislation (S 2107) requiring Federal agencies to make electronic versions of their forms available for electronic submission, including electronic signature, within five years. The House introduced a similar bill (HR 2991), but did not have the opportunity to pass the measure. There is widespread support in both the House and Senate to get this legislation through in 1999 and are working to ensure that the government keeps up with the technology already used in the private sector. In addition, the Administration has given Congress a strategic plan for agencies to provide full service electronic commerce by 2001. In fact, the National Institute of Standards and Technology has issued standards on the use and acceptance of electronic signatures, which the Working Group should use as a standard.