Up until the COVID-19 pandemic, DOT regulations required that all SAP evaluations be conducted in-person. The Department has always maintained that the “face-to-face” assessment and evaluation must be done ‘in person’ and is essential to the SAP process. Recently, the Office of Drug and Alcohol Policy & Compliance (ODAPC) issued a statement regarding the requirement for face-to-face assessments and evaluations.
The ODAPC statement says that even though remote assessments may not be as informative as a face-to-face assessment, during the COVID-19 pandemic they are acceptable. This is temporary guidance for DOT qualified Substance Abuse Professionals (SAPs) up until June 30, 2020 or for the remainder of the health crisis, whichever comes first.
Does this mean my SAP has to go remote?
No, the new guidelines are at the discretion of each SAP. The SAP must put their own technology in place in order to conduct an evaluation remotely. And, it can depend on what technology is available to the client.
Although the Health and Human Services (HHS) is not enforcing or imposing penalties for non-HIPAA compliance during the crisis, many SAPs will still want to use a HIPAA compliant tele-health platform in order to protect your privacy.
The HHS has said that a covered health care provider that wants to use audio or video communication technology to provide telehealth to patients during the COVID-19 nationwide public health emergency can use any non-public facing remote communication product that is available to communicate with patients.
Will the Remote SAP Evaluation be Easier?
Your SAP will follow the same clinical process during the evaluation or assessment as they would in a face-to-face evaluation. Nothing is changed in this regard. The SAP will not only be evaluating your answers to his or her questions but will also be looking closely for verbal and non-verbal cues including your body language, physical appearance, eye contact and more.
If your SAP provides remote evaluations and assessments during this health crisis, it will be easier for you to connect with the SAP from home. If you failed a DOT drug or alcohol test, don’t wait for the pandemic to end before you start the return-to-duty process. Find a SAP near you that can offer remote evaluations and do it now while everyone is at home anyway.