For pipeline contractors, maintaining a compliant drug and alcohol testing program is a team effort. Multiple parties play a role in supporting workplace safety and regulatory compliance, yet two of the most commonly misunderstood roles are those of a Third-Party Administrator (TPA) and National Compliance Management Services (NCMS).
While both support compliance, they serve very different functions.
A TPA helps contractors establish, administer, and maintain their drug and alcohol testing programs. NCMS independently reviews and verifies that those programs meet applicable requirements and are being followed consistently.
Understanding this distinction can help contractors better prepare for audits, strengthen their compliance efforts, and know where to turn when questions arise. Auditors want to see that contractors can demonstrate compliance with their programs and procedures and the right TPA can be a resource to help ensure success.
The TPA’s Role: Building and Supporting Your Program
A Third-Party Administrator (TPA) serves as a resource for managing the day-to-day aspects of a drug and alcohol testing program. Navigating the DOT regulations and Operator requirements can feel overwhelming, so many contractors rely on a TPA
A TPA may assist with:
- Establishing and maintaining testing procedures
- Coordinating drug and alcohol testing services
- Managing random testing selections
- Supporting recordkeeping and documentation requirements
- Providing guidance on how program requirements apply to a contractor’s operations
Many TPAs also offer training, educational resources, and additional support services that help contractors better understand their compliance obligations.
While a TPA can provide expertise, guidance, and administrative support, contractors remain responsible for understanding their own programs and ensuring they are implemented correctly within their organization.
NCMS’s Role: Independent Compliance Verification
Unlike a TPA, NCMS does not administer or manage a contractor’s drug and alcohol testing program.
Instead, NCMS provides independent oversight and verification on behalf of pipeline operators. Through audits and compliance reviews, NCMS evaluates whether contractors have compliant programs in place and whether those programs are being followed as intended under both federal regulations and operator-specific requirements.
During the review process, NCMS assesses whether:
- Appropriate drug and alcohol testing programs are in place
- Required policies and procedures have been established
- Program requirements are being followed consistently
- Documentation supports the contractor’s practices
- Testing and recordkeeping processes are being properly implemented
- The contractor can demonstrate compliance with applicable requirements
The goal is not simply to determine whether a written program exists. Audits are designed to evaluate whether the contractor understands its program, follows established procedures, and can provide documentation that supports compliance.
This independent verification helps operators reduce risk, maintain safer worksites, and demonstrate compliance with regulatory and operator-specific requirements.
What This Means During an NCMS Audit
One of the most common misconceptions during an audit is that the auditor will explain how a program should operate or guide a contractor through the answers.
While it is understandable to seek clarification during an audit, NCMS auditors are not there to administer a program or provide compliance consulting. Their role is to verify that the contractor already understands the program and is following it correctly.
During an audit, contractors should be prepared to:
- Answer questions about how their program operates
- Provide information on their service agents (lab, MRO, etc.)
- Provide requested documentation
- Demonstrate that procedures are being followed consistently
- Show evidence of compliance with applicable requirements
If contractors have questions about program requirements, implementation, documentation, or other operational details, those discussions are often best addressed with their TPA.
Contractors can and should reach out to their TPA whenever they need assistance understanding or managing their program, including before, during, or after an audit.
Know Who to Call and Know Your Program
Successful compliance depends on understanding the role each partner plays.
When you need assistance establishing, maintaining, or understanding your drug and alcohol testing program, a TPA is often the right resource.
When an operator requires independent verification that your program is compliant and being followed, NCMS provides that review.
By understanding that distinction and maintaining a strong working relationship with your TPA, contractors can approach audits with greater confidence and demonstrate a clear commitment to safety and compliance.
Need help establishing a compliant drug and alcohol testing program? NCMS can help connect you with a qualified TPA that can provide the expertise and support your organization needs. Contact an NCMS representative today to learn more.
