Many Colorado employers believe that joining a consortium means their entire random testing program is being managed. The reality is different. A consortium only provides membership in a compliant pool. The day to day work of managing selections, notifications, documentation, and audit readiness is handled by a Third Party Administrator, or C/TPA. PROCOM serves as both, but the responsibilities are not the same.
This article explains the operational side of the program. Some employers refer to this as random drug testing management, but it is simply the part of the process carried out by the C/TPA. Understanding this distinction helps employers know what to expect from membership versus program management.
If you want an overview of how random selection works in general, you can also review our guide on random drug and alcohol testing.
Consortium vs C/TPA Responsibilities.
A consortium determines who is in the pool. A C/TPA manages how the random testing program actually operates.
This includes a comparison of the two functions:
| Consortium | Random Testing Management |
| Provides membership access to a compliant pool | Executes the testing program day to day |
| Determines who is eligible | Determines when and how they are tested |
| Required for DOT regulated employers | Critical for audit readiness and compliance |
| A structural requirement | An operational process |
In other words, a consortium is the membership layer. The C/TPA is the operational engine that keeps employers compliant.
To learn about pool membership requirements, see PROCOM’s page on Colorado DOT consortium options. This article focuses on what PROCOM manages after membership is established.
Why Many Colorado Employers Confuse the Two
Confusion usually comes from assuming that the consortium provides all program management. In reality, the consortium creates the pool, while the C/TPA manages the random testing program. When these roles are blended together, employers are often left without the documentation they need for an audit.
What a Random Drug Testing Program in Colorado Must Include
Regardless of industry, compliant random testing programs must meet the same compliance expectations. Random selections must be valid and scientifically defensible. Notifications must be timely and confidential. Records must be thorough and organized so that employers can pass an audit.
A compliant program includes five core functions.
1. Accurate Employee Pool Management
Employees who perform safety sensitive or policy driven functions must be added, updated, and removed accurately. PROCOM verifies rosters each cycle so employers maintain clean, audit ready files.
For broader compliance support, you can see our full list of testing and compliance services.
2. Valid Random Selection Methodology
Selections must be generated using a compliant system. PROCOM uses validated software that aligns with federal expectations. Colorado employers can review annual testing percentages through DOT published rates to better understand selection frequency.
3. Prompt and Confidential Notifications
Supervisors receive secure notifications when an employee is selected. Each notification includes the selection date, regulatory requirement, and instructions for timely completion. This documentation becomes important during audits, especially when verifying that employees were notified correctly.
4. Collection Coordination and Result Tracking
PROCOM provides the test authorization form, identifies recommended collection sites, and helps employers navigate location challenges common in rural Colorado. Results are tracked and reported promptly, including any required follow up actions.
5. Comprehensive Audit Ready Recordkeeping
Audits focus on documentation. PROCOM maintains a complete record for each selection cycle, including:
- Selection reports
- Collection documents
- Refusals and required follow up tests
- MIS data
Employers who want to strengthen their documentation practices can reference our guide on DOT audit readiness.
When agencies such as FMCSA investigate, they look for alignment with the federal rules. Colorado employers can confirm details at the FMCSA overview of drug and alcohol rules.
Colorado Example. A Typical Scenario
A Colorado employer enrolled in a consortium assuming their random program was being managed automatically. Select employees were not receiving notifications, and MIS reporting lacked documentation. During a compliance review, these gaps became a risk.
Once PROCOM took over random testing management, the employer received structured notifications, validated rosters, archived selection reports, and complete documentation for every quarter. When the next audit occurred, the employer met all expectations with minimal preparation.
This is the most common scenario PROCOM sees. Employers have pool access but lack the operational support required to stay compliant.
Why Proper Random Drug Testing Management Matters
A compliant program requires both structure and execution.
- A consortium determines eligibility.
- Random drug testing management determines compliance.
Regulators want to see whether the program functions correctly every quarter. Employers are cited when selections, notifications, or documentation are incomplete. PROCOM reduces this risk by managing the operational components that audits focus on.
Employers interested in strengthening training requirements can review our guide on DOT drug and alcohol supervisor training.
You can also stay informed on regulatory changes through our DOT drug testing updates.
Strengthen Your Random Testing Program in Colorado
Whether you operate in transportation, aviation, construction, education, public safety, utilities, or energy, a structured random testing program protects your organization and reduces compliance risk. PROCOM manages the entire process so Colorado employers stay audit ready throughout the year.If you prefer in person assistance, our teams in Glenwood Springs, Grand Junction, Pueblo are ready to help. You can also contact PROCOM’s team through our contact page.
Frequently Asked Questions
A compliant program follows valid selection methods, timely notifications, documented testing, and complete records that align with DOT and industry standards.
Most agencies require quarterly selections. Percentages vary by agency and are published annually by DOT.
No. A consortium provides access to the pool. Random drug testing management is the operational work that keeps a company compliant.
Yes. Insurance audits, safety audits, and internal policy requirements often expect a structured random program.
PROCOM maintains selection reports, notifications, test results, and MIS data to support employers during agency or insurance reviews. We are happy to speak with the auditor directly on your behalf.
