SAFETY AND SECURITY: Expanded Random Drug Testing Could Help Further Detect and Deter Prescription Opioid Misuse

Our objectives for this report were to assess (1) the extent to which the company’s employees who perform safety-related work are at risk for prescription opioid impairment and misuse and (2) the company’s efforts to detect and deter this risk.

After examining de-identified prescription and medical claims data from fiscal year 2019 for 11,356 employees who performed safety-related work, we found that some employees are potentially at risk for prescription opioid misuse, overdose, and impairment. This includes 113 employees who met one or more of the Centers for Disease Control and Prevention indicators for potential opioid use disorder or overdose. We also found that the company’s random drug testing program excludes safety-related positions and common prescription opioids because the company limits its program to the U.S. Department of Transportation’s minimum requirements. Finally, we found that the company’s Benefits group does not require the company’s benefit administrators—CVS/Caremark and Aetna—to report key information from their opioid monitoring tools to the company, such as prescription patterns they detect, trends in specific opioid risk factors, and the number and status of interventions the administrators have taken.

To address the findings, we recommended that the company assess its workforce and identify all positions in which employees’ use of prescription opioids could impair their ability to safely perform job-related tasks. We also recommend that the company identify whether additional prescription opioids are of substantial concern for safety-related work. We recommend that the company then develop a strategy to negotiate with unions to expand its random drug testing program to cover these additional positions and any additional opioids. In addition, we recommend that the Benefits group identify and require benefit administrators to provide additional data, subject to U.S. Health Insurance Portability and Accountability Act of 1996 requirements, that would help support effective decision-making.