Drug Screening Policy and Procedure

I. Scope

This policy describes the drug screening and testing expectations that students are held to as part of their nursing education. This policy applies to all students registered in nursing courses.

II. Policy

The Washington State University College of Nursing (CON) coordinates clinical placements for all students in their nursing programs. These clinical placements, both for direct patient care and indirect care experiences, are legally required in order to meet regulatory and accreditation expectations for nursing education. The nature of providing patient care and health care services inherently requires that nurses be mentally sound and free from effects of intoxicants that may mentally or physically impair them. See Uniform Disciplinary Act, RCW 18.130.180(23) (defining unprofessional conduct as current misuse of alcohol, controlled substances, or drugs). This screening policy promotes nursing health, patient safety, and compliance with the law and professional expectations of assigned students in their clinical sites. Early identification of, and intervention for, student nurses with substance use issues protects patients and maintains trust with nursing and the CON. Nursing has an ethical and legal responsibility for public safety.

The CON views entrance into the profession as occurring when a student is admitted into the academic program.  Accordingly, all nursing students are identified as members of the profession and must accept responsibility and ethics of the profession. This includes adhering to the American Nurses’ Association code of ethics, including safeguarding the patient from harm.

Additionally, students are held to the WSU Community Standards for alcohol and drugs, regardless if they are on or off campus during university breaks. See Executive Policy #20 as well as WAC 504-26-211 and WAC 504-26-212 for regulation on lawful use and possession. While the state of Washington has legalized marijuana, Washington State University complies with Federal law where marijuana remains illegal. WSU considers any results positive for THC or “dilute” as a positive drug screening and will follow the processes identified below. 

III. Procedure

The CON does not require annual drug screening; however, there are two scenarios in which drug screening will be required:

1. to meet requirements for a clinical placement.
   • Clinical sites may have varied and more stringent drug and substance policies beyond those mandated for all students by the CON. For example, a site may require a negative drug screen prior to assignment, placement, or clinical orientation. This type of screening will be referred to as “Site-Required Drug Screenings“.
   • Students will be responsible for the cost of drug screening unless the requesting site provides this service free of charge.
   • The process for obtaining the site-required drug screening will either be facilitated by the agency or facilitated by WSU to meet the agency’s requirement.
   • WSU Vancouver Nursing is a member of a clinical placement consortium that does require Urine Drug Screen completion for all students.
2. when there is “for cause or suspicion”.
   • If a faculty member, clinical preceptor, facility/site mentor, or other individual(s) has reasonable suspicion that a student is impaired, immediate action will be taken to relieve the student of their duties.
   • Drug screening for cause may be required by the site or authorized CON individuals following reasonable suspicion.
   • Students will be responsible for the cost of drug screening unless otherwise arranged.
   • Engagement and participation in patient care activities and clinical site activities will cease while completing the required drug screen and pending the results. Students may not resume patient care activities until cleared to resume by the CON.

Clinical sites may have their own policies around drug screenings and their own interpretation of what constitutes a “positive” drug screen.

A positive drug screen may preclude the student from rotations at their clinical site. See RCW 69.51A.060(7) (permitting employers to establish drug-free policies including denying an accommodation for the medical use of marijuana if an employer has a drug-free workplace policy).

Students placed on probation for professionalism issues or code of conduct violations related to drug and alcohol abuse may be subject to follow-up random drug screening(s) if imposed as a sanction, for which the student will be responsible for the cost of the screening.

Section III. A: Types of Drug Screenings

The most commonly required drug screen is a urinary analysis which may include an “observed collection” and may be requested by the agency at any time with little to no advanced notice. Other types of required drug screening may include, but is not limited to, a hair follicle or nail test. The method of drug screening (i.e., urine analysis, hair follicle, etc.), and scope of substances tested for, will be contingent on the situation.

Type 1: Site-Required Drug Screenings for Placement

Training Sites requiring screenings will either facilitate the testing themselves with students or will require the screening results be facilitated by WSU. The general process for either situation is discussed below.

Site-Facilitated Screenings

1. Site and/or Clinical Affairs will inform the student of the drug screening requirement for placement.
2. Site and/or Clinical Affairs will provide student with where and how to complete the screening.
3. All testing must be completed within the timeframe requested by the Training Site.

WSU-Facilitated Screenings

1. Site and/or Clinical Affairs will inform the student of the drug screening.
2. Students will be directed to order a drug screening through CastleBranch.
3. CastleBranch will provide students with a list of acceptable laboratories to have the screening conducted through.
4. All testing must be completed within the timeframe requested by the Site.

Type 2: For Cause Drug Screenings

Students required to complete a Drug Screening for Cause will be given specific instructions including a deadline for completing this testing.

Medical Review of WSU-Facilitated Screening Results

Non-negative drug test results will be reviewed by the Medical Review Officer (MRO) retained by the CON’s test vendor. The MRO will decide the legitimacy of any prescriptions and consider evidence of illicit substance use.

MROs may request medical documentation from the student to explain a non-negative test result. For claims related to purported prescription medications, students will sign any and all releases of information (ROI) as requested by the MRO to allow for communication with the identified prescriber and to facilitate fact-finding by the MRO. Students who do not provide a ROI, or who do not respond to the MRO’s request for information in the timeframe specified by the MRO, would have their test results treated as positive.

Once the MRO has completed review of non-negative test results, the test vendor will report the final results to the student and the CON. Information about specific substances found will not be reported to the CON in the MRO’s report.

Students may contest the results of a non-negative drug test directly to the test vendor. Students must formally dispute the drug screening results with the test vendor within 30 days of receiving a non-negative test result. If contested, the sample will be retested. Repeat testing will be done with the same sample but at a different laboratory as the initial test.

Confidentiality of Drug Test Results

Reports from the test vendor to the CON will generally not include information about specific substances found in a student’s test unless positive. Records of drug test results and inquiries and evaluations related to drug tests are treated as confidential and are shared only on a strict “need to know” basis. Results of drug tests are maintained in the electronic documentation system maintained by the test vendor. Students have access to their results through the test vendor’s system. The CON will not externally release drug screen results or details of related findings except as authorized by law.

The CON may disclose testing records externally including to NCQAC, the Nursing Care Quality Assurance Commission, and pursuant to a subpoena or other lawful court order. The CON may also disclose positive drugs screenings internally such as a grievance, or other proceeding initiated on behalf or against the student that arises from test results or the violation of either alcohol or controlled substance prohibitions. The CON may also disclose testing records to others upon the written authorization of the student, or as permitted under Washington State or federal law.

Section III. B: Results of Drug Screenings

Negative Drug Screening

Negative results: The student has successfully completed the drug screening and can commence their rotation.

Positive Drug Screening

Regardless of why there was a screening, (either site-facilitated or WSU-facilitated), the CON considers a positive drug screen to be a breach of the CON Code of Professionalism. Per the Department of Health and Human Services Medical Review Officer Guidance Manual.

Note: CBD oils are not highly regulated and could contain THC, thus potentially resulting in a positive drug screen. Any student utilizing CBD who tests positive for THC will follow the process outlined below for positive drug screen.

• Positive: include results that are positive for substances (without a verified medicinal use), diluted, substituted, adulterated or invalid substances; or instances where students do not complete the drug screening by the deadline, refuse testing or take deceptive measures to confound testing. The process identified in the next section will be followed.
  • Results are reviewed by the laboratory’s Medical Review Officer and Clinical Affairs will be notified that the screening is under review.
  • The Medical Review Officer will evaluate the medicinal use of substances and/or other factors that could have impacted the results.
  • If there is a verified medicinal use for the substance, then Clinical Affairs will be notified that the result was clear, and the drug screening successfully completed.
  • If there is not a verified medicinal use for the substance or the student has been notified that they are to not use a specific substance, then Clinical Affairs will be notified what substance was identified. Steps in “Positive Drug Screenings” will be followed.

     Process After a Positive Drug Screening:

1. The Clinical Affairs staff who receives the confirmed positive result from the MRO will immediately inform the program director of the program the student is enrolled.
2. The program director will inform the student (and the course faculty if the screening occurs after clinical training has begun for the term) they cannot initiate or return to patient care activities and that this can impact a student’s ability to complete the program and/or may delay progression.
3. The program director (or course faculty) will complete the PIP to document violation of the CON Code of Professionalism.
4. The program director will, within 7 days of the PIP notification to the student, form an ad hoc committee including the Director of the Program, Director of Clinical Affairs, Director of Center for Student Excellence, and Assistant Dean of Experiential Learning to meet with the student gather additional information. To abide by the timeline presented, the Chair of the applicable department and/or Associate Dean for Academic Affairs may be used to substitute for a member if that member is on leave (i.e sick, or PTO).
5. The committee will make recommendation of action to program director and, if applicable, course faculty within 3 days following the committee meeting. The recommendation may include any of the following:
   1. student undergoes new drug screening within 3 days of notice from the committee and if
      1. negative – will be allowed to resume clinical rotation.
      2. positive – a second positive drug screen will result in the student being removed from the clinical placement. The ad-hoc committee will reconvene to determine if the student will be afforded the opportunity to have a third drug screening or to be withdrawn from the clinical course.
   2. student fails the clinical course (involving course faculty of record; this action will also trigger a review by the progression committee which may make recommendation for dismissal from program).
      1. pending further information or investigation (involving student and CSE staff for assistance)
6. The CON may also refer the matter to the Nursing Care Quality Assurance Commission (NCQAC) for investigation and enforcement of the Uniform Disciplinary Act. This will occur when patient harm occurred, or the student created unreasonable risk a patient would be harmed.

Policy Title:	Drug Screening Policy & Procedure
Policy Home:	Academic Affairs, College of Nursing, Spokane
Policy Inception Date:	08/2023
Policy Applicable Party:	All students enrolled in a College of Nursing program
Date of Last Change	08/2023
Responsible Party, Level I: (to create/provide feedback/review)	Academic Affairs
Responsible Party, Level II: (to implement)	Academic Affairs
Responsible Party, Level III (to implement)	Center for Student Excellence
Related Other Policy or Regulation:	ANA Code of Ethics (2015) WSU EP20 – Alcohol and Drug Policy (2022 Nov) RCW 18.130.180 (2021) RCW 69.51A.060(7) WAC 504-26-211 WAC 504-26-212