In UGI Utilities, Inc. v. Unemployment Compensation Board of Review, 851 A.2d 240, 245 (Pa. Cmwlth. 2004), the Court held that the Board erred, in part, because the Board analyzed a discharge pursuant to an employee's failure of a drug test under Section 402(e), rather than 402(e.1). Id. The Court recognized that after the passage of Section 402(e.1), discharges pursuant to failure of a drug test should no longer be analyzed as if they were willful misconduct cases. Id. at 245-47. In UGI Utilities the Court reversed the Board's refusal to deny the claimant benefits under Section 402(e) of the Law, 43 P.S. 802(e). The Court rejected the argument that the employer failed to show that the claimant committed willful misconduct by violating a company substance abuse policy after submitting to random drug testing and being found positive for cocaine. She refused retesting and was then discharged. The policy provided that a positive test result would be reported to the designated human resources representative who might then inform appropriate management officials. The Board also agreed that the employer failed to provide sufficient evidence regarding the chain of custody, and it granted benefits. In reversing, the Court held that the Board erred in concluding that no difference existed between Section 402(e) (general provision denying benefits for violating work rule) and Section 402(e.1) (specific provision denying benefits for failing to pass test conducted under substance abuse policy so long as it was not requested or implemented in violation of the law or of a collective bargaining agreement). The Court concluded that Section 402(e.1) required an employer to show that "it followed its established 'substance abuse policy' in discharging an employe for drug use on the job." Id., 851 A.2d at 246.