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HCLLC OPERATIONS MANUAL 2018

Published by learningsupport, 2018-05-03 09:20:40

Description: HCLLC OPERATIONS MANUAL 2018

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Table of ContentsMission Statement................................................................................................................................................................................................... 3Equal Opportunity Employment .......................................................................................................................................................................... 5Conflict of Interest .................................................................................................................................................................................................... 5Organizational Chart................................................................................................................................................................................................ 6Code of Business Ethics......................................................................................................................................................................................... 9Standards of Conduct......................................................................................................................................................................................... 10Sexual and Other Unlawful Harassment....................................................................................................................................................... 11Contracts “Agreement of Service”................................................................................................................................................................... 12Compliant Management...................................................................................................................................................................................... 13Reporting Clinical Incidents................................................................................................................................................................................ 14Work Related Injuries........................................................................................................................................................................................... 15Emergency Management.................................................................................................................................................................................... 16Recruitment ............................................................................................................................................................................................................. 22Professional Work Experience Requirements for Healthcare ............................................................................................................... 23Professional License / Certification Verification .......................................................................................................................................... 24Professional Skill Reference Check ................................................................................................................................................................. 26Employee Health Clearance Policy.................................................................................................................................................................. 27Competency Assessment Policy...................................................................................................................................................................... 34Background Check Policy ................................................................................................................................................................................... 35Drug Free Workplace........................................................................................................................................................................................... 36Basic Life Support (BLS) Certification.......................................................................................................................................................... 38Appropriate Placement and Reassignment Policy .................................................................................................................................... 39Orientation Policy................................................................................................................................................................................................... 40Continuing Education Requirements.............................................................................................................................................................. 41Performance Evaluation ...................................................................................................................................................................................... 42Definition of Active Employee ........................................................................................................................................................................... 43Health Carousel Internal Do Not Use Policy ................................................................................................................................................ 43Performance Measurement Program ............................................................................................................................................................. 45Information Management ................................................................................................................................................................................... 47Healthcare Professional Job Description – Case Manager...................................................................................................................... 53 1 OPERATIONS MANUAL | v13018

Healthcare Professional Job Description - COTA ...................................................................................................................................... 56Healthcare Professional Job Descriptions – EKG Tech............................................................................................................................. 59Healthcare Professional Job Description - LPN .......................................................................................................................................... 62Healthcare Professional Job Description – Medical Technologist/Medical Lab Technician......................................................... 65Healthcare Professional Job Description – Occupational Therapist..................................................................................................... 68Healthcare Professional Job Description – Physician Assistant/Nurse Practitioner....................................................................... 71Healthcare Professional Job Description – Physical Therapist .............................................................................................................. 74Healthcare Professional Job Description – Physical Therapy Assistant............................................................................................. 77Healthcare Professional Job Description – Registered Nurse................................................................................................................ 80Healthcare Professional Job Description – Radiological Tech ............................................................................................................... 83Healthcare Professional Job Description – Speech Language Pathologist....................................................................................... 86Healthcare Professional Job Description – Surgical Tech........................................................................................................................ 89 2 OPERATIONS MANUAL | v13018

Mission StatementPurpose: To communicate the key values the organization is committed to.JC Standard: LD.1.3 The leaders set goals, develop plans, and manage the firm’s performance measurementand improvement activities.About Health CarouselHealth Carousel, LLC, is an Ohio limited liability corporation based in Cincinnati. Health Carousel provides avariety of workforce solutions and services for leading healthcare staffing organizations.From the headquarters in Cincinnati, Ohio, Health Carousel has been providing healthcare recruiting andstaffing services for more than ten years. We recruit top quality health professionals globally and place themwith client organizations, across the country. We have clients in a variety of clinical settings includinghospitals, skilled nursing, government facilities and even home health.We tailor assignments to the work-style preferences of our healthcare professional employees.• PRN Assignments (a.k.a. Relief, Per Diem, Registry or On-Call): These assignments may be as short as a single shift, a series of shifts or patient visits over more defined period. PRN Assignments typically with clients located within a commutable distance from the professional’s primary residence.• Local Contract Assignments: These assignments typically are pre-scheduled for a designated contract period and are typically located within a reasonable daily commuting distance. From the employee’s home; typically, within a 50-mile radius of the employee’s residence. These types of assignments are normally longer than per diem assignments, usually ranging from four to thirteen weeks. Some Local Contracts are not eligible for housing or transportation expense reimbursements and/or stipends during the assignment period.• Travel Assignments: These contract assignments are located outside of a reasonable commuting distance from your home. Travel assignments are typically structed as thirteen-week assignments; however, they could be shorter or longer in some situations. Travel assignments usually include guaranteed work schedule, paid transportation to the assignment and housing throughout the assignment period.• Passport USA Assignments: Passport USA provides foreign educated health professionals for long term contract assignments with U.S. client organizations, for periods up to three years or more in length. Contract professionals participating in this type of assignment usually require a visa sponsorship by Health Carousel. Participants in Passport USA assignments may receive financial support for transitional housing and initial transportation to the assignment. However, unless a foreign contract professional is assigned to a client located outside of her/his commutable work area; Passport USA Contract Professionals are not eligible for financial support for housing and transportation expenses during the remainder of their assignment period.• Direct Placement: Full-time employment as a direct employee of our client 3 OPERATIONS MANUAL | v13018

Health Carousel prides itself on listening carefully to the professional aspirations of our Contract Professionals.Then, we submit them to jobs that match their priorities. If we don’t have position with a current client thatmatches their preferences, our sales and marketing team will confidentially promote them to prospective clientorganizations. • Health Carousel Travel Network (HCTN): HCTN provides “Mission Critical” travel and local contract staffing assignments nationwide for nurses and allied health professionals. HCTN also provides direct placement of pharmacy and advanced practice professionals, as well as management level professionals for healthcare organizations. HCTN utilizes a multi-brand network to maximize coverage. These brands include Tailored Healthcare Staffing, Next Travel Nursing, and Medical Staffing Options. • Passport USA (PPUSA): PPUSA provides long-term contract placement and direct placement of international healthcare professionals to U.S. healthcare institutions.Vision and MissionCompany Vision:To provide healthcare organizations with a range of workforce solutions to help them attract, employ, developand retain the best talent available, to become the preferred workforce partner for our Clients and ContractProfessionals and, through the services we provide, elevate the industry and occupations we serve.Company Mission:To help healthcare organizations and healthcare professionals achieve their professional objectives throughthe provision of creative, high-value, socially responsible staffing, workforce development, and human capitalmanagement services.We intend to achieve the Mission and Vision by: • Listening carefully to understand the goals, opportunities and challenges of our client and employee partners • Providing solutions that are creative, high-value, and socially responsible; and • Earning the trust and confidence of our client and employee partners by displaying integrity and respect in our business relationships. • Developing mutually rewarding, long lasting relationships with our clients, strategic partners, and employees that reflect a spirit of partnership.Core Values:Everything we do will be driven by our commitment to: • Honesty and integrity – We conduct our business with uncompromising integrity and strive to live up to every one of our commitments to our customers, partners, Contract Professionals and shareholders. We understand that a good reputation takes a long time to acquire, but only a moment to lose. • Ethical business practices – We strive to maintain a high standard for ethical business practices. We believe that doing the right thing is not just good for the soul, it’s good for business. 4 OPERATIONS MANUAL | v13018

• Fair treatment and respect for all people – We believe that everything is due fair treatment and respect as an individual. We work diligently to provide the kind of fair treatment and respect to others that we would expect for ourselves. • Excellence and professionalism – We aspire to high standard of excellence and professionalism. It is our goal to be regarded by our customer and Contract Professional partners as among the very best in our industry. • Citizenship and social responsibility – We are proud of our efforts to provide leadership in citizenship and social responsibility. We recruit responsibly and reinvest in sustainability and other humanitarian initiatives domestically and internationally.Our commitment to these core values has helped us earn our reputation as a quality organization within thecommunities we serve, and we understand that we must work diligently each day to maintain that highstandard.Equal Opportunity EmploymentPurpose: Health Carousel is an Equal Opportunity Employer. It is the policy of Health Carousel to provide equal opportunity for all qualified persons and not discriminate against any employee or applicant for employment because of race, color, religion, sex, age, national origin, veteran status, disability, or any other protected status.JC Standard:This policy applies to all personnel actions including recruitment, hiring, promotion, training, transfer, retention,compensation, benefits and all other details and conditions of employment.Conflict of InterestPurpose: To identify potential conflicts of interest and to implement a process to handle conflicts of interest when they arise.Procedure: Employees have an obligation to conduct business in such a way that prohibits actual or potential conflicts of interest. The purpose of these guidelines is to provide general direction so that employees can seek further clarification of issues.JC Standard: LD.3 The firm addresses existing or potential conflicts of interest related to its internal andexternal relationships.An actual or potential conflict of interest occurs when an employee who is in a position to influence a decision,may result in a personal gain for that employee, or his relative or someone else known to him. Employees mustcomplete the Health Carousel Conflict of Interest Policy Acknowledgement form annually. 5 OPERATIONS MANUAL | v13018

If an employee has any influence over transactions involving purchases, contracts, or leases, it is imperativethat they disclose this to the Compliance Committee, as soon as possible, so that the absence of any actual orpotential conflict of interest can be established.Disclosure: The best way to avoid a conflict of interest is to disclose any relationships that others mightmisinterpret. This includes any relationships with other employees, customers, suppliers, and competitors. Aconflict of interest may arise when doing business or competing with companies for which a family memberworks; or in which a family member has an ownership interest. Employee should raise questions aboutpossible conflicts of interest and disclose these kinds of situations to a member of the Compliance Committee.Board Memberships: Employees may serve on the board of directors of community or non-profitorganizations if the role does not affect employee’s ability to perform his/her job for Health Carousel. To makesure such activities do not cause a conflict of interest or other problem with position at Health Carousel,employee should disclose this information to the Compliance Committee.If employee becomes a board member for another organization, employee should ask about the type ofindemnity and insurance for board members. Except when employee serves as a member of anotherorganization’s board at Health Carousel’s request, Health Carousel will not defend or indemnify employee foranything that occurs as a result of board membership. Employee shall not serve on the board of directors orany company that competes with Health Carousel.Employment Activities and Outside of Health Carousel: Regular internal employees, are required to provideyour full time and attention to his/her position with Health Carousel. Employees are not permitted to acceptemployment (with or without pay) outside of their duties with Health Carousel without the prior writtenconsent of the Company. During period of employment and for a period of two years’ post-employment,employee may not provide services to any business that competes with Health Carousel or any of its divisionsor subsidiaries.Employees may not use Health Carousel’s time or resource for non-Health Carousel employment activitieswithout CEO approval. Employee must make sure any activities are strictly separate from duties at HealthCarousel.Organizational ChartPurpose: To provide a visual representation of the organization, its employees and their job responsibilities.JC Standard: LD.1 The health care staffing services (HCSS) firm clearly defines its leadership roles. 6 OPERATIONS MANUAL | v13018

Corporate: 7 OPERATIONS MANUAL | v13018

Passport USA:HCTN: 8 OPERATIONS MANUAL | v13018

Code of Business EthicsPurpose: To identify potential ethical issues and to implement a process to handle such issues.JC Standard: LD.2.1 The firm has a written code of business ethics. LD.2.2 The firm identifies potential ethical issues related to its business practices LD.2.3 The firm implements a process to handle ethical issues.As a condition of employment with Health Carousel, each employee pledges his/her adherence to theprinciples and practices set forth below. Health Carousel employees acknowledge that such compliance is inthe best interests of the organization, its customers and its employees. Health Carousel employees agree toalways strive to:• Respect all laws and avoid any involvement in false, fraudulent, or deceptive activity.• Maintain high standards of honesty, integrity, and professionalism• Treat colleagues and those entrusted to their care with respect and dignity• Protect confidences and respect the privacy rights of patients, clients, and employers; reveal confidential information only as required by law to protect the welfare of the individual or community• Carry out responsibilities of assigned job in a manner that is respectful to co-workers and that contributes to an environment free of all forms of harassment• Ensure the delivery of quality patient care and service unrestricted by concerns of personal attributes and without discrimination.• Use equipment and accessories, employ techniques and procedures, and perform services in accordance with acceptable standards of practice and facility protocol.• Employ ethical recruiting practices by not directly, knowingly recruiting, encouraging or enticing professional to leave employment of a client.• Demonstrate ethical practices for international recruitment, which is free from intimidation or exploitation.• Honor all contracts, agreements, and assigned responsibilitiesPersonal Accountability: All of us are personally accountable for our decisions and actions. We each mustfollow a course of personal conduct that preserves and enhances Health Carousel’s reputation for honesty andintegrity. To do so, it is critical that we each understand the laws, company policies and contractual obligationsthat apply to our specific areas of responsibility. We should never misuse our authority, whether for personalinterests or to the detriment of Health Carousel.Added Responsibility for Managers: While all Health Carousel employees must follow the Code, each HealthCarousel manager must be an example for those under his or her leadership. S/he must know the Code, TheEmployee Handbooks, and all policies and procedures relevant to their area of responsibility. Manager mustcreate and maintain a workplace where all employees and Contract Professionals under their leadership knowthe ethical and legal behavior that is expected of them. In some cases, all or part of the Code and other 9 OPERATIONS MANUAL | v13018

company policies may apply to those acting on behalf of the company such as sales agents, external advisors,contractors and others. The business person responsible for the relationship and representatives of HealthCarousel’s Compliance Committee should decide if this Code or any company policies apply to a contractor.Violations and Consequences: Failure to follow this Code, and other company policies, applicable laws andregulations is unacceptable. Unethical or illegal acts cannot be justified by saying they were good for thecompany or were directed by a higher authority in the company. No employee is every authorized to commit,or direct another employee to commit, an unethical or illegal act. In addition, employees cannot use acontractor agent, consultant, distributor, or third party to perform any act not allowed by applicable laws of acontractor agent, consultant, distributor, or third parties county, this Code, company policies, and contractualobligations will be taken seriously and may result in disciplinary actions. In addition, employees who commitcriminal or illegal acts may face immediate termination and possible legal action.Resources for Questions: Employees are invited and should feel free to speak with their manager and/or othermanagerial representatives of the company, about any questions they may have and any action they believemay violate this Code, the law, company policies, or contractual obligations.Duty to Report Misconduct: Employees are to promptly report illegal or unethical conduct to an appropriatecompany representative. Failure to report suspected violations violates this Code and may lead to disciplinaryactions up to and including termination. If an employee has any concerns about reporting the conduct tohis/her manager or s/he has done so and the conduct has not been corrected, the employee should contact arepresentative of the Compliance Committee. Managers who receive reports of possible illegal or unethicalconduct must report this to the CEO immediately.Compliance Committee: The Compliance Committee is responsible for reviewing and responding tosubmissions of complaints, concerns, violations and proposed revisions to Health Carousel’s Code of Ethicsand Professional conduct. Committee members are currently as follows: • Marijke Woodruff, Chief of People: [email protected] • Jon Kukulski, General Counsel: [email protected] of ConductPurpose: To identify general standards for job performance and behavior expected of all Health Carousel employees.JC Standard: LD.4 The firm complies with applicable laws and regulations.The performance and behaviors of Health Carousel Contract Professional correlates directly to the clientfacility’s continuing and future use of the services of Health Carousel and the Contract Professional. Therefore,it is essential that Contract Professional conduct his/herself in a professional manner throughout his/herassignment. 10 OPERATIONS MANUAL | v13018

Health Carousel Contract Professionals are responsible to adhere to federal and state laws as well as therules, policies and procedures set forth by the healthcare facility, including any required professionalcompetency, drug screening or other testing.Allegations or omission of acts of negligence, malpractice, tardiness, unauthorized absence, substance abuse,insubordination, violation of facility rules or other unprofessional conduct or breach or neglect of duty may begrounds for immediate termination of the assignment. In the event of misconduct, wages for hours workedprior to termination will be paid, less any deduction for housing (including lease termination costs), anyapplicable ground and air travel expenses, and benefit charges. Upon termination, Health Carousel has nofurther financial obligation to Contract Professionals who violate these standards of professional conduct.Healthcare Contract Professionals who are on assignment with Health Carousel are not to recruit or solicitdirect employees of the client facility.Health Carousel Contract Professionals are expected to abide by our Code of Professional Practice: • Respect the patient’s right to confidentiality, privacy and individuality • Maintain professional integrity by neither seeking nor receiving personal compensation for purveyor or services in return for the referral of a patient or patients to such purveyor • Be responsible for informing the patient (or his/her representative) and the necessary medical and administrative personnel when a care plan is judged inappropriate • Maintain complete records and appropriately document the care process including assessment • Promote interdisciplinary practice and interagency collaboration to achieve continuity of care • Communicate as accurate assessment of patient care needs to service providers. • Accurately represent any limitations of serviceSexual and Other Unlawful HarassmentPurpose: Health Carousel is committed to providing a work environment that is free from all forms of discrimination and conduct that can be considered harassing, coercive, or disruptive, including sexual harassment.At Health Carousel, we strive to maintain a workplace that promotes mutual employee respect and productiveworking relationships. Therefore, Health Carousel prohibits unlawful harassment of any of its employees.Harassment refers to behavior that is personally offensive, impairs morals, and interferes with the workeffective ness of employees. Any harassment of employees, by other employees, will not be permittedregardless of their working relationship.Sexual harassment includes unwelcome advances, request(s) for sexual favors, and other verbal or physicalconduct that is both sexual and offensive in nature. As a guide for supervisors and managers, sexualharassment is defined below based on government definitions. 11 OPERATIONS MANUAL | v13018

Unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexualnature constitute sexual harassment when: • Submissions to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment • Submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual • Such conduct has the purpose of effect of unreasonable interfering with an individual’s work performance or creating an intimidating, hostile, or offensive working environment.Individuals who believe they have been subjected to harassment from either a co-worker or a manager shouldmake it clear that such behavior is offensive to them and bring it to the attention of their manager. In theevent, you believe that either your immediate manager or other supervisory employee has committedharassment, you should contact the Chief Executive Officer directly. You are encouraged to report conduct youbelieve to be harassment within 72 hours of its occurrence. All complaints of harassment will be investigatedimmediately and confidentially. Investigation may include private discussions with the complainant, thealleged harasser, and any witnesses. Any employee who, after investigation, has been found by HealthCarousel to have harassed another employee, or retaliated against that employee for making a complaint ofharassment, will be subject to appropriate disciplinary action up to and including termination.Contracts “Agreement of Service”Purpose: To assure the services contracted for by Health Carousel are provided to the customer.JC Standard: LD.5 The firm provides services to customers according to a written agreement.Written agreements with Client facilities and other healthcare providers are a necessary part of doingbusiness. Written Agreements protect both parties by explaining terms of service, expectations, andaccountability.Health Carousel will attempt to establish a written agreement with all clients prior to providing service.Because most written agreements originate with the Client or the Client refuses to sign an agreement, ofteninformation relative to the scope of our services is not included. Therefore, Health Carousel will provide clientwith a written policy statement that outlines expectations and accountabilities of both Health Carousel andClient. A copy of this policy statement will be maintained in the Joint Commission file and updated as needed.The following are the minimal requirements that must be included in the contract or the policy statement:• Whether or not Health Carousel uses subcontractors• Which party (Health Carousel or customer) determines the competencies required for the assignment• The reassignment of staff only to areas of practice with their clinical competence• That staff members are employee of the firm 12 OPERATIONS MANUAL | v13018

• How unexpected incidents, errors, and sentinel event that involve Health Carousel’s staff are communicated to Health Carousel • How occupational safety hazards or events that involve Health Carousel staff are communicated to Health Carousel • Health Carousel encourages the client to orient staff to the relevant unit, setting or program specific policies and proceduresUpon signature, contracts are uploaded into the Account folder on the Company’s corporate shared drive.An Active Client is defined as any client that Health Carousel has a current signed contract or policy statementin place and currently has Health Carousel Contracted Professional(s) on assignment.Compliant ManagementPurpose: A Customer Service Complaint is any complaint and/or concern from one of our valued customers regarding a situation or incident that results in dissatisfaction of that customer. The purpose of our complaint policy is to: - To have a positive impact in improving customer service and satisfaction - To understand the causes that underlie a complaint and to focus on making changes to systems and processes to reduce the probability of a similar complaint in the future. - To prevent potentially compensable events and to protect corporate financial resources potentially jeopardized by customer dissatisfaction. - To analyze and trend data to identify opportunities for organizational performance improvement.JC Standard: LD.7 The firm addresses the resolution of complaints from customers and staffHealth Carousel accepts complaints from any individual or organization that has concerns about the servicesprovided by Health Carousel, the clinical setting(s) staffed by Health Carousel and/or Health Carousel’shealthcare professionals. The following guidelines shall be followed in resolving complaints.• Complaints must be filed within 30 days of the alleged act.• When possible, the complaint is submitted in a written format that describes the occurrence• An individual seeking to file a complaint needs to contact Health Carousel management. An intake interview or phone interview will be conducted with the complaining party.• After a careful screening process, the complaint is investigated to determine if there is sufficient evidence to support allegations• A complaint may be settled at any time after it is filed. Opportunities will be given to all parties involved to ask questions, provide information, and suggest witnesses in order to resolve complaint.• As the investigation proceeds, individuals will be interviewed and pertinent records and documents will be reviewed.• Health Carousel’s Nursing department will investigate all complaints of the clinical nature. 13 OPERATIONS MANUAL | v13018

• The Compliance Committee will investigate all complaints of an illegal or unethical nature. • The Quality Review Committee will review all complaints and determine final resolution. • The person filing the complaint must cooperate fully by providing accurate information and by supplying documents to support allegations. • All information gathered in the course of an investigation is subject to disclosure unless otherwise protected by the individual’s right to privacy (e.g. medical records). • Complaint, investigation and resolution will be documented using the Complaint/Termination Report. A summary of the complaint will be entered in the Complaint Log.All complaints will be reviewed at least monthly by the Quality Review Committee to identify trends, developand implement performance improvement plan to prevent similar complaints in the future.Quality Review Committee: The Quality Review committee is responsible for reviewing and responding toany complaints, concerns, violations, ethical issues or questions that would impact any of our HCPs. They havean additional responsibility of updating policies/procedures and educating internal staff on suchpolicies/procedures. The Committee can request advisors as needed. Committee members are currently asfollows: • Jon Kukulski, General Counsel: [email protected] • Earl Dalton, Chief Nursing Officer: [email protected] • Neil Okonak, Sr. Director of Support Services: [email protected] Clinical IncidentsPurpose: Health Carousel identifies and takes steps to reduce safety risksJC Standard: LD.8.3 The firm implements a process for its clinical staff to report unexpected patient incidentsrelated to the care, treatment and services provided (including errors, safety hazards, injuries and sentinelevents), regardless of whether the incident resulted in an adverse patient outcome.Clinical staff must recognize the importance of following effective procedures and are encouraged to speak upif something has compromised or might comprise patient safety and quality.A clinical incident is any event or series of events that resulted in or had the potential to results in an adversepatient outcome. Examples of a clinical incident include but are not limited to omission of treatment, deviationfrom policy, medication error, improper equipment usage, patient fall, inaccurate clinical assessment, andpatient or physician complaint. Clinical staff should notify Health Carousel of any clinical incidents that occurwhile on assignment, regardless of an adverse action. Health Carousel’s Nursing Department will be notifiedregarding all clinical incidents. The clinical incident, including investigation and resolution will be documentedon the Compliant Management Report.A sentinel event is an unexpected occurrence involving serious physical or psychological injury or death or therisk thereof. These events must be reported to Health Carousel’s management within 24 hours of the 14 OPERATIONS MANUAL | v13018

occurrence. The Client facility will conduct a Root Cause Analysis for all sentinel events, to identify the causesof the error. Health Carousel’s Nursing Department will work closely with any staff involved in an error,including supporting them through the difficult time, facilitate communication between the clinical staff andthe customer about the event, and based on the root cause analysis, plan for improvement activities.In the event of deviation of practice according to the professional practice act, fraudulent behaviors, narcoticabuse or deviation and/or other aberrant or illegal behavior, each event is documented and a report is made,which includes information from the customer. Health Carousel’s Nursing Department reports each situationaccording to the guidelines of the appropriate professional association or licensing board.Work Related InjuriesPurpose: All employees of Health Carousel, LLC are covered by Workers’ Compensation insurance in complianceJC Standard: LD.7 The firm addresses the resolution of complaints from customers and staff reportedoccupational illness, work-related injuries and security incidents that occur while one assignment.LD.8 The firm identifies and takes steps to reduce safety risks.Health Carousel provides Workers Compensation insurance for its employees as required by law. It is ourphilosophy that if an employee is injured while at work, it is our intent to assist that employee to return towork as soon as possible. The employee is obligated to report a work-related injury to Health Carouselimmediately. An Injury Report Form needs to be completed by the employee as soon as possible after theinjury.Any on-the-job injuries, exposures to disease, illnesses that may be attributable to the workplace or any othersignificant incidents must be reported to the supervisor at the facility and to Health Carousel’s BenefitsDepartment immediately. Benefits Team Phone: 513.872.1237 Email: [email protected] following steps are required when there is a work-related injury and/or exposure:1. Assess the seriousness of the injury and obtain appropriate medical treatment.2. Notify the health facility supervisor and Health Carousel ‘s Benefits Team. As soon as possible within the first 24 hours. Failure to report an incident in a timely manner may affect Worker’s Compensation eligibility and is also grounds for disciplinary action. Health Carousel’s Benefits Team will direct the employee to the appropriate worker’s compensation office for the state in which the employee is working.3. Complete an accident investigation report; even if the injury is minor and medical assistance is not needed. If a company representative is not available, employee should leave a voicemail message. 15 OPERATIONS MANUAL | v13018

When completing incident report forms, the report from the facility should be used to document important information about the workplace incident, as well as Health Carousel’s incident report. A witness, preferably the shift supervisor, or someone who was present at the time of the incident and saw what happened should sign the incident report. 4. Employee must submit to a drug screen if injured on the job. Health Carousel requires Contract Professionals to take a drug screen as a routine part of every workplace incident. When seeking medical treatment, request physician to order a drug screen. If you do not seek treatment, a drug test is still required. The employee should contract his/her Health Carousel supervisor/recruiter for proper contact information to take the test at least within 24 hours of the incident. 5. Complete any state required injury reports when applicable and forward to Health Carousel. Submit medical release form prior to returning to work. Employee may return to work upon certification by the physician. Prior to return to work, employee must provide Health Carousel with a statement from the physician certifying his/her ability to return to work, including the return date as well as any applicable restrictions.For Maryland only:In accordance with State Regulations, the State of Maryland has established a Nursing Staff Hotline. The purpose of thehotline is: - To receive complaints about local Nursing Staff Services Agencies; and - To receive questions about local Nurse Staff Service AgenciesThe hotline number is 800.492.6005: All voicemail messages will be returned during the next business day. Writtencomplaints may be submitted to www.dhmh.maryland.gov/ohcg/sitepages/FAQS-Complaints.aspxTo report any abuse or neglect, please go to https://c.ymcdn.com/sites/www.nasw-md.org/resource/resmgr/imported/child%abuse%20reporting%20checklist.pdfContract Professionals performing services at a healthcare facility in the State of Maryland must understand that, ifHealth Carousel is or becomes aware of an action or inaction by a Contract Professional that may be grounds foraction under Health Occupations Article, Annotated Code of Maryland, Health Carousel shall (i) complete athorough investigation into the details surrounding the action or condition and (ii) document the details surroundthe action or condition and maintain a record of such documentation on file internally. Where necessary orappropriate, Health Carousel shall report the action or condition to the appropriate Board and the Office. Where theOHCQ conducts its own investigation or inspection based on a complaint, Health Carousel may, upon request andas appropriate, make copies of the internal records or reports available to the OHCQEmergency ManagementPurpose: Every business can experience a serious incident that can prevent it from continuing normal business operations. The purpose of this policy is to reduce the potential cost, loss of services and supplies, and/or damage that can arise from such an event, with the goal of avoiding business failure as the result of such disruptive incidents. 16 OPERATIONS MANUAL | v13018

JC Standard: LD.9 The firm addresses emergency management. The firm has a written plan describing theiremergency management process. The plan includes backup communication systems in the event of acommunication system failure.In order to effectively plan and strategize against emergencies and unforeseen contingencies, there is theneed to identify potential incidents and assess their impact on the continuity of business operations andfunctions. Listed below are a description of such incidents and possible outcomes of such occurrences. Thepotential incidents have been grouped into relatable categories.Hazardous Vulnerability Analysis Impact Rating Probability of Occurrence Risk 1. Very High 2. High 3. Medium 4. Low 5. Very Low 1. Terminal 2. Devastating 3. Critical 4. Controllable 5. IrritatingElectrical Power Failure XXCommunication Service XXBreakdownLoss of Water Supply X XAir Conditioning Failure X XCyber Crime/Cyber XXAttackLoss of Data X XDisclosure of XXInformationMain Server Failure XXActive Shooter XXFire XXEarthquake/Tornado XXIce/Snow Storms XXLoss of Utilities and Services: • Electrical Power Failure: This can be internal, caused by equipment or cable failure, or may be regional in origin. Regardless of the source, power failure can impact the operations of Health Carousel. Lights, computers, telephones and other communication devices will not be operational. Customer service and revenue may be impacted. 17 OPERATIONS MANUAL | v13018

• Communication Services Breakdown: Health Carousel, being a customer service company, is fully dependent on telecommunication services such as phone, email, internet, fax for day-to-day business. A breakdown in communication service can put a halt to business and therefore cause a loss of customers as well as revenue.Information System Security Threats • Cybercrime/ Cyber Attack: This is a major threat against information security and integrity. It includes attacks by hackers, virus attacks, hoax virus warnings and premeditated internal attacks. Any of these attacks can have a devastating effect on Health Carousel’s normal business operations. • Loss of Data: Loss of data can be particularly damaging wherein recovery procedures could result in retrieval and re-inputting of data. The smooth operation of Health Carousel would be adversely impacted by the loss of ready access to reliable data. • Disclosure of sensitive information: This can be quite damaging to Health Carousel as it can lead to embarrassment, damage to Health Carousel’s professional reputation, financial loss and potential litigation.Environmental Hazards • Fire: Whether accidental or deliberate, its impact on Health Carousel can be very damaging depending on severity of the fire and the speed with which it can be brought under control. It has the potential to cause injury and death to workers, as well as damage to records and equipment. • Earthquake/Tornado: Though the potential for an earthquake or tornado is rare, the effect of earthquake/tornados on Health Carousel’s business operation depends on the severity of the earthquake/tornado. Severe earthquakes/tornados can cause bodily harm, destroy power and communication lines; disrupt gas, water and sewage services. Significant damage to structure can occur to the extent of total collapse of buildings, bridges and/or other elevated structures. Employees can be trapped in a collapsing building with the potential for injury or loss of life. • Ice/Snow Storms: Severe ice/snow storms can affect Health Carousel’s business operation negatively. These storms can cause power and communication lines damage, hazardous driving and walking conditions, power outages, and water disruptions. Active Shooter: In the event of an active shooter the following procedures will ensure the safety of employees and the continuity of business. If you notice characteristics of potentially violent behavior in an employee or co- worker, alert the HR Department of this potentially violent behavior. Active shooter situations are unpredictable and evolve quickly. Typically, the immediate deployment of law enforcement is required to stop the shoot and mitigate harm to victims. Because active shooter situations are often over within 10 to 15 minutes, before law enforcement arrives on the scene, individuals must be prepared both mentally and physically to deal with an active shooter situation. 18 OPERATIONS MANUAL | v13018

• Run: if there is an accessible escape path, attempt to evacuate the premises. Be sure to have an escape route, prevent others from entering an area with the shooter may be, keep your hand visible and call 911 when you are safe. • Hide: If evacuation is not possible, find a place to hide where the active shooter is less likely to find you. Your hiding place should be out of the active shooter’s view, provide protection if shots are fired in your direction, and not trap or restrict your options for movement. • Fight: This should only be used as a last resort and only if your life is in imminent danger. You should attempt to disrupt and/or incapacitate the active shooter. This can be done by acting aggressively as possible against him/her, throwing items and improvising weapons, yelling and committing to your actions.Backup StrategiesListed below are strategies and alternative practices for managing business at Health Carousel in the event ofan emergency.Recruitment and Credentialing • Health Carousel utilizes Microsoft Dynamics CRM (Merlin) for recruitment and applicant tracking. Microsoft Dynamics CRM is a web-based, password encrypted software program. Data is saved in real time and the system is backed-up on a daily basis. Microsoft Dynamics CRM has a 99.99% up time and has state of the art data centers to keep data safe, secure and available. • Employment documents and credentials are maintained in a secure document management system and Microsoft SharePoint. The files are saved into the document management system and saved to the shared drive on the server. Then the documents are saved within Microsoft SharePoint. • Credentials and documents can be faxed to Health Carousel using eFax specifically for documents. All faxes are archived to a company email address and accessible via password encrypted website. As eFax is web based – faxes can be accessed from an alternate location. • In the event of a critical situation, Microsoft Dynamics CRM can be accessed from an alternate location where power and Internet service is available.Administration (Business), Strategic Planning and Marketing • Master files of all business documents are saved on the server. • Health Carousel has thirty (30) servers that are backed up on a nightly basis. A copy of each is maintained offsite. • Passwords are placed on all critical information to avoid unauthorized access.General Accounting and Payroll • Health Carousel utilizes ADP for payroll which is a web-based, password encrypted program. Payroll information is entered directly into ADP. ADP is backed-up on a nightly basis. 19 OPERATIONS MANUAL | v13018

• Timesheets and documents can be faxed to Health Carousel using eFax specifically for documents. All faxes are archived to a company email address and accessible via password encrypted website. As eFax is web based – faxes can be accessed from an alternate location. • Payroll is processed on Mondays, but in the event of a critical situation, payroll could be processed on Tuesday or from a location where power and internet service is available.Phone and General Communication • The phone system is VOIP. There are automatic redundant internet connections. • Phones can be transferred to alternative locations or company cell phones. • Health Carousel utilizes eFax, a web based, password encrypted program. All faxes sent to Health Carousel can be accessed by logging in. • A hosted exchange server provides Health Carousel’s email. Email can be accessed through Outlook or through Office365, a web based interface from alternate location.Recovery StrategiesIn the event of emergency situations, the following procedure will be followed to enable continuity of serviceprovision.Telecommunication Services Breakdown • Telephones calls will be transferred to Health Carousel administrative staff cell phones. Phones can be transferred remotely, if necessary. • Office 365 is a part of our business subscription that allows access to our hosted exchange server for email, Skype for Business, SharePoint, and Offices applications such as Word, Excel, and PowerPoint. This can be accessed from any point of power and internet connection. • WatchGuard Mobile VPN is a password encrypted program that allows remote access to all Health Carousel applications and servers. • Clients and staff shall be informed immediately of the situation • Communication with clients and employees will be maintained via email as needed. • If necessary, Health Carousel’s employees will relocate to an area where power and internet service are available.Power OutageIn the event of a Power Outage, the following procedures will be implemented to assure the safety ofemployees and continuity of business. • Telephones calls will be transferred to Health Carousel administrative staff cell phones. • In the event of an extended power outage, discretion and good judgment will be used to determine if clients and employees should be notified of the emergency and assure them that Health Carousel will continue to provide services from an alternate location. 20 OPERATIONS MANUAL | v13018

• Depending on the predicted length of power outage, a decision will be made by Sr. Management as to whether or not employees will be asked to relocate to an area where power and internet services are available.Environmental HazardsIn case of emergencies such as fire, earthquake, flood, or any other hazards all employees must leave thebuilding through marked exits at either side of the building. The following procedures will ensure continuity ofbusiness. In the event of a severe disaster situation, involving client facilities, Health Carousel can immediatelycontact healthcare professionals using phones or email, to ascertain their safety and to assess additionalavailability for deployment to client facilities as needed.EarthquakeIn the event of an earthquake the following procedures will ensure the safety of employees and the continuityof business.Stay as safe as possible during an earthquake. Be aware that some earthquakes are actually foreshocks and alarger earthquake might occur. Minimize your movements to a few steps to a nearby safe place and stayindoors until the shaking has stopped and you are sure exiting is safe. • DROP to the ground; take COVER by getting under a sturdy table or other piece of furniture; and HOLD ON until the shaking stops. If there isn’t a table or desk near you, cover your face and head with your arms and crouch in an inside corner of the building. • Stay away from glass, windows, outside doors and walls, and anything that could fall, such as lighting fixtures or furniture • Use a doorway for shelter only if it is in close proximity to you and if you know it is a strongly supported, load bearing doorway. • Stay inside until shaking stops and it is safe to go outside. Research has shown that most injuries occur when people inside buildings attempt to move to a different location inside the building or try to leave. • Be aware that the electricity may go out or the sprinkler systems or fire alarms may turn on. • DO NOT use the elevators.Once the shaking has subsided, employees must leave the building through marked exits at either side ofbuilding. All employees should be accounted for. In the event of employee injury, emergency personnel shouldbe requested. Emergency manual with employee and client contact information should be retrieve andremoved from the building.FireIn the event of a fire the following procedures will ensure the safety of employees and the continuity ofbusiness.In the event of a fire, 21 OPERATIONS MANUAL | v13018

• All employees will evacuate the building through emergency exits. • Call 911. • All employees have been given an evacuation plan according to the Health Carousel location that they are assigned to. These evacuation plans are also posted throughout the offices.In the occurrence that the office becomes inoperable or inaccessible, • Telephones calls will be transferred to Health Carousel administrative staff cell phones. • At the earliest convenience, clients and employees should be notified of the emergency and assure them that Health Carousel will continue to provide services from an alternate location • Staff will work from an alternate locationLoss of DataIf there is a loss of data, the following procedures will ensure continuity of business. • Inform the IT Manager of loss of data • Follow the procedures as instructed to restore most recent back-upRecruitmentPurpose: Health Carousel strives to recruit and hire qualified and highly competent healthcare professional that will deliver safe, quality patient care.JC Standard: HSHR.1 The firms confirms that a person’s qualifications are consistent with his or herassignment(s)Recruiting healthcare professionals is one of the pillars of this company, and of the staffing industry in general.Without the continuous flow of new candidates our business will not grow.Recruiting is a responsibility shared by all of Health Carousel’s Recruiters. All forms of advertising and itsrelated content accurately represent the services offered and are to be approved by the Present of Healthcare, before being distributed to the public.In addition to Health Carousel’s websites: www.healthcarousel.com, www,passportusa.com,www.thstravel.com, www.nexttravelnursing.com, www.msotravelnursing.com , other websites used forrecruitment: www.americantherapyjobs.blogspot.com, www.indeed.com, www.activejobseeker.com,www.simplyhired.comHealth Carousel also has an international recruiting division, Passport USA, which recruits registered nurses,therapist, and laboratory professionals. Health Carousel maintains an affiliate recruiting office in Manila andCebu, Philippines.The client organization and the candidate may complete a telephone interview to discuss the responsibilitiesand requirements of the position, and the candidate’s experience, skills, and interests in order to determine 22 OPERATIONS MANUAL | v13018

whether there is a mutual fit for the prospective assignment. Upon completion of the interview, the client willdecide whether they will accept the candidate for assignment and the candidate decides whether the positionmeets their professional objectives. If both parties agree upon a fit and agree to financial terms, HealthCarousel makes a formal offer of employment to the candidate and confirms the assignment details amongparties, usually by way of Assignment Confirmation Letters.Professional Work Experience Requirements for HealthcarePurpose: To assure that Health Carousel’s healthcare professionals’ competence, qualifications and skills are consistent with job responsibilities.JC Standard: HSHR.2.1 The firm defines and documents the minimum clinical competence and qualificationconsistent with staff job responsibilities.Health Carousel’s highly skilled professional recruiters conduct a search and selection process that is uniquelytailored to the characteristics most important to our clients, from specific expertise to interpersonal skills. Allhealthcare professionals complete a rigorous screening and competency assessment process.Health Carousel requires extensive testing and interviewing during our application process. Each applicantmust show evidence of licenses, certifications, education and training. One year current experience in theirarea of expertise is a preferred and is often a minimum requirement by many of Health Carousel’s clients.Generally, US training Nursing Professionals and Allied Health Professionals that have direct patient careresponsibilities are required to have a minimum of one (1) year full time acute care experience, in the clinicalsetting for which the applicant is to be assigned to work. Specific client contracts may require HCPs to havegreater than one (1) year of experience, therefore the client contract will always take precedence when placingHCPs.However, the experience required for foreign trained Nursing and Allied Health Professionals that have directpatient care responsibilities, is based exclusively on client requirements. Recent clinical experience may not bea requirement for these clinical assignments, Clients review the HCPs profile and may conduct a telephoneinterview to assure they are a good fit for the position. Clients are required to provide adequate clinicalorientation to US standards of practice.In addition, Rehab Professionals’’ (PT/OT/SLP) experience requirement is based exclusively on clientrequirements, regardless of the nature of the assignment and regardless of the HCP’s country of educationand training. Client review the HCP’s profile and usually conduct a telephone interview to assure they are agood fit for the position.Health Carousel representative will review candidate’s resume/work experience to assure experiencerequirement is met before proceeding to skills assessment step in the hiring process. 23 OPERATIONS MANUAL | v13018

Upon completion of application, Health Carousel representative will verify HCP’s employment history, usingthe Clinical Reference Check Authorization and Verification Form or a Clinical Reference Evaluation Form.Employment verification may be completed via internet or telephone.Employment Verification Standard: Employment Verification will be completed for the last place ofemployment for foreign trained candidates and the last two (2) places of employment for domestic candidatesor to verify experience required for the position.Professional License / Certification VerificationPurpose: Primary source verification permits Health Carousel to determine with accuracy the current status of a HCP’s license, certification or registration. Copies of the license, certification or registration submitted by HCP my not be reliable and do not allow Health Carousel to determine what might have occurred since issuance.Personnel: Applies to all Healthcare Professionals (HCP) classifications that require state licensure and state or national certification.JC Standard: HSHR.1.1 The firm uses primary source verification to confirm and document that requiredlicenses, certifications, or registration are current at the time of hire, reactivation, or expiration according to lawregulation, and the firm’s policy or customer requirements.HSHR.1.2 Uses primary source verification and documents the voluntary or involuntary relinquishment,sanctions or limitations of any licensure or registration at the time of hire, reactivation, or expiration accordingto law, regulation, and the firm’s policy or customer requirements.Health Carousel will place HCPs who have obtained the appropriate license/certification for their discipline.Health Carousel will not employ professionals whose license/certification has expired, has current disciplinaryaction or is under investigation.License/Certification Verification Standard: All licenses or certifications listed on HCP’s employmentapplication and/or physically presented at time of application will be verified. This includes all known active,inactive or expired licenses. Licenses will be verified a time of hire, new assignment, and at time of licenserenewal.HCP may provide copy/copies of his/her licenses and certification when distributed by licensing or certifyingorganization. In this “green environment”, some states are no longer sending HCP’s a hard copy of theirlicenses.Nurse license verification can be completed via NURSYS website (www.nursys.com/) or appropriateregulatory agency website.License verification should identify whether the license has multi-state privileges. See Enhanced NurseLicensure Compact below. 24 OPERATIONS MANUAL | v13018

The online verification for each license will be save electronically to a pre-designated company file. The onlineverification documentation will be retained in the employee personnel file.If the professional license verification indicates current or past disciplinary action against the license, HealthCarousel representative will forward the license verification to the Nursing Department for review andrecommendation to Chief Nursing Officer. The Chief Nursing Officer will make the final determinationregardingEnhanced Nurse Licensure Compact (eNLC)The eNLC license works very similar to the driver’s license model. A person holding a driver’s license in his/herhome state is permitted to drive in other states without applying for a driver’s license in every state he/shedrives through. Though requirements for a driver’s license are similar across states, each state may determineand vary its own licensure requirements. The eNLC is similar in that it allows a nurse licensed in one “home”compact state to practice in a party compact state without seeking an additional nursing license. Anothersimilarity to the driver’s license model is that the eNLC is implements through laws passed by the legislatureof each participating state. The essence of any state Compact law must permit the nursing board of that stateto recognize individuals licensed as nurses from other participating compact states.In order to enjoy the multistate licensure privilege, the Compact requires that the nurse by licensed in the statein which he/she permanently resides. This license is known as a home state license. The nurse must meet thelicensure criteria of his/her home state in order to obtain and retain multistate licensure recognition privilegeson his/her state nursing license.Other states belonging to the eNLC allows a nurse to work in their state without obtaining a new licensebecause of the uniform licensure requirements. All eNLC states require the following: meets requirements inthe home state, graduated from a board-approved education program, passed English proficiencyexamination, passed NCLEX, eligible for or holds an active, unencumbered license, submitted to state andfederal fingerprint-based criminal background check, has no state or federal felony convictions, has nomisdemeanor convictions related to the practice of nursing, not currently participating in an alternativeprogram, and has a valid U.S. social security number.eNLC Member States• Arizona • New Hampshire• Arkansas • New Mexico• Colorado • North Carolina• Delaware • North Dakota• Florida • Oklahoma• Georgia • South Carolina• Idaho • South Dakota• Iowa • Tennessee• Kentucky • Texas• Maine • Utah• Maryland • Virginia 25 OPERATIONS MANUAL | v13018

• Mississippi • West Virginia• Missouri • Wisconsin• Montana • Wyoming• Nebraska*Rhode Island was a part of the original NLC. They have a 6-month grace period (7/18/18) to enact eNLC or they will nolonger be considered part of the multistate licensure recognition.Professional Skill Reference CheckPurpose: Health Carousel supplies staff that provides safe, quality patient care. To enhance the quality of patient care, Health Carousel must be able to assess the qualification and competency of its staff.Personnel: Applies to all Healthcare Professionals (HCP)JC Standard: HSHR.2 As part of the hiring process, the firm determines that a person’s qualifications andcompetencies are consistent with his or her job responsibilities.Domestic Candidates: Applicant will be required to provide at least two (2) professional references. ForeignTrained Candidates: Applicant will be required to provide at least one (1) professional reference. Referencemust be employers or professional co-workers of recent history, if not current employer.If at least two recent professional references cannot be provided, an instructor who has had student/instructorrelationship with the applicant may be used.Professional co-worker references must be from a colleague functioning in an equal or higher clinical orsupervisory capacity.Personal references are not acceptable.Qualitative references, which include evaluation of skills, are preferred. However, quantitative references,which only verifies position and employment dates, are acceptable in the absence of qualitative references.For staffing agency employment, it is important to verify type and frequency of assignment if possible, toassure minimum experience requirement is met. Travel assignments should be verified with the healthcarefacility whenever possible.Skills references may be conducted via telephone. The Clinical Reference Check Authorization & VerificationForm must include the name and title of the person providing reference information and must be signed anddated by the Health Carousel representative obtaining the reference.Professional References will be maintained in the employee personnel file and into the DocumentManagement System. 26 OPERATIONS MANUAL | v13018

Employee Health Clearance PolicyPurpose: To establish a baseline for minimum employee health standards for Healthcare Professionals. To ensure all HCPs meet minimum requirements that comply with OSHA Standard 29CRF 1910.134 for Respiratory Protection, OSHA rule 29 CRF 1919.1030 Bloodborne Pathogens and Centers for Disease Control recommendations.Personnel: Applies to all Healthcare Professionals (HCP)JC Standard: HSHR.1.3 For clinical staff, the firm verifies and documents compliance with applicable healthscreening and immunization requirements established by law, regulation, the firm’s policy or customerrequirements.All HCPs, at time of hire and during their employment with Health Carousel must adhere to the HealthClearance Policy.Health Clearance is required before a HCP is place on an assignment.Health StatusAll HCPs, at time of hire, will provide a Physician Statement that he/she is in good physical and mental health, freeof communicable disease, has no physical limitations and is able to function in his/her professional discipline andspecialty on a full-time basis. A Physician Statement or a physical within 12 months of hire date will be accepted. Aphysician, nurse practitioner or physician assistant may complete the Physician Statement. Equivalentdocumentation provided by the health practitioner will be accepted.A Physician Statement is required at the time of hire and as required by client contract for all HCPs with directpatient care.Client contract requirements regarding HCPs with no direct patient contact, will take precedent. If the clientrequires an annual Physician Statement, the HCP will need to comply with this requirement.Tuberculosis ScreeningUpon hire, all HCPs must provide evidence that they are free from active tuberculosis, prior to their first assignmentand at lease annually thereafter.Two-Step TB Testing is preferred on all new HCPs who have not had a documents TB test during the previoustwelve (12) months.• TB Step 1 o Administer first Mantoux tuberculin skin test (TST) following proper protocol. o Review Result • Positive: No second TST needed, evaluated for TB disease • Negative: a second TST is needed. Retest in 1-3 weeks after first TST results is read.• TB Step 2 o Administer second TST 27 OPERATIONS MANUAL | v13018

o Review Results ▪ Positive: evaluated for TB disease ▪ Negative: consider person not infected.TB Blood Test: Interferon-Gamma Release Assays (IGRA) can be used in place of the 2 Step TB test. The twoIGRA’s that have been approved for use by the FDA are QuantiFERON TB Gold In-Tube Test and T-Spot TBTest. This type of testing is not affected by the BCG vaccination.History of Positive TB Test: HCPs must provide the proof of positive history, a negative baseline chest x-rayand will be required to complete the Annual TB Questionnaire.If the HCPs Annual TB Questionnaire indicated presence of symptoms, the HCP will be required to have amedical evaluation and clearance before further work will be scheduled. A copy of the medical evaluation willbe required for the HCP confidential health file.Routine, repeat chest x-rays are required every five (5) years. Client contracts may require repeat chest x-rays atspecific intervals and will be required for the HCP to be placed on assignment at the facility.The Mantoux tuberculin skin test (TST) results are to be read between 48 and 72 hours after injection. If thereading is delayed past 72 hours, the TST must be re-administered. Employees self-reading and reporting of resultsis not acceptable. The results must be documented in terms of measurements (in millimeters) of induration, notredness or erythema.Tuberculin Skin Testing Information from the Centers for Disease Control and Prevention (CDC)What is it?The Mantoux tuberculin skin test (TB Test) is the standard method of determining whether a person is infected withMycobacterium tuberculosis. Reliable administration and reading of the TB Test requires standardization ofprocedures, training, supervision, and practice.How is the TB Test Administered?The TB Test is performed by injecting 0.1 ml of tuberculin purified protein derivative (PPD) into the inner surface ofthe forearm. The injection should be made with a tuberculin syringe, with the needle bevel facing upward. The TBTest is an intradermal injection. When placed correctly, the injection should produce a pale elevation of the skin (awheal) 6 to 10 mm in diameter.How is the TB Test Read?The skin test reaction should be read between 48 and 72 hours after administration. A patient who does not returnwithin 72 hours will need to be rescheduled for another skin test.The reaction should be measured in millimeters of the induration (palpable, raised, hardened area or swelling). Thereader should not measure erythema (redness). The diameter of the indurated area should be measured across theforearm (perpendicular to the long axis).How Are TB Test Reactions Interpreted? 28 OPERATIONS MANUAL | v13018

Skin test interpretation depends on two factors:• Measurement in millimeters of the induration• Person’s risk of being infected with TB and of progression to disease if infectedClassification of the Tuberculin Skin Test ReactionAn induration of 5 or more An induration of 10 or more An induration of 15 or moremillimeters is considered positive in millimeters is considered positive in millimeters is considered positive in • HIV-infected persons any person, including persons with • A recent contact of a person • Recent immigrants (< 5 no known risk factors for TB. years) from high- However, targeted skin testing with TB disease prevalence countries programs should only be conducted • Persons with fibrotic changes among high-risk groups. • Injection drug users on chest radiograph consistent • Residents and employees with prior TB • Patients with organ of high-risk congregate transplants settings • Persons who are • Mycobacteriology immunosuppressed for other laboratory personnel reasons (e.g., taking the • Persons with clinical equivalent of >15 mg/day of conditions that place them prednisone for 1 month or at high risk longer, taking TNF-a • Children < 4 years of age antagonists) • Infants, children, and adolescents exposed to adults in high-risk categoriesIGRA Testing Information from the Centers for Disease Control and Prevention (CDC)How do they work?IGRAs measure a person’s immune reactivity to M. tuberculosis. White blood cells from most persons that havebeen infected with M. tuberculosis will release interferon-gamma (IFN-g) when mixed with antigens (substancesthat can produce an immune response) derived from M. tuberculosis.How do you interpret IGRA test results?IGRA interpretations are based on the amount of IFN-g that is released or on the number of cells that release IFN-g.Both the standard qualitative test interpretation (positive, negative, or indeterminate) and the quantitative assaymeasurements (Nil, TB, and Mitogen concentrations or spot counts) should be reported.As with the tuberculin skin tests (TSTs), IGRAs should be used as an aid in diagnosing infection with M.tuberculosis. A positive test result suggests that M. tuberculosis infection is likely; a negative result suggests thatinfection is unlikely. An indeterminate result indicates an uncertain likelihood of M. tuberculosis infection. Aborderline test result (T-Spot only) also indicates an uncertain likelihood of M. tuberculosis infection.A diagnosis of LTBI requires that TB disease be excluded by medical evaluation. This should include checking forsigns and symptoms suggestive of TB disease, a chest radiograph, and, when indicated, examination of sputum or 29 OPERATIONS MANUAL | v13018

other clinical samples for the presence of M. tuberculosis. Decisions about a diagnosis of M. tuberculosis infectionshould also include epidemiological and historical information.Recommendations on when to use IGRA tests • IGRAs can be used in place of (but not in addition to) TST in all situations in which CDC recommends TST as an aid in diagnosing M. tuberculosis infection, with preferences and special considerations noted below. This includes contact investigations, testing during pregnancy, and screening of health care workers and others undergoing serial evaluation for M. tuberculosis infection. Despite the indication of a preference, use of the alternative test (FDA-approved IGRA or TST) is acceptable medical and public health practice. Caution in interpretation should be used when testing certain populations because of limited data on the use of IGRAs (see Updated Guidelines for Using Interferon Gamma Release Assays to Detect Mycobacterium Tuberculosis Infection, United States). • Populations in which IGRAs are preferred for testing: o Persons who have received BCG (either as a vaccine or for cancer therapy); and o Persons from groups that historically have poor rates of return for TST reading. • TST is preferred over IGRAs for testing children less than 5 years of age. • As with TST, IGRAs generally should not be used for testing persons who have a low risk of infection and a low risk of disease due to M. tuberculosis. • Each institution and TB control program should evaluate the availability and benefits of IGRAs in prioritizing their use. • Routine testing with both TST and IGRA is not recommended. However, results from both tests might be useful in the following situations: o When the initial test is negative and: ▪ The risk for infection, the risk for progression to disease, and the risk for a poor outcome are high (e.g., HIV infected persons or children under 5 years of age who are exposed to a person with infectious TB). ▪ There is clinical suspicion for TB disease (e.g., signs, symptoms, and/or radiographic evidence suggestive of TB disease) and confirmation of M. tuberculosis infection is desired. ▪ Taking a positive result from a second test as evidence of infection increases detection sensitivity. o When the initial test is positive and: ▪ Additional evidence of infection is required to encourage acceptance and adherence (e.g., foreign- born healthcare workers who believe their positive TST is due to BCG). A positive IGRA might prompt greater acceptance of treatment for LTBI as compared with a positive TST alone. ▪ The person has a low risk of both infection and progression from infection to TB disease. Requiring a positive result from the second test as evidence of infection increases the likelihood that the test reflects infection. An alternative is to assume, without additional testing, that the initial result is a false positive or that the risk for disease does not warrant additional evaluation or treatment, regardless of test results. ▪ In addition, repeating an IGRA or performing a TST might be useful when the initial IGRA result is indeterminate, borderline, or invalid and a reason for testing persists. 30 OPERATIONS MANUAL | v13018

Multiple negative results from any combination of these tests cannot exclude M. tuberculosis infection. Steps shouldbe taken to minimize unnecessary and misleading testing of persons at low risk.Selection of the most suitable test or combination of tests for detection of M. tuberculosis infection should be basedon the reasons and the context for testing, test availability, and overall cost of testing.Hepatitis BIn compliance with the Occupational Safety and Health Administration (OHSA) rule (29 CFR 1910.1030 Bloodborne Pathogens) and Centers for Disease Control (CDC) recommendations, all HCPs with occupationalexposure, (Categories I and II, Job Classifications) obtain the Hepatitis B Vaccination. • Category I – Job classification where exposure is anticipated in normal routine of job. • Category II – Job classification where only occasional exposure is anticipated in normal routine of job. • Category III – Job classification where no exposure is anticipated in the normal routine of job however may occur if an emergency is encountered.The Hepatitis B Vaccine is offered free to all HCPs who are at high risk for exposure to blood or body fluids ofpatients (Category I and II Job Classifications).Upon hire, the HCP will be evaluated as to vaccination status and offered the vaccine unless the HCP has: • Previously received the complete Hepatitis vaccination series (3 immunizations) • Antibody testing has revealed that the HCP is immune (titer) • The vaccine is contraindicated for medical reasonsIf the employee accepts the vaccination, it will be initiated within ten (10) working days of initial assignment.If the employee refuses the vaccine, the employee will sign a Hepatitis Declination Form. If at a later date,while still employed, the HCP decides to accept the vaccination, the vaccine will be made available at thattime.Currently the Center for Disease Control (CDC) does not recommend a routine booster dose of Hepatitis Bvaccine.Hep B Titer results: • Hep B titer: In order to show positive immunity, the Hep B Surface Antibody (HBsAb) must reach a level of greater than 12 mIU/mL and for Hep B Surface Antigen (HSbAg) must reach a level of equal to or greater than 10.0 mIU/mL. • According to the Center of Disease Control (CDC), Hepatitis B results should be interrupted as follows: 31 OPERATIONS MANUAL | v13018

VaricellaVaricella, more commonly known as Chickenpox, is a highly contagious illness caused by primaryinfection with varicella zoster virus (VZV) Chickenpox is spread easily through coughs or sneezes of illindividuals, or through direct contact with secretions from the rash. Following primary infection there isusually lifelong protective immunity from further episodes of chickenpox.All HCPs must provide evidence of immunity to varicella as required by client contract. Evidence ofimmunity includes any of the following: • Documentation of one dose of varicella vaccine; • Blood tests (titer – see below) showing immunity to varicella or laboratory confirmation of prior disease; or • Receipt from a healthcare provider of a) a diagnosis of chickenpox or herpes zoster (shingles); or b) verification of a history of chickenpox or herpes zoster (shingles).Varicella Titer: In order to show positive immunity, the Varicella titer must reach a level of 1.10. If it's onor below .90, then there is no immunity and the HCP should be vaccinated. If the titer level is between .91- 1.09, there is some immunity, but the HCP should have a booster of Varicella vaccine.Measles, Mumps, Rubella (MMR) 32 OPERATIONS MANUAL | v13018

All HCPs who have direct patient contact should have documented immunity to Measles, Mumps andRubella.Measles (Rubeola) is an infection of the respiratory system caused by a virus, specifically a paramyxovirusof the genus Morbillivirus. Measles is spread through respiration (contact with fluids from an infectedperson's nose and mouth, either directly or through aerosol transmission), and is highly contagious—90%of people without immunity coming in contact with an infected person will catch it. The infection has anaverage incubation period of 14 days (range 6–19 days) and infectivity lasts from 2–4 days prior, until 2–5 days following the onset of the rash (i.e. 4–9 days infectivity in total).All HCPs must provide evidence of immunity to Rubella, when required by client contract. Evidence ofimmunity includes any of the following: • Documentation of one dose of MMR or Measles vaccine on or after first birthday; • Blood tests (titer – see below) showing immunity to Rubella or laboratory confirmation of prior disease; orMeasles Titer: In order to show positive immunity, the Rubeola titer must reach a level of 1.10. If it's .90,then there is no immunity and the HCP should be vaccinated. If the titer level is between .91 - 1.09, thereis some immunity, but the HCP should have a booster of Measles vaccine.Mumps is a viral disease caused by the mumps virus. Mumps is a contagious disease that is spread fromperson-to-person through contact with respiratory secretions such as saliva from an infected person.When an infected person coughs or sneezes, the droplets aerosolize and can enter the eyes, nose, ormouth of another person. Sharing food, sharing drinks, and kissing can also spread mumps. The virus canalso survive on surfaces and then be spread after contact in a similar manner.All HCPs must provide evidence of immunity to Mumps, when required by client contract. Evidence ofimmunity includes any of the following: • Documentation of Mumps vaccine on or after the first birthday • Blood tests (titer – see below) showing immunity to Mumps or laboratory confirmation of prior disease; or • Receipt from a healthcare provider of a) a diagnosis of Mumps; or b) verification of a history of Mumps.Mumps Titer: In order to show positive immunity, the Mumps titer must reach a level of 1.10. If it's .90,then there is no immunity and the HCP should be vaccinated. If the titer level is between .91 - 1.09, thereis some immunity, but the HCP should have a booster of Mumps vaccine.Rubella, commonly known as German measles, is a disease caused by the rubella virus. The virus istransmitted by the respiratory route and replicates in the nasopharynx and lymph nodes. The virus isfound in the blood 5 to 7 days after infection and spreads throughout the body. The virus has teratogenicproperties and is capable of crossing the placenta and infecting the fetus where it stops cells fromdeveloping or destroys them. 33 OPERATIONS MANUAL | v13018

All HCPs must provide evidence of immunity to Rubella, when required by client contract. Evidence ofimmunity includes any of the following: • Documentation of one dose of MMR or Rubella vaccine on or after first birthday; • Blood tests (titer – see below) showing immunity to Rubella or laboratory confirmation of prior disease; orRubella Titer: In order to show positive immunity, the Rubella titer must reach a level of 1.10. If it's on orbelow .90, then there is no immunity and the HCP should be vaccinated. If the titer level is between .91 -1.09, there is some immunity, but the HCP should have a booster of Rubella vaccine.Pregnancy is a contraindication to vaccination against measles, mumps and/or rubella. Vaccine shouldnot be given to pregnant women or those who may become pregnant within three (3) months ofvaccination.HCP’s employee health documents may be released to Client facilities for the purpose of ensuring thatcontractual requirements are met prior to placement, only upon written authorization of the HCP.Competency Assessment PolicyPurpose: To enhance the quality of patient care, Health Carousel assesses the qualifications and competencies of its staff and adequately matches clinical staff with customer needs based on competencies.Personnel: Applies to all Healthcare Professionals (HCP)JC Standard: HSHR.4.1 The firm assesses and documents clinical staff competence based on the techniques,procedures, technology and skills needed to provide care, treatment and service to the population(s) served.HRHS.4.3 The firm assess and reassesses competencies on an ongoing basis, based on the customer’s reportof clinical staff performance.All HCPs will be required to complete a skills checklist specific to their occupation and clinical specialty prior tooffer of employment with Health Carousel.All HCPs must successfully pass a competency assessment specific to their occupation, clinical specialty andclinical setting prior to commencement of employment with Health CarouselCompetency exams are administered by Prophecy Clinical Assessments, Nurse Competency, or HealthStream.Upon offer of assignment, a skills competency assessment will be administered. Upon completion by the HCP,the skills assessment will be maintained in the personnel file and uploaded into the Document ManagementSystem.If the applicant fails the exam, a re-take will be allowed. The applicant can review the questions that wereanswered incorrectly prior to re-take. There is also a course content available for review. If the applicant fails 34 OPERATIONS MANUAL | v13018

the 2nd exam, they will be referred to the Nursing Department. The Nurse Manager assign with counsel andremediate with the HCP. the applicant fails to achieve a passing score after they have completed theremediation process, the applicant will not be eligible to work for Health Carousel. The applicant may re-applyand re-test after 6 months of additional work experience.For Foreign HCPs, being placed on long term assignments, that fail the competency exam, the exam resultsand the exam content outline will be shared with client facility to assist the client to customize orientation toaddress their learning needs. The Foreign HCP will then be re-tested after working 1 year in U.S. facility.Skills checklist and competency exams are required to be re-administrated and updated on an annual basis.Expiration dates will be tracked and monitored for timely completion, but prior to expiration.If an employee requests or being floated in a new clinical setting, verification of required experience andappropriate skills checklist and competency exam will be required.Background Check PolicyPurpose: To assure the healthcare professionals placed by Health Carousel have a clear criminal background.Personnel: Applies to all Healthcare Professionals (HCP)JC Standard: HSHR.1.4 The firm verifies information on criminal background, according to law, regulation, andthe firm’s policy and customer requirements.Health Carousel completes criminal background checks using various NAPBS accredited agencies, includingUniversal Background, FS Solutions, and other providers as required by Clients. The background checkincludes criminal record check including felonies and misdemeanors, national criminal NCIB, SS# verificationand trace, OIG, EPLS, & sexual offender, based on 7 years of state/county residence. Health Carousel will alsoprovide specific record check as required by state or district.The following criminal convictions will disqualify an applicant from employment with Health Carousel: • Convictions that have the potential to negatively impact the delivery of safe patient care including assault/battery, abuse/neglect, theft/robbery, crimes involving a child, crimes involving weapons and sex crimes. • Failure to disclose convictions on Health Carousel application.The following criminal convictions may disqualify an applicant from employment with Health Carousel: • Multiple DUIs within last 5 years. • All other felony and misdemeanor convictions will be reviewed individually. Frequency, recency, and nature of convictions will be considered when making an eligibility decision. 35 OPERATIONS MANUAL | v13018

For candidates that otherwise may be disqualifies by Health Carousel’s standard or the client’s standards asdefined in their contract. Health Carousel may at its discretion present said candidates to the client withdisclosure of any credentialing issues. The client will then have the opportunity to accept the candidate on anexception basis. If the client decides to accept the candidate, confirmation must be received in writing thatthey understand the credentialing issue(s) and are willing to accept the candidate as presented.Health Carousel utilizes an escalation process to review criminal convictions to determine if an applicant iseligible for hire. The Credentialing Manager reviews the criminal background results with the listed convictionand submits to the Quality Review Committee. The Quality Review Committee will make the final eligibilitydecision.Drug Free WorkplacePurpose: It is the purpose of Health Carousel to help provide a safe and drug-free work environment for our clients and our employees. With this goal in mind and because of the serious drug abuse problem in today’s workplace, the policy applies to all existing and future employees of Health Carousel.JC Standard: HSHR.1.3 The firm verifies compliance with applicable health screening and immunizationrequirements established by law, regulation, the firm’s policy or customer requirements.Health Carousel is committed to providing a drug-free, healthful and safe workplace by following federalguidelines. To promote this goal, HCP are required to report to work in appropriate mental and physicalcondition to perform their jobs in a satisfactory manner. Health Carousel retains the right to test any currentHCP at any time in response to any reasonable suspicion on the part of management.While on Health Carousel’s premises and while conducting business-related activities off Health Carouselpremises, no HCP may use, possess, distribute, sell, or be under the influence of alcohol or illegal drugs. Thelegal use of prescription drugs is permitted on the job only if it does not impair a HCP ability to perform theessential functions of the job effectively and in a safe manner that does not endanger other individuals in theworkplace.Violations of this policy may lead to disciplinary action, up to an including immediate termination ofemployment and/or required participation in a substance abuse rehabilitation or treatment program. Suchviolation may also have legal consequences. HCP with drug or alcohol problems that have not resulted in in,and are not the immediate subject of, disciplinary action may request approval to take unpaid time off toparticipate in a rehabilitation program. Leave may be granted if the HCP agrees to abstain from the use of theproblem substance, abides by all Health Carousel policies, rules and prohibitions related to conduct in theworkplace, and, if granting the leave, will not cause any undue hardship.Health Carousel requires all prospective and/or current Contract Professionals to submit to a 10-paneldrug screen in the following circumstances (a) at initial hire; (b) rehire after a break of 90 days or more; (c)according to client requirements for new assignments; and (d) after work-related accident or injury. 36 OPERATIONS MANUAL | v13018

Additionally, a drug screen may be required in the following circumstances; (a) randomly throughoutemployment; (b) reasonable suspicion of drug/alcohol related impairment; (c) specific request of client. Anappropriate sample as determined by Health Carousel’s affiliated organizations and/or its client in accordancewith the requirements of Health Carousel policies, and to have such samples tested for evidence of drugand/or alcohol abuse. If the creatinine, specific gravity, nitrates, temperature or other parameter typically usedto determine if a sample is a representative of normal is outside that range, the employee may be required toreturn to the collection point for a witnessed collection. The results must be negative for an individual tobecome employed as a Contract Professional. Health Carousel maintains a record of the results of the drugtest.Health Carousel reserves the right to request drug tests at any other time, including but not limited to, random,post-accident, scheduled and for-cause testing. Employee may not begin/continue an assignment with anyHealth Carousel affiliated organization unless the test results are negative for illegal drugs and/or alcoholwhen such test is required.Contract Professional may also be required to submit to a drug/alcohol screen at the facility to which she/hehas been assigned. Further, most policies that allow them to randomly drug screen any personnel workingwith its clients/patients.Results of the test may be disclosed to clients of Health Carousel’s affiliated organization to whom theContract Professional may be assigned to do business with. Refusal to take a drug screen test will result intermination and pay will be reduced to minimum wage. Note: State laws require that all positive drug tests bereported to the relevant state licensing/certification board.Employees subject to federal testing are prohibited from use of any Schedule I medication including marijuanaregardless if they reside and/or visit a state when recreational marijuana is permitted.Notice of Results: Once a drug test results report has been received from the testing lab, Health Carousel willinform the Contract Professional by telephone of the negative results or if necessary, instruct the ContractProfessional that they have tested positive in a confirmatory retest of the original sample. In this case, if theretest does not confirm the original results, no adverse personal action may be taken against the professionalbased on the initial testing.Withdrawal of Job Offer: If an applicant or Contract Professional has received a job offer made contingentupon the applicant or Contract Professional passing drug and alcohol testing and has elected to pay for asecond confirmatory retest which results in the same positive result, offers for placement may be withdrawn.Confidentiality of Results: All information acquired in the drug and alcohol testing process constitute privateand confidential information that will not be disclosed to any third-party individual, other ContractProfessional, government agency, or private organization with expressed written consent of the ContractProfessional or applicant tested.Suspicion of Impairment of Drug Diversion While on Assignment 37 OPERATIONS MANUAL | v13018

In the event of suspicion of impairment or diversion on drugs while on assignment, the following protocol willbe followed. • All Client facility protocol will be followed • Contract Professional will be suspended pending investigation • Chief Nursing Officer will be notified • Contract professional will be required to submit to a drug screen within 24 hours from time Client notified Health Carousel of concern. Failure to report for drug screen will result in immediate termination of Contract Professional. • Drug test company will be contacted to request a Health Care Professional Drug Screen. This drug screen is more extensive than the 10-panel drug screen and includes many drugs that Contract Professional would have access to in the hospital.In the event of a negative drug screen – Client will be notified and Client will make determination as towhether Contract Professional is allowed to continue assignment. Contract Professional will be required tosubmit to another drug screen prior to the start of next assignmentIn the event of a positive drug screen – Client facility will be notified and contract will be terminated. ContractProfessional will be terminated immediately and Nursing Department will notify the appropriate licensingboard/s.Basic Life Support (BLS) CertificationPurpose: To clearly define the Basic Life Support (BLS) requirements for Health CarouselPersonnel: Applies to all Healthcare Professionals (HCP)JC Standard: HSHR.2.2 The firm accurately represents clinical staff qualifications, clinical competency,licensure, registration and certification to the customer.All nurses involved in direct patient care responsibilities are required to show proof of successful completionof a Basic Life Support (BLS) Program. For all other Allied and Rehab Professionals, BLS is required per clientcontract.Health Carousel prefers the following BLS cards:• American Heart Association – Healthcare Provider (expiration – 2 years) http://www.onlineaha.org/index.cfm?fuseaction=info.bls• American Red Cross – Professional Rescuer (expiration – 1 year) http://www.redcross.org/portal/site/en/menuitem.53fabf6cc033f17a2b1ecfbf43181aa0/?vgnextoid= 42eebd7df52bb110VgnVCM10000089f0870aRCRD&currPage=200646a80f2bb110VgnVCM1000 0089f0870aRCRD• American Safety and Health Institute – CPR PRO (expiration – 2 years) http://www.ashinstitute.org 38 OPERATIONS MANUAL | v13018

• Military Training Network – (expiration – 2 years) http://www.usuhs.mil/mtn/bls.htm • Canadian Heart & Stroke http://www.heartandstroke.com/site/c.ikIQLcMWJtE/b.3382505/k.29EB/Contact_Us/apps/ka/ct/conta ctus.asp?c=ikIQLcMWJtE&b=3382505&en=ijJMI4NPLaJPL5MDJaJUIeNQLfLYJdOQLgKWJiN2F#infoAn online course combined with verification of hands-on demonstration through a certified instructor isacceptable. Health Carousel does not accept online certification for BLS that does not have an in-personreturn demonstration component.The Health Care Provider Course covers adult, infant and child CPR, foreign body airway obstruction, andAED. Courses such a “Community CPR” or “Heart saver” do not cover all requirements for HCPs, andtherefore are not accepted.HCPs providing care in specialty units may be required to show proof of additional life supports training.These may include Advanced Cardiac Life Support (ACLS), Pediatric Advanced Life Support (PALS) andNeonatal Resuscitation Program (NRP). Some examples include: • Critical Care/Intensive Care Unit (ICU)/Recovery Room – ACLS • Emergency Department – ACLS & PALS • Pediatrics & Pediatric Intensive Care (PICU) – PALS • Neonatal Intensive Care (NICU) – NRP • Labor & Delivery – ACLS & NRPHealth Carousel recognizes the importance of understanding the requirements of our client contracts – so allHCPs working at the client facility are in compliance with the contract requirements.Upon presentation of the BLS card by the HCP, make a copy of both the front and the back with signature ofthe card for the HCP’s employment file. Copy of the BLS will be maintained in the personnel file.If a HCP’s BLS card expires prior to renewal, the HCP will not be allowed to work until a current BLS card isobtained.Appropriate Placement and Reassignment PolicyPurpose: To assure that healthcare professionals are placed appropriately based on experience, skills & competencies.Personnel: Applies to all Healthcare Professionals (HCP)JC Standard: HSHR.2.2 The firm accurately represents clinical staff qualifications, clinical competency,licensure, registration and certification to the customer.HSHR.2.3 The firm places clinical staff only in areas of practice within the scope of their license, registration,certification, or clinical competence. 39 OPERATIONS MANUAL | v13018

Health Carousel will appropriately place HCPs in assignments that match their clinical experience, skills andcompetencies. The following will be considered for placement • Minimum clinical experience in the clinical setting to which the professional will be assigned. o 1 year experience for U.S. trained nurses and certain allied health professions o No minimum experience required for rehab professionals (PT / OT / SLP) o No minimum experience required for foreign-trained healthcare professionals including RN / MT / PT / OT / SLP. o Client specific clinical experience requirements may be higher than these standards, in which case, the higher standard is required • Successful completion of competency exam specific to the occupational specialty and/or clinical setting • Completion of a skills checklist specific to the clinical setting • Appropriate certifications as required by client (ACLS, PALS, NRP, etc.)The Client facility may conduct a pre-assignment interview with the candidate by telephone or other electronicmedia to discuss, experience, skills and to determine if they will be a good fit for the organization.If a HCP is asked to float to another department at the client facility, the department must be a likedepartment or unit and the float HCP must have demonstrated previous competency and have theappropriate certifications and credentials for that department/unit.Orientation PolicyPurpose: To assure all HCPs are oriented to Health Carousel’s policies and procedures and are provided an appropriate orientation at the client facility.JC Standard: HSHR.2.2 The firm accurately represents clinical staff qualifications, clinical competency,licensure, registration and certification to the customer.HSHR.1.5 The firm requires staff members to produce evidence of identity when reporting to assignment.Health Carousel will provide all new HCPs with an orientation to the company’s policies and procedures. EachHCP will receive a Contract Professional Handbook. All new HCPs are required to sign a ContractProfessional Handbook Acknowledgement Form.Health Carousel provides a comprehensive and thorough pre-employment orientation and training thatreflects current compliance and promotes safe healthcare delivery. The program provided through ProphecyTesting, Nurse Competency or HealthStream which includes, but is not limited to the following:• Body Mechanics • Infection Control/Bloodborne Pathogens• Disaster Preparedness • Age Specific• Environmental Safety • Cultural Diversity• Fire Safety • Ethics for Healthcare• Hazardous Chemicals • National Patient Safety Goals• HIPAA • Pain Management 40 OPERATIONS MANUAL | v13018

• Patient Rights • Patient Restraints• Abuse • Sexual Harassment• Advanced Care Planning • Workplace Violence• Domestic ViolenceHealthcare facilities require some form of orientation. The amount of time required by each facility varies.Some facilities require computer training classes and orientation prior to the first shift worked. A HealthCarousel Supervisor or Recruiter will explain required orientation to the HCP prior to start of assignment.When reporting to the healthcare facility for the first time, it is essential that the HCP produce evidence ofidentity; a picture ID that verifies their identity. It is also important for HCPs to carry their professional licenseand other certifications with them. Some healthcare facilities will request to see the HCP’s original documentsand HCP will not be allowed to begin assignment without them.Continuing Education RequirementsPurpose: To assure that Health Carousel’s HCPs meet all educational requirements as required by OSHA and Joint CommissionJC Standard: HSHR.3 The firm provides orientation to clinical staff regarding initial training and orientation.HSHR.5.3 The firm documents ongoing educational activities of clinical staff.Health Carousel provides a comprehensive, mandatory educational training program at time of hire andannually thereafter.The following education programs are required:• Body Mechanics • Infection Control/Bloodborne Pathogens• Disaster Preparedness • Age Specific• Environmental Safety • Cultural Diversity• Fire Safety • Ethics for Healthcare• Hazardous Chemicals • National Patient Safety Goals• HIPAA • Pain Management• Patient Rights • Patient Restraints• Abuse • Sexual Harassment• Advanced Care Planning • Workplace Violence• Domestic ViolenceEducational programs will be offered through Prophecy Health Testing, Nurse Competency or HealthStream.Annual Mandatories are required for all clinical assignments.Documentation of completion of educational requirements will be maintained in the HCPs employment record.Expiration dates will be monitored to assure timely completion of annual requirements prior to expirations. 41 OPERATIONS MANUAL | v13018

Additional education programs may be required per Client contract and will be completed prior to the start ofthe assignment.Ongoing continuing education is the responsibility of Health Carouse’s employees to ensure that all clinicalstaff has a current knowledge and practice base. Health Carousel maintains information on available resourcesfor BLS, ACLS, PALS, etc.Health Carousel has made HealthStream available to all HCPs on assignment. HealthStream is a web-basedprogram that offers over 2,000 CEUs. HCPs will have complete access to courses that will assist withfurthering their education and help with their license renewals. Health Carousel also makes other programsavailable for continuing education.HCPs are requested to submit copies of continuing education certificates or CEUs to Health Carousel.Evidence of continuing education and annual required in-service education are part of the ongoingcompetency assessment program and will be maintained in the personnel file.Performance EvaluationPurpose: To access Healthcare Professionals’ ability to meet performance expectations as stated in his/her job description and according to client policies and procedures.JC Standard: HSHR.6 The firm evaluated the performance of clinical staff.HSHR.6.1 The firm conducts a performance evaluation of active clinical staff based on the firm’s jobdescriptions biennially.HSHR.6.2 The firm’s performance evaluation includes an assessment of clinical staff performance based onthe customer’s job descriptions and feedback.Health Carousel representatives are unable to physically observe the work performance of the HCPs onassignment; therefore, client feedback is necessary to appropriately assess the HCPs performance.Health Carousel will request client feedback for every ACTIVE HCP as follows:• Foreign Contract Professional on long-term contracts – Client feedback will be requested periodically, but at least after the initial 90 days and annually thereafter.• Domestic Contract Professional – Client feedback is requested periodically, but at least at the beginning of and at the end of the assignment.Health Carousel representative will review Performance Assessments received from clients. If PerformanceAssessment indicates a clinical performance issue, the Nursing Department will be contacted for follow-upwith the HCP.Performance Assessments will be maintained in the HCPs personnel file. 42 OPERATIONS MANUAL | v13018

A Health Carousel representative will complete an Annual Performance Evaluation on each HCP that hasworked greater than 1 year and then annually thereafter. The Annual Evaluation provides composite feedbackregarding both clinical and behavioral performance as observed and documented by the client as well as non-clinical performance indicators observed by Health Carousel.Annual Performance Evaluations will be communicated with the HCP via telephone or via e-mail, at thediscretion of Health Carousel' management team. Annual Evaluations are considered confidential and will bemaintained in the HCPs Personnel file.The HCP will be provided a copy of the Annual Evaluation for their records.Definition of Active EmployeePurpose: To determine the appropriate employment status of a healthcare professional and to establish a timeframe for when an inactive employee must repeat the hiring process.JC Standard:An ACTIVE Health Carousel HCP Employee is any HCP employee that is currently on assignment.Any employee, who fails to maintain compliance with all expiration dates of credentials, will be placed onInactive status temporally until compliance is achieved.Any healthcare employee that has had a break in employment greater than 12 months will be required torepeat the hiring process prior to being placed on an assignment. A criminal check and drug screen will berequired. All other credentials must be brought to current status prior to assignment.Health Carousel Internal Do Not Use PolicyPurpose: The following operating standards are meant to address the appropriate usage of Do Not Use (DNU) in the Health Carousel candidate database. Management reserves the right to use discretion in implementation of these standards and to modify these standards in the future.JC Standard:DNU is a classification that should be used only after careful consideration. Classifying a candidate as DNUmeans that no one in the company should recruit or place this candidate for any position. Below is a list ofoffenses that can merit changing a candidate’s status to DNU. Before changing a candidate to a DNU status,the CNO, Nursing Department, Sr. Director of Support Services, Credentialing Manager, or the QualityCommittee may review the related incident and elect to either change the status or not change the statusbased on the facts of the candidate’s case.• Failed background check: results matching items on the Ohio Revised Code of Disqualifiers for health care professionals and include any state or licensing board disqualifiers. 43 OPERATIONS MANUAL | v13018

• Failed drug screen: results will be confirmed by MRO. A candidate having been classified as DNU for having failed a drug test may be reclassified once (a) s/he has completed a rehab program, (b) met all requirements of their state licensing board, and (c) have successfully reentered the workforce at a health facility for at least a one year period. The candidate must then also successfully pass a drug screen prior to being eligible for employment. • License revoked: by any state or foreign board of licensure. Candidates may be eligible for reclassification from DNU once their license has been fully restored and the candidate has successfully reentered the workforce at a healthcare facility (not an agency) for a period of at least 1 year. • Disciplinary Action on License: Disciplinary action by a licensing board is different than license revocation. If a candidate is the subject of disciplinary action by a state licensing board, the candidate may be classified as DNU until the candidate has met all of the state licensing board requirements relating to their disciplinary action and the license is once again active without sanctions or restrictions. • Medical exam reasons: inability to perform physical requirements of the position may be the basis for DNU; however, the candidate may have the DNU classification removed once s/he has secured a medical exam that confirms the candidate is physically able to perform the physical requirements of the position. • Walking off an assignment: This is a very severe offense. Travelers are required to apprise Health Carousel of any conditions that would merit early termination of an assignment. • No call, no show: Each traveler is responsible for calling in for absences. No call, no show without adequate explanation may be grounds for DNU classification. Family members are not an acceptable substitute, unless there is a documented medical emergency. Similarly, leaving a voicemail is also not acceptable. • Other international reasons: candidates that violate visa laws or breach their contractual obligations to the firm may be classified as DNU. • Missing scheduled client interview: Chronically missing scheduled client interviews may be the basis for classifying a candidate as DNU. • Assignment cancellations: within 5 days of the start of an assignment, without cause is grounds for DNU. The traveler is responsible for calling and family members are not an acceptable substitute, unless there is a documented medical emergency. Leaving a voicemail is also not acceptable. • Other circumstances: If a recruiter or account manager identifies another reason for DNU that is not listed above, s/he should consult with the Credentialing Manager, who will request review of Chief Nursing Officer.Rude, offensive, or otherwise belligerent communications with Health Carousel is not a valid reason for DNU.It is not appropriate to us DNU for candidates that are unresponsive, or for those unable to speak, understandor communicate in English. Please refer these candidates to IELTS or TOEFL, whenever possible, to improveon their English language skills and place them in a KIT status.Changing Status to DNU 44 OPERATIONS MANUAL | v13018

Anyone wishing to change a professional’s status to DNU must go through the DNU Request Process. Thechange must be requested of the Credentialing Manager. If the underlying reason for change to DNU isclinical, the Nursing Department must approve the change. All DNUs will remain for a minimum of 6 months.After the 6-month period, the candidate will be reviewed once again to decide whether they will remain in aDNU status or be move to a probation status.Appeal process for DNUsCertain pre-conditions for a DNU in our database can change, or be appealed by the professional. In the eventthat one of the pre-conditions change, an evaluation by the Credentialing Manager and, if applicable, theNursing Department, can change the DNU for a particular professional. To request a review, the recruitermust notify the Credentialing Manager of the professional’s name and reason for review. All changes to DNUstatus must then be authorized by the Credentialing Manager and approved by the Sr. Director of SupportServices and Chief Nursing OfficerPerformance Measurement ProgramPurpose: The performance improvement program for Health Carousel is multifaceted program designed to objectively and systematically evaluate the performance of services provided to clients, pursue opportunities to improve service, identify trends that warrant evaluation, modify processes to improve customer service and resolve identified problems. This focus on the continuous improvement of performance and service to customers is in concert with the philosophy of the organization.JC Standard: CPR.5 The staffing firm submits performance measurements to The Joint Commission on aroutine basis.PM.1 The firm plans an organized comprehensive approach to performance improvement.PM.3 The firm collects performance improvement dataPM.4 The frim analyzes dataThe management staff of Health Carousel fosters approaches to facilitate continuous performanceimprovement through the following mechanisms:• Establishment of an organizational culture which supports utilization of the principles of quality/performance improvement.• Provision of direction for the setting of priorities and selection of key functions to assist the organization to improve customer service.Objectives of the Performance Improvement Program• To identify opportunities to improve the processes that effect the performance of services provided by the organization 45 OPERATIONS MANUAL | v13018

• To identify and resolve problems associated with the provision of services for the purpose of performance improvement and enhanced customer service. • To identify high volume, high risk/benefit or potentially problematic processes that have the greatest potential or most important impact on the performance of services provided • To assure stability of existing processes that are performed in a manner that meet standards • To identify patterns or trends that warrant further evaluation • To integrate information provided from clients that relate to services provided • To identify and resolve employee safety related issues.Plans for Performance Improvement • Health Carousel will use its human resources and internal information technology to collect, track and analyze data for the purpose of improving the clinical and customer service performance the organization on an ongoing basis. • The three performance measures to be assessed will be o Do Not Return Clinical - rate per 1000 hours worked o Do Not Return Professional - rate per 1000 hours worked o Personnel file compliance for clinical staffDO NOT RETURN - CLINICALImprovement noted as: Decrease in rateNumerator Statement: Occurrences of Do Not Returns attributed to Clinical EventsDenominator Statement: Total hours worked / 1000 hoursData collection Approach: Retrospective – reported on a monthly basisDate is reported a ratioDO NOT RETURN - PROFESSIONALImprovement noted as: a decrease in rateNumerator Statement: Occurrences of Do Not Returns attributed to Professional EventsDenominator Statement: Total hours worked / 1000 hoursData collection Approach: Retrospective – reported on a monthly basisDate is reported a ratioPERSONNEL FILE COMPLIANCEImprovement noted as: Increase in rateNumerator statement: Personnel files meeting the minimum data set requirements for all components of acomplete personnel file: 1. Job Appropriate Credentials a. Current license for employees licensed/registered by state boards 46 OPERATIONS MANUAL | v13018

b. Verification of certification program completion for employees not licensed by state boards (i.e. Certified Surgical Technologist)2. Evidence of Competency Assessment a. Verification of prior work experience in the profession assigned b. Clinical skills checklist appropriate to discipline and/or specialty at time of hire and annually c. OSHA and HIPAA compliance training at time of hire and annually d. Current CPR for those categories of employees required under state law to be certified in basic life support3. Health Status a. TB test annually or documentation that employee previously tested positive (i.e. CXR, physician note or physical exam)4. Background check a. Verification of previous employers b. Reference checks at time of hire c. Verification of a criminal background check at the time of hire and annuallyDenominator Statement: Total active clinical staffData Collection Approach: Retrospective – reported on a monthly basisMonthly Sample Size Based on Population Size• 1-9 Active Clinical Staff 100%• 10-49 Active Clinical Staff 10 personnel files• 50-99 Active Clinical Staff 20%• > 100 Active Clinical Staff 20 personnel filesPERFORMANCE IMPROVEMENT MEASUREMENTUpon collecting the data to be used for Health Carousel’s performance improvement project, Health Carouselwill analyze it to identify opportunities for improvement. It is the Director of Operations’ responsibility toreport performance measurement data to the Joint Commission on a monthly basis. As opportunities forimprovement are identified, action plans are created and communicated to the Health Carousel team.Information ManagementPurpose: It is important to have an information system to meet the information needs associated with providing clinical staff to customers. It is essential to have good principles of information management to provide authorized staff to easily access information, to preserve confidentiality and security and to maintain continuity of information. To provide all stakeholders with timely and accurate information to support their operations without comprising the privacy, confidentiality and/or security of information.Personnel: Applies to all Administrative Employees 47 OPERATIONS MANUAL | v13018

JC Standard: IM.1 Information Management processed meet internal and external information needs.IM.2 The firm maintains health information and personnel records for clinical staff.IM.3 The firm preserves the confidentiality and security of information about clinical staff and customers.IM.4 The firm has a process for maintaining continuity of informationHealth Carousel maintains an electronic personnel file for every employee. Employee information can be foundin Microsoft CRM Dynamics (Merlin), our recruitment and applicant tracking system and all requiredcredentials and documentation are found in the Document Management System/Microsoft SharePoint.Both current and archived documents are maintained in the files.Data Capture & Information Processing • U.S. Based applicants can apply online at any of the HCTN brand websites, www.thstravel.com, www.nexttravelnursing.com, and www.msotravelnursing.com • Internationally trained applicants can apply at www.passportusa.com • Employee information and data can be received via submission on Health Carousel’s website, email, fax, phone or mail. • All incoming employee data is to be captured as soon as possible, but within two business days (e.g. 48 hours) of receipt – i.e. information in into personnel file. • Professional licenses are to be verified (via Internet) prior to submission for an assignment. • Employment verifications and professional references may be obtained via phone, fax or internet and are to be completed prior to submission for an assignment. • All Client facility requests for information (be it staffing-related or administrative) are to be responded to as soon as possible. • Client facility requests for healthcare staff are to be processed as soon as request is received. • Generally, all required credentials and documentation will be submitted to the Client five (5) business days prior to start for the Contract Professional’s assignment. For “Quick Start” assignments (scheduled within 10 days of client and candidate confirmation of acceptance), all credentials and required documentation will be submitted to the Client no later than the start of the Contract Professional’s assignment. If this standard cannot be met for a specific employee assignment, the Client shall be notified as to which documentation is outstanding. Depending upon the document that is outstanding, the Client may choose to allow the professional to commence orientation pending receipt of the outstanding documentation. • Time sheets are processed on a weekly basis, for the production and issuance of payroll checks. Time sheets must be received by Monday at 12 noon EST. Information Retrieval • Access to employees’ protected health information is limited to office staff with a “need to know”, based on job responsibilities. 48 OPERATIONS MANUAL | v13018

• Health Carousel will periodically evaluate compliance with the guidelines for information access limitations and how the limitations affect the workplace. Recommendations on increasing or decreasing access rights will be made based on the impact of the access limitations on the productivity of staff.Information DisseminationInformation dissemination is an issue that demands careful handling. As much as Health Carousel wanted toshare information with all stakeholders on a timely basis to enhance their operations, it behooves HealthCarousel to ensure that information is not violated. Health Carousel utilizes the following procedures indisseminating information.• An authorization for Release of Information is obtained from all employees, authorizing Health Carousel to release any and all professional credentials, work verifications, criminal background check information and/or health information that have been acquired by Health Carousel, to clients facilities, for the purpose of assuring that all required credentials and regulatory documentation as required by contract are in place and current prior to and during the healthcare professional’s assignment.• All request for employment verification will be honored only if they are accompanied by an authorization signed by employee.• A cover sheet, which includes a statement of confidentiality, is to be used for all transmissions of information via fax.Retention of RecordsHealth Carousel strives to be a “paperless office” by housing as many documents electronically as possible,although we understand that it is nearly impossible to be completely paperless. Health Carousel’s recordsmust be stored electronically or in a safe, secure, and accessible manner.Personnel Records, including inactive employee records:Type of Record Retention PeriodBenefits record PermanentDisciplinary files 4 yearsEmployer Information (EEO-1) Reports PermanentEmployment agreements 10 years after terminationsEmployment applications 3 yearsPension plan and retirement records PermanentPerformance appraisals 4 yearsPayroll registers 7 yearsWorkers’ compensation records (including Duration of employment + 30 yearsinvolvement with blood and/or bodily fluidexposures)For additional information regarding retention of records, refer to the HCLLC Document Retention Policymaintained by our General Counsel and Legal Department. 49 OPERATIONS MANUAL | v13018


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