CAA Employee Handbook 01 · 2017. 9. 27. · Employee Handbook Introduction - 3 - Vision Statement...

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Employee Handbook September 2017

Transcript of CAA Employee Handbook 01 · 2017. 9. 27. · Employee Handbook Introduction - 3 - Vision Statement...

Page 1: CAA Employee Handbook 01 · 2017. 9. 27. · Employee Handbook Introduction - 3 - Vision Statement CAA is committed to being the premier provider of anesthesia, comprehensive perioperative,

Employee Handbook

September 2017

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Table of Contents

INTRODUCTION ................................................................................................................................... 1

Welcome to CAA........................................................................................................................................................................ 2

Mission Statement .................................................................................................................................................................... 2

Vision Statement ....................................................................................................................................................................... 3

At-Will Employment .................................................................................................................................................................. 3

EMPLOYMENT PRACTICES ................................................................................................................... 4

Americans with Disabilities Act (ADA) & Americans with Disabilities Act Amendments Act (ADAAA) ..................................... 5

Equal Employment Opportunity Policy ..................................................................................................................................... 5

Sexual Harassment .................................................................................................................................................................... 6

Other Unlawful Harassment ...................................................................................................................................................... 8

COMPENSATION & PAY PRACTICES ................................................................................................... 10

Employment Classification ...................................................................................................................................................... 11

Call Classification ..................................................................................................................................................................... 11

Change in Status ...................................................................................................................................................................... 12

Garnishments .......................................................................................................................................................................... 12

Pay Practices ............................................................................................................................................................................ 12

Pay Periods and Paydays .................................................................................................................................................... 12

Reporting Payroll Errors ...................................................................................................................................................... 12

Payroll Deductions .............................................................................................................................................................. 12

CRNA Compensation and Call Responsibilities.................................................................................................................... 14

Resignation .............................................................................................................................................................................. 14

Salary & Wage Administration ................................................................................................................................................ 15

Timekeeping ............................................................................................................................................................................ 15

EMPLOYEE BENEFITS ......................................................................................................................... 16

Benefits Overview ................................................................................................................................................................... 17

Administrative Leave of Absence ............................................................................................................................................ 17

Bereavement Leave ................................................................................................................................................................. 17

COBRA ..................................................................................................................................................................................... 18

Direct Deposit .......................................................................................................................................................................... 18

Disability Insurance ................................................................................................................................................................. 19

Domestic Partnership Policy .................................................................................................................................................... 19

Definitions ........................................................................................................................................................................... 19

Eligibility ............................................................................................................................................................................. 20

Termination of Domestic Partnership ................................................................................................................................. 20

Cost of Coverage & Taxability ............................................................................................................................................. 20

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Employee Assistance Program ................................................................................................................................................ 20

Employee Military Leave ......................................................................................................................................................... 21

Compensation and Benefits While on Military Leave ......................................................................................................... 21

Family and Medical Leave Act (FMLA) ..................................................................................................................................... 21

Paid and Unpaid Leave ....................................................................................................................................................... 22

Intermittent or Reduced-Schedule Leave ............................................................................................................................ 22

Notice of Need for Leave..................................................................................................................................................... 23

Medical Certification ........................................................................................................................................................... 23

Benefits ............................................................................................................................................................................... 23

Abuse of FMLA .................................................................................................................................................................... 23

Return to Work Rights ........................................................................................................................................................ 24

Financial Planning .................................................................................................................................................................... 24

Health & Welfare Benefits ....................................................................................................................................................... 24

Holidays ................................................................................................................................................................................... 25

Jury & Witness Duty ................................................................................................................................................................ 26

Medical Professional Liability Insurance ................................................................................................................................. 26

Paid Time Off Program (PTO) .................................................................................................................................................. 26

PTO Allowances .................................................................................................................................................................. 27

Requesting PTO ................................................................................................................................................................... 28

PTO Carryover ..................................................................................................................................................................... 28

Payment of PTO upon Termination of Employment or Change in Status ........................................................................... 28

Professional Development Expense Policy .............................................................................................................................. 29

401(k) Profit Sharing Plan ........................................................................................................................................................ 29

Unemployment Insurance ....................................................................................................................................................... 29

Vacation Policy ........................................................................................................................................................................ 29

Vacation Accrual ................................................................................................................................................................. 30

Vacation Allowance Schedules ........................................................................................................................................... 30

Vacation Allowances for Rehired CRNAs and Physicians .................................................................................................... 30

Vacation Selection Process ................................................................................................................................................. 31

Vacation Taken during a Holiday Week .............................................................................................................................. 31

Vacation Carryover ............................................................................................................................................................. 31

Selling Vacation Days .......................................................................................................................................................... 31

Vacation Pay upon Termination of Employment or Change in Status ................................................................................ 32

Policy Administration .......................................................................................................................................................... 32

Workers’ Compensation .......................................................................................................................................................... 32

HUMAN RESOURCES PRACTICES ........................................................................................................ 34

Employment of Family Members ............................................................................................................................................ 35

Employment References & Wage Verification ........................................................................................................................ 35

Exit Interviews ......................................................................................................................................................................... 36

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Health and Safety .................................................................................................................................................................... 36

Immigration Reform and Control Act ...................................................................................................................................... 36

Inclement Weather ................................................................................................................................................................. 37

Open Door Policy ..................................................................................................................................................................... 37

Ownership of Work Product .................................................................................................................................................... 37

Performance Management ..................................................................................................................................................... 38

Personal Vehicles ..................................................................................................................................................................... 38

Personnel Files ......................................................................................................................................................................... 38

Romantic Relationships ........................................................................................................................................................... 39

STANDARDS OF CONDUCT ................................................................................................................. 40

CAA Code of Conduct .............................................................................................................................................................. 41

Attendance and Punctuality .................................................................................................................................................... 42

Reporting Unexpected Absences & Late Arrivals ................................................................................................................ 42

Failure to Report ................................................................................................................................................................. 43

On-Call Coverage ................................................................................................................................................................ 43

Computer Usage Policy ........................................................................................................................................................... 43

General Use ........................................................................................................................................................................ 43

Internet Usage Policy .......................................................................................................................................................... 45

Confidential Information ......................................................................................................................................................... 46

Conflict of Interest ................................................................................................................................................................... 46

Contact with News Media ....................................................................................................................................................... 47

Corrective Action Process ........................................................................................................................................................ 47

Criminal Charges and Convictions ........................................................................................................................................... 48

Employee Privacy .................................................................................................................................................................... 49

Health Insurance Portability and Accountability Act (HIPAA) ................................................................................................. 49

Medical Billing Compliance ..................................................................................................................................................... 50

Personal Communication Devices ........................................................................................................................................... 50

Social Media ............................................................................................................................................................................ 51

Solicitation and Distribution .................................................................................................................................................... 53

Substance Abuse Policy ........................................................................................................................................................... 53

Policy ................................................................................................................................................................................... 53

Policy Guidelines ................................................................................................................................................................. 54

Substance Abuse Screening ................................................................................................................................................ 55

Procedures Following Positive Drug and Alcohol Tests ....................................................................................................... 56

Violence in the Workplace ...................................................................................................................................................... 57

Restraining Orders .............................................................................................................................................................. 57

Treatment of Family Members ................................................................................................................................................ 58

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ACKNOWLEDGEMENT OF RECEIPT COMMONWEALTH ANESTHESIA ASSOCIATES EMPLOYEE HANDBOOK ...................................................................................................................................... 59

AND .................................................................................................................................................. 59

CODE OF CONDUCT ........................................................................................................................... 59

ACKNOWLEDGEMENT OF RECEIPT COMMONWEALTH ANESTHESIA ASSOCIATES EQUAL EMPLOYMENT OPPORTUNITY, SEXUAL HARASSMENT, AND OTHER UNLAWFUL HARASSMENT POLICIES ................... 60

ACKNOWLEDGEMENT OF RECEIPT CONFIDENTIAL INFORMATION POLICY .......................................... 61

ACKNOWLEDGEMENT OF RECEIPT COMPUTER USAGE POLICY ........................................................... 62

ACKNOWLEDGEMENT OF RECEIPT SUBSTANCE ABUSE POLICY ........................................................... 63

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INTRODUCTION

Welcome to CAA

Mission Statement

Vision Statement

At-Will Employment

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Welcome to CAA

Commonwealth Anesthesia Associates (“CAA”) is Virginia’s premier healthcare practice, providing exceptional anesthesia services to its patients and clients. At CAA, we strive to create a satisfying working environment where everyone can reach his or her full potential.

This Handbook serves as an overview of human resources policies and procedures for CAA. It will provide you with an understanding of what you can expect from CAA, and what CAA expects from you. It is not intended to be comprehensive or address all possible applications of, or exceptions to, the policies and procedures of the organization. Every effort has been made to cover the most relevant human resources policies.

The constantly changing environment in which we do business and CAA’s desire to continually improve our work practices will at times necessitate revisions to our policies and procedures. The Company therefore reserves the right to delete, amend, or modify these policies and procedures as necessary, with or without notice. In addition, in situations where a federal, state, or local law may be inconsistent with any policy in this Handbook, the applicable law will be controlling.

Some of the policies and employee benefits described in this Handbook are covered in detail in official policy documents and written insurance policies. You should refer to those documents for specific information, since this Handbook only briefly summarizes those plans. The terms of written insurance policies will be controlling.

In situations where employees have entered into authorized Employment Agreements with CAA, the terms of the applicable Employment Agreement control over any contrary terms in this handbook.

All employees are expected to be familiar with and abide by the policies in this Handbook, and all those with authority to do so have a duty to administer these policies fairly and consistently and to enforce them when necessary. If you have questions, please ask. CAA’s leadership team is happy to assist you at any time.

Mission Statement

The mission of Commonwealth Anesthesia Associates is to provide safe, effective, and ethical care to our patients. To accomplish this mission, our group of board-certified Anesthesiologists works in a care-team model with Certified Registered Nurse Anesthetists.

We are committed to providing advocacy and education for our patients. We strive to create a fulfilling work environment for all CAA members by developing innovative care-plan strategies, providing ethical leadership for operating room and practice management, and providing market responsive perioperative services.

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Vision Statement

CAA is committed to being the premier provider of anesthesia, comprehensive perioperative, and healthcare management services in Virginia.

At-Will Employment

Nothing in this Handbook creates, or is intended to create, a contract, either express or implied, or a representation of continued employment. All employees at CAA are hired on an at-will basis, for no specific term, and may be terminated at any time for any reason at the will of either CAA or the employee, with or without notice. No supervisor or employee of CAA has authority to enter into an agreement for employment for any specified period of time or to make an agreement other than at-will. Only the CAA Board of Directors or its’ designee(s) have the authority to make any such agreement, and then only in writing.

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EMPLOYMENT PRACTICES

Americans with Disabilities Act (ADA) and ADA Amendments Act

Equal Employment Opportunity

Sexual Harassment

Other Unlawful Harassment

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Americans with Disabilities Act (ADA) & Americans with Disabilities Act Amendments Act (ADAAA)

CAA complies with the Americans with Disabilities Act (ADA) in all matters of employment including recruiting, hiring, training, promoting, compensating, providing benefits, taking corrective action or separating an employee, or any other term or condition of employment.

The ADA/ADAAA prohibits the discrimination against persons with disabilities, defined as a physical or mental impairment that substantially limits one or more major life activity; or the record or history of such impairment; or being regarded by the employer as having such an impairment.

An individual must be qualified to perform the essential functions of the job with or without reasonable accommodation in order to be protected by the ADA/ADAAA. CAA will endeavor to make reasonable accommodation to a qualified employee/applicant who can perform the essential functions of the job, provided that such accommodation does not constitute an undue hardship on the Company. Reasonable accommodation includes, but is not limited to, making facilities accessible, restructuring jobs, providing modified work schedules, and/or acquiring or modifying equipment or devices.

An employee or applicant cannot and will not be asked about the severity or nature of his or her disability, but may be asked to demonstrate how he or she, with or without reasonable accommodation, will perform the essential duties of the job. The Human Resources Department will evaluate all qualified employees/applicants with a disability to ensure that reasonable accommodation is offered when possible, and that the Company remains in compliance with ADA/ADAAA. Any questions regarding the ability of the Company to make reasonable accommodation for an employee/applicant with a disability are to be sent to the Director of Human Resources.

Any individual who feels that he or she may have a disability discrimination concern is strongly encouraged to immediately contact the Director of Human Resources or CAA’s Administrator. Concerns may also be reported using CAA’s Compliance Hotline by calling 804-461-3883 or by sending an email to [email protected]. Any member of management notified of alleged disability discrimination is required to bring the matter to the immediate attention of the Director of Human Resources.

Equal Employment Opportunity Policy

CAA subscribes to the equal employment opportunity requirements of federal laws, regulations, and executive orders, as well as the laws of the states and municipalities in which we conduct business. CAA is committed to hiring and developing the most qualified individuals from the available workforce in the communities we serve. It is the policy of CAA to ensure equal opportunity to all employees and applicants in all employment matters, including, but not limited to, recruitment, hiring, placement, compensation, training, promotion, and separation. In these and all activities, CAA does not discriminate against any qualified individual because of sex, age, race, color, religion, creed, national

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origin, ancestry, familial status, marital status, sexual orientation, sexual preference, disability, handicap, liability for service in the United States Armed Forces, veteran status, and/or any other legally protected characteristic.

CAA requires that staff understand and make a personal commitment to practice and enforce the principles of this policy as follows:

• Recruit, hire, place, compensate, train, promote, and separate without regard to sex, age, race, color, religion, creed, national origin, ancestry, familial status, marital status, sexual orientation, sexual preference, disability, handicap, liability for service in the United States Armed Forces, veteran status, and/or any other legally protected characteristic, except where a bona fide occupational qualification exists.

• Ensure all employment decisions are in accordance with the principles of equal employment opportunity.

• Ensure that the workplace is void of any unlawful verbal or physical abuse, intimidation, or harassment against any employee or applicant for employment.

Any individual who feels that he or she may have been discriminated against in violation of this policy is strongly encouraged to immediately contact the Director of Human Resources, CAA’s Administrator, or the CAA Board of Directors. Concerns may also be reported using CAA’s Compliance Hotline by calling 804-461-3883 or by sending an email to [email protected]. Any member of the CAA leadership team who is notified of alleged discrimination is required to immediately report the incident to the Director of Human Resources, except where the Director may be implicated in the allegations and an immediate report to the Director would jeopardize the investigation.

CAA will thoroughly investigate all such claims with due regard for the privacy of the individuals involved. Any employee who knowingly retaliates against an employee who has reported workplace discrimination will be subject to immediate corrective action, up to and potentially including termination of employment.

Sexual Harassment

CAA is committed to the belief that all employees are entitled to work in an environment free of implicit or explicit physical and/or verbal harassment of a sexual nature. No employee shall be subject to sexual harassment from another employee at his or her place of work, or from any individual doing business with CAA. Sexual harassment includes same-sex harassment.

• This policy applies to all officers and employees of CAA. In addition, CAA will communicate this policy with CAA vendors and CAA contractors who have contact with any business location where CAA provides services.

• Sexual harassment may include, but is not limited to, unwelcome or offensive sexual advances, sexual jokes, requests for sexual favors, inappropriate touching, leers, intrusive personal questions and/or questions of a sexual nature, visual

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displays of degrading images or references to sexual stereotypes, screaming, shouting, or insulting language of a sexual nature, or other verbal or physical conduct of a harassing nature. These actions constitute sexual harassment when:

• Submission to such conduct is made a term or condition of employment.

• Submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting the individual, or

• Such conduct unreasonably interferes with an individual’s work performance or creates an intimidating, hostile, or offensive working environment.

• Sexual harassment is unacceptable conduct and will not be tolerated. This policy applies not only to the workplace during normal business hours, but also to all work-related social functions, whether on or off Company premises. All employees are responsible for assuring that the workplace is free from sexual harassment. Employees violating this policy shall be subject to corrective action that may include immediate termination of employment.

An employee with a complaint of sexual harassment, or knowledge of alleged sexual harassment by anyone, is strongly encouraged to bring the problem to the immediate attention of the Director of Human Resources, or CAA’s Administrator. Concerns may also be reported using CAA’s Compliance Hotline by calling 804-461-3883 or by sending an email to [email protected].

Any member of the CAA leadership team who is notified of alleged sexual harassment or has knowledge of alleged sexual harassment is required to immediately report the incident to the Director of Human Resources (except where the Director may be implicated in the allegations and an immediate report to the Director would jeopardize the Company’s investigation). The leadership team member is to communicate to the employee that CAA will thoroughly investigate the matter and that the Company will pay due regard to the privacy of the individuals involved. No other comment or commitments should be made to the employee. The leadership team member must document the complaint and submit the documentation to the Director of Human Resources within 24 hours of receiving the complaint. If the complaint is brought to the attention of a member of the leadership team and the employee does not receive a follow-up phone call from the Director of Human Resources within 72 hours, the employee should contact the Director of Human Resources personally.

CAA will not, in any way, retaliate against an individual who makes a good faith report of sexual harassment or permit any CAA employee to do so. Retaliation is a serious violation of this policy and should be reported immediately. Any person found to have retaliated against another individual for reporting sexual harassment will be subject to corrective action, up to and potentially including termination of employment.

CAA will conduct a thorough investigation into all complaints to gather information and determine the validity of the allegation and, when appropriate, ensure corrective action is taken, up to and potentially including termination of employment.

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Other Unlawful Harassment

CAA is committed to the belief that all employees are entitled to work in an environment completely free of implicit or explicit physical and/or verbal harassment on the basis of age, race, color, religion, creed, national origin, sexual orientation, disability, or handicap, or any other protected characteristic. No employee shall be subject to other unlawful harassment from another employee at his or her place of work, or from any individual doing business with CAA.

• This policy applies to all officers and employees of CAA. In addition, CAA will communicate this policy with CAA vendors and CAA contractors who have contact with any business location where CAA provides services.

• Other unlawful harassment is verbal or physical conduct that denigrates or shows hostility or aversion toward an employee or his or her relatives, friends, associates, or employees on the basis of age, race, color, religion, creed, national origin, sexual orientation, disability, or handicap, or any other protected characteristic.

• Harassing conduct includes epithets, slurs, negative stereotyping or threatening, intimidating, or hostile acts. It also includes written or graphic material that denigrates or shows hostility.

• Other unlawful harassment is unacceptable conduct and will not be tolerated. All employees are responsible for assuring that the workplace is free from other unlawful harassment. Employees violating this policy shall be subject to corrective action that may include immediate termination of employment.

An employee with a complaint of alleged other unlawful harassment, or knowledge of alleged other unlawful harassment by anyone, is strongly encouraged to bring their concern to the immediate attention of the Director of Human Resources, or CAA’s Administrator. Concerns may also be reported using CAA’s Compliance Hotline by calling 804-461-3883 or by sending an email to [email protected].

Any member of the CAA leadership team who is notified of alleged other unlawful harassment or has knowledge of alleged other unlawful harassment is required to immediately report the incident to the Director of Human Resources (except where the Director may be implicated in the allegations and an immediate report to the Director would jeopardize the Company’s investigation). The leadership team member is to communicate to the employee that CAA will thoroughly investigate the matter and that the Company will pay due regard to the privacy of the individuals involved. No other comment or commitments should be made to the employee. The leadership team member must document the complaint and submit the documentation to the Director of Human Resources within 24 hours of receiving the complaint. If the complaint is brought to the attention of a member of the leadership team and the employee does not receive a follow-up phone call from the Director of Human Resources within 72 hours, the employee should contact the Director of Human Resources personally.

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CAA will not, in any way, retaliate against an individual who makes a good faith report of other unlawful harassment nor permit any CAA employee to do so. Retaliation is a serious violation of this policy and should be reported immediately. Any person found to have retaliated against another individual for reporting other unlawful harassment will be subject to corrective action, up to and potentially including termination of employment.

CAA will conduct a thorough investigation into all complaints to gather information and determine the validity of the allegation and, when appropriate, ensure corrective action is taken, up to and potentially including termination of employment.

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COMPENSATION & PAY PRACTICES

Employment Classification

Call Classification

Change in Status

Garnishments

Pay Practices

Resignation

Salary & Wage Administration

Timekeeping

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Employment Classification

The following classifications determine CAA employees’ compensation methods and eligibility for various Company-sponsored employee benefit programs.

Exempt With limited exceptions, exempt employees are paid a set salary for each workweek in which they perform work for CAA. Exempt employees, because of their duties, responsibilities, and decision-making authority, are exempt from overtime requirements under the law.

Non-Exempt Non-exempt employees are generally paid on an hourly basis, but may be paid on a salary basis, and receive overtime at a rate of time and one-half of the employee’s regular rate for time worked in excess of 40 hours in any single workweek.

Full-Time Employees who consistently are scheduled and work an average of 36 hours or more on a weekly basis are classified as Full-Time employees. CAA full-time employees are generally eligible for all Company-sponsored employee benefit programs.

Part-Time Employees who typically work fewer than 36 hours per week are classified as Part-Time employees. Part-time CAA employees will generally work between 25 and 35 hours per week, but may work greater or fewer hours as required by CAA, at its discretion. CAA part-time employees are generally eligible for all Company-sponsored employee benefit programs, though some benefits may be pro-rated.

Flex Pool Employees who work on a per-diem basis and make a less than full-time commitment to CAA are classified as Flex Pool employees. There is no guarantee of scheduled hours for Flex Pool employees. CAA flex pool employees are limited in the Company-sponsored employee benefit programs available to them.

Call Classification

Full-Call Employees who are regularly scheduled to take call at a CAA facility and share an equal burden for the call with their peers at their primary campus are classified as Full-Call employees.

Limited-Call Employees who are regularly scheduled to take call at a CAA facility, but who are scheduled for fewer call shifts than their full-call peers, are classified as Limited Call employees. Limited-call employee schedules are determined based on CAA facility needs. Limited-call schedules must be approved by CAA’s Workforce Committee.

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Without Call Employees who are not scheduled to take call at any CAA facility on a regular basis are classified as Without Call employees. These employees may, on occasion, accept a call shift, and receive hourly compensation for that shift at a pre-determined rate of pay.

Change in Status

Employees who change their name, address, phone number, marital status, dependents, or Voluntary Life Insurance beneficiary are responsible for promptly notifying the Human Resources Department so that updates can be made in the appropriate corporate systems.

Garnishments

CAA will honor garnishments and wage attachments that are required by law and properly served upon the Company. The Human Resources Department must be notified immediately of garnishments, attachments, or any other orders requiring payment of a portion of an employee’s compensation to someone other than the employee. The notice of garnishment should be forwarded to the Director of Human Resources. The amount deducted from an employee’s disposable income will not exceed that permitted by law. CAA cannot refuse to accept a properly served garnishment or wage attachment. Doing so is considered interfering in a lawful process and, as such, is a punishable offense.

Pay Practices

Pay Periods and Paydays CAA pays employees on a bi-weekly basis, with paychecks and payroll deposit advices issued 26 times per year. CAA’s pay periods begin at 6:30 a.m. on Monday and end 14 days later at 6:29 a.m. CAA employees are paid with one pay period of lag time, which is necessary so that information from CAA’s timekeeping and provider scheduling systems can be validated and accurately processed through the payroll system by the Human Resources Department.

Reporting Payroll Errors CAA makes every effort to accurately compensate employees and to do so in accordance with all applicable state and federal laws. Occasionally, inadvertent mistakes may happen. When mistakes occur, they will be corrected in the next CAA pay cycle. All employees have a responsibility for reviewing their pay stub or payroll deposit advice to make sure it is correct. If employees believe a mistake has occurred or if they have questions, they should contact the Human Resources Department.

Payroll Deductions CAA employee salaries will be reduced for certain types of deductions, in accordance with Company policies and applicable state and federal laws. These deductions may include, but are not limited to, the following:

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• Employee contributions for health and dental insurance coverage, or other Company-sponsored benefit plans

• Voluntary deductions for a 401(k)

• State, federal and/or local taxes

• Social Security

• Exempt Employee Deductions

With limited exceptions, exempt employees are paid a set salary for each workweek in which they perform any work for the Company, without regard to the number of days or hours worked. Wage continuation for time away from work may be the result of approved vacation time off, Paid Time Off (PTO), disability leave or Workers’ Compensation insurance lost-time claims. Apart from the preceding wage continuation benefits, exempt employees will generally not be paid for any workweek in which they perform no work.

Deductions may be taken from the salary of an exempt employee in the following circumstances:

o The employee is absent from work for one or more full days for personal reasons, other than approved vacation or PTO;

o The employee is absent from work for one or more full days due to sickness or disability (including work-related accidents) and the deduction is made in accordance with the Company’s policies and practices for providing compensation for such leave;

o The employee is absent from work for the entire work week or performs no working during an entire work week.

o The employee may have offset against any salary to be paid in a workweek any amount received for jury fees, witness fees, or military pay in such workweek;

o An unpaid disciplinary suspension of one or more full days is imposed in good faith against the employee for violating the Company’s written rules governing conduct and safety;

o The employee resigns or is terminated having taken vacation or PTO days in excess of vacation and/or PTO time actually accrued;

o The employee fails to work the entire workweek in the initial or final week of employment with the Company, or

o The employee takes unpaid leave under the Family and Medical Leave Act.

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Employees who believe that they have been subject to an improper deduction should immediately contact the Human Resources Department so that the matter may be investigated. If the Company determines that any deductions from salary were made in error or in violation of this policy or Federal, state, or local law governing the payment of wages, the Company will reimburse the employee for any improper deductions or compensation and make a good faith commitment to ensure compliance in the future.

CRNA Compensation and Call Responsibilities CAA has several CRNA salary ranges in place, which are applied depending on the type of position a CRNA has with the Company: Full-Call, Limited-Call, or Without Call. Without Call positions are generally compensated using the lowest salary range, and Full-Call positions are compensated using the highest salary range. Limited-Call positions are generally compensated somewhere in between, depending on the amount of call that is taken. Limited-Call schedules and compensation must be approved by CAA’s Workforce Committee.

While it is understood that CRNAs will occasionally need to ask another CRNA to work their assigned call due to a last-minute personal conflict, these instances of not taking assigned call should be extremely rare, and must be communicated to the Human Resources Department so that CAA’s scheduling system can be updated as needed. Failure to take assigned call with a degree of frequency will not be tolerated, as it has the effect of compensating a CRNA at a higher salary range for call that they are not taking.

In general, Full-Call and Limited-Call CRNAs must take at least 85% of their assigned call to remain eligible for these higher salary ranges. Exceptions may occur based on extenuating circumstances (for instance, an extended period of absence due to disability), and must be approved by CAA’s Workforce Committee.

Resignation

If a CAA employee wishes to terminate his or her employment relationship with the Company, the employee is required to follow the termination provisions set forth in his or her Employment Agreement, if applicable. Notice of resignation should be made in writing to the employee’s Chief of Anesthesia with a copy of the resignation letter forwarded to the Director of Human Resources.

In the absence of an Employment Agreement, CAA requests that clinical employees provide a minimum of four (4) weeks’ notice of resignation to allow for recruitment of a replacement. CAA may, at its discretion, elect to accept an employee’s resignation effective immediately.

Nothing in this Handbook creates, or is intended to create, a contract, either express or implied, or a representation of continued employment. All employees at CAA are hired on an at-will basis, for no specific term, and may be terminated at any time for any

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reason at the will of either CAA or the employee, with or without notice. No supervisor or employee of CAA has authority to enter into an agreement for employment for any specified period of time or to make an agreement other than at-will. Only the CAA Board of Directors or its’ designee(s) have the authority to make any such agreement, and then only in writing.

Salary & Wage Administration

To attract and retain high caliber employees, CAA strives to pay salaries and wages competitive with those paid by other employers in our industry in the labor markets in which we provide anesthesia services. In keeping with this objective, CAA monitors salary and wage scales to ensure that we remain competitive.

Employees’ total compensation consists of not only the salary or wages they are paid, but also the various benefits that are offered to employees, such as group health and dental insurance, vacation time and Paid Time Off, 401(k) Profit Sharing Plans, etc., as described later in this Handbook. As noted earlier, some of the benefits described are covered in detail in official policy documents and written insurance policies. Employees should refer to these documents for specific information, since this Handbook only briefly summarizes those plans. The terms of written insurance policies will be controlling. Questions regarding CAA’s salary and wage administration program or your individual salary should be directed to CAA’s Director of Human Resources.

Timekeeping

All employees are responsible for clocking into and out of CAA’s web-based timekeeping system every day that they work at a CAA facility. This includes regular work shifts and call shifts where arrival and departure may take place overnight or on the weekend. All new CAA employees are trained on how to use the timekeeping system.

Employees who inadvertently forget to clock in or clock out should contact the Human Resources Department so that corrections may be made to their timekeeping records. If a member of the Human Resources team is not available by phone, the employee may email any member of the Human Resources team with the information they will need to make the correction. The employee should then review their timesheet again within 24 hours, to ensure the correction has been made.

Depending on the facility, employees may clock in using a time clock or via an Internet application. If an employee is scheduled to work at a facility that has not been designated as their “primary campus” and they are clocking in via an Internet application, they are required to select the correct location code at the time that they clock in.

Failure to consistently clock in and out is a performance issue that will be addressed with the employee, and may result in corrective action. In addition, falsification of timekeeping records, or inaccurate reporting of time worked, is a violation of CAA’s Code of Conduct and will not be tolerated.

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EMPLOYEE BENEFITS

Benefits Overview

Administrative Leave of Absence

Bereavement Leave

COBRA

Direct Deposit

Disability Insurance

Domestic Partnership Policy

Employee Assistance Program

Employee Military Leave

Family and Medical Leave Act (FMLA)

Financial Planning

Health & Welfare Benefits

Holiday Time Off

Jury & Witness Duty

Medical Professional Liability Insurance

Paid Time Off

Professional Development Expense Policy

401(k) Profit Sharing Plan

Unemployment Insurance

Vacation Policy

Workers’ Compensation

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Benefits Overview

The benefits summaries in CAA’s Employee Handbook serve as an overview of benefits and programs that generally will be available to all active, full-time CAA employees. These summaries provide employees with a high-level review of the benefits that CAA has in place, and are not intended to be comprehensive or address all possible applications of, or exceptions to, the benefits and programs described.

CAA reserves the right to delete, amend, or modify these benefits and programs as necessary. In addition, in situations where a federal, state, or local law may be inconsistent with any policy in this Handbook, the applicable law will be controlling.

Some of the policies and employee benefits described in this section of the Handbook are covered in detail in official policy documents and written insurance policies. Employees should refer to these documents for specific information, since this Handbook only briefly summarizes those plans. The terms of written insurance policies will be controlling.

Administrative Leave of Absence

An administrative leave of absence with or without pay may occur when it is determined to be in either the Company’s or employee’s best interest for the employee to not return to work for a specified period of time. Employees requesting an administrative leave of absence must submit their request in writing to the Director of Human Resources, who will present the request to the CAA Board of Directors for consideration.

If CAA decides to place an employee on an administrative leave without having received a request for same from the employee, the employee will be notified of such leave in writing. An administrative leave will generally not exceed 21 days. However, CAA reserves the right to extend the leave if it deems it appropriate to do so. Employees may not be actively employed elsewhere while on an approved leave of absence of any kind, excluding Military Leave.

Bereavement Leave

CAA recognizes that an employee who suffers the death of a family member may need time off to make memorial/funeral arrangements and/or to travel to and attend memorial/funeral services. The time necessary to make such arrangements and/or travel to and attend such services will be paid Bereavement Leave. This policy provides all CAA active, full-time employees with up to three (3) days off (or up to 24 hours of pay) for bereavement leave. Such leave will be determined and approved by the Director of Human Resources based on scheduling and coverage needs.

Under this policy, family members are defined as: spouse or qualified domestic partner, child, parent, sibling, grandparent, grandchild, and corresponding in-law and “step” relations.

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COBRA

Under the Consolidated Omnibus Budget Reconciliation Act (COBRA) of 1985, an employee or qualified dependent that was enrolled in CAA’s medical and/or dental plan on the day before a life event known as a “qualifying event” takes place will be offered continuation coverage through COBRA. COBRA allows for the continuation of plan coverage when coverage would otherwise end because of the qualifying event.

Employees and/or qualified dependents that elect COBRA continuation coverage are required to pay the full cost for their coverage plus a small administrative fee as allowed by law. COBRA notices offering continuation coverage are either hand delivered during the exit interview process or mailed using the U.S. Postal Service to the address on record with the Human Resources Department.

Qualifying events that trigger COBRA eligibility are:

• Termination of employment (except for terminations resulting from “gross misconduct”)

• Reduction in hours of employment

• Divorce or legal separation of spouse or qualified domestic partner

• Child’s loss of dependent status

• Employee’s request to terminate coverage

• Employee’s entitlement to Medicare; or

• Employee’s death

New employees and their qualified dependents that enroll in CAA’s medical and/or dental plan are sent detailed notices explaining their COBRA rights, in accordance with federal and state requirements. Because the law changes and CAA’s health benefits periodically change, continuation of benefits may change as well. Complete explanations of insurance continuation rights are available in the Summary Plan Descriptions (SPDs) for CAA’s medical and dental insurance programs.

Direct Deposit

In an effort to “go green” and eliminate unnecessary paper, all CAA employees are offered the convenience of direct deposit for payroll transactions. If direct deposit is elected, a form must be completed and submitted to Human Resources along with a voided check or deposit slip. It typically takes two (2) pay cycles for a direct deposit to take effect or for a change in account to take effect. Electronic payroll deposit advices are generated in lieu of paper and are accessible to employees via the payroll system’s web-based portal. Questions should be directed to Human Resources.

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Disability Insurance

CAA contracts with a disability insurance carrier to provide eligible employees with both Short- and Long-Term Disability insurance coverage. These employees become eligible for this important wage continuation coverage on the first of the month following their date of hire. If a disability claim is approved by the disability insurance carrier, this coverage pays a disability benefit (following the completion of a required elimination period) as partial replacement of income lost due to injury, illness, or pregnancy. It is important to note that approved Short-Term Disability leave runs concurrent with Family Medical Leave Act “FMLA” leave. Please refer to the Family Medical Leave Act section of this Handbook for additional information.

Employees out on an approved Short-Term Disability claim may request to be paid on a bi-weekly basis for unused, accrued vacation and/or PTO concurrent with receiving wage continuation payments from CAA’s disability insurance carrier. In no case, however, can the compensation received for unused, accrued vacation and/or PTO PLUS the wage continuation payments received from the disability insurance carrier exceed 100% of the employees’ pre-disability earnings.

Employees who know they will be continuously absent from work more than 14 calendar days must contact the Human Resources Department as soon as they are aware of the need for their absence. Chiefs of Anesthesia should contact Human Resources if an employee’s absence due to illness or injury exceeds five (5) work days.

Domestic Partnership Policy

CAA offers domestic partnership insurance coverage under the group medical and dental plans to employees’ qualified Domestic Partner and his or her dependent children.

Definitions A Domestic Partner is defined as a non-married person of the same or opposite sex who:

• Shares a common legal residence with the employee.

• Has resided with the employee for a minimum of 12 months.

• Intends to cohabit with the employee indefinitely.

• Shares the common necessities of life with the employee.

• Is no less than 18 years of age.

• Is not related by blood or adoption to the employee.

• Is mentally competent to consent to a contract.

• Shares responsibility for common welfare and living expenses with the employee.

• Has not had another/a different Domestic Partner within the preceding 12 months, and has not filed a Termination of Domestic Partnership form within the preceding 12 months.

• Is the employee’s sole Domestic Partner and intends to remain so indefinitely.

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Eligibility For employees to add a domestic partner under their medical and/or dental insurance coverage, they must satisfy the requirements outlined in CAA’s Affidavit for Domestic Partnership. Both the employee and the domestic partner must complete this form, and it must be notarized. The form is then reviewed and approved by the Director of Human Resources, prior to enrollment in medical and/or dental plans.

Termination of Domestic Partnership If a domestic partnership is terminated, the domestic partner and his or her covered children may no longer be eligible for the benefits under which they had been covered previously, depending on the circumstances. The employee must complete a Termination of Domestic Partnership form as soon as the partnership has been dissolved and no longer meets the guidelines stated in the affidavit. Upon completion of the termination form, the employee is not eligible to add a new domestic partner, or re-enroll the same domestic partner, in CAA’s medical and dental plans for at least 12 months following the submittal date of the Termination of Domestic Partnership form. Human Resources will provide additional information regarding COBRA eligibility.

Cost of Coverage & Taxability There are significant complexities in state and federal laws concerning taxation and benefits for Domestic Partners. Employees interested in enrolling in group medical and/or dental coverage for their domestic partner are encouraged to meet with CAA's Director of Human Resources and CAA’s Controller, so that current information as it applies to their situation may be reviewed.

Employee Assistance Program

CAA contracts with a professional firm to provide CAA employees and their immediate family members with a comprehensive Employee Assistance Program (EAP). This program provides support, resources, and information that can assist with both personal and work-life issues. Services are available in a wide variety of areas, including marital and family conflicts, stress, alcohol and drug abuse, and financial/legal difficulties.

The EAP is staffed by highly trained Master’s and doctoral-level clinicians who listen to concerns and ultimately refer employees and their family members to in-person counseling and other resources, as appropriate. There is no cost to employees or their family members for this program. Additional information on this valuable benefit may be found on CAA’s intranet or by contacting Human Resources for a confidential discussion on program options.

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Employee Military Leave

CAA is committed to supporting the United States Armed Forces and complies with all the requirements of the Uniformed Services Employment and Reemployment Rights Act of 1994 (USERRA). Active, full-time employees who are members of the military services will be granted leaves of absence, provided benefits, and afforded reemployment rights consistent with applicable federal and state laws.

As with other types of scheduling and leave matters, employees are expected to communicate with their Chief of Anesthesia and the Human Resources Department as far in advance as possible when they are requesting military leave. Notice must be in writing, and copies of military orders or other supporting documentation must be included, unless precluded from doing so by military necessity.

Compensation and Benefits While on Military Leave USERRA provides employees who are absent from work because of service in the U.S. Uniformed Services (the Armed Forces, National Guard, Reserves, Coast Guard, and the U.S. Public Health Service) with certain rights regarding employment, reemployment, health plan coverage, and tax-qualified retirement plan coverage.

Information on requests for leave, required documentation, reemployment rights, reporting for reemployment, health plan benefits, and other USERRA guidelines is available from the Human Resources Department.

Family and Medical Leave Act (FMLA)

The Family and Medical Leave Act (FMLA) is a federal law that provides certain rights to eligible employees under covered medical and military circumstances. An employee is eligible for consideration for leave under FMLA if the employee:

• Has worked for CAA for at least 12 months in the last seven years; and

• Has been employed by CAA for at least 1,250 hours of service during the 12-month period immediately preceding the start of leave; and

• Works in a facility during a period when CAA employs 50 or more employees within a 75-mile radius.

Eligibility determination will be made based on the date leave starts.

FMLA requires employers to provide eligible employees up to 12 weeks of unpaid, job-protected leave in a rolling 12-month period for the following reasons:

• The employee’s incapacity due to pregnancy, prenatal medical care, or child birth; or

• The care of the employee’s child after birth, or for the placement of the child with the employee through adoption or foster care; or

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• The care of the employee’s spouse, son, daughter, or parent who has a serious health condition; or

• For a serious health condition that prevents the employee from performing the essential functions of his or her job.

When both spouses are employed by CAA, the combined amount of leave they may take will be limited to 12 weeks for the birth or adoption of a child or to care for a sick family member. FMLA defines family as a spouse, son, daughter, or parent.

FMLA also entitles eligible employees to take leave for a covered family member’s service in the Armed Forces. Additional information about FMLA for military reasons may be obtained from the Human Resources Department.

Paid and Unpaid Leave Approved leave under FMLA runs concurrent with any other paid or unpaid leave (such as Short-Term Disability, Workers’ Compensation, and/or vacation and Paid Time Off “PTO”). In general, employees taking an approved FMLA leave are required to use all their accrued vacation and PTO prior to the start of any unpaid portion of the FMLA leave. CAA employees may elect to save a portion of their accrued vacation and PTO time for use after their return to work, as follows:

• Employees who take 12 weeks of FMLA and have a return to work date in the 1st or 2nd quarter of the calendar year may elect to “save” up to ten (10) days of vacation and/or PTO time, for use later in the year.

• Employees who take 12 weeks of FMLA and have a return to work date in the 3rd quarter of the calendar year may elect to “save” up to five (5) days of vacation and/or PTO time, for use later in the year.

• Employees who take 12 weeks of FMLA and have a return to work date in the 4th quarter of the calendar year are not eligible to “save” accrued vacation and/or PTO time, and will be required to take that time prior to the start of the unpaid portion of the FMLA leave.

When an employee’s serious health condition is due to a work-related illness or injury, the workers’ compensation absence and FMLA run concurrently. Workers’ Compensation indemnity benefits will be considered primary and the employee will be paid in accordance with workers’ compensation state law and the applicable insurance policy.

Employees who are on unpaid FMLA during a holiday will not be paid for the holiday.

Intermittent or Reduced-Schedule Leave When eligible employees request intermittent or reduced-schedule leave, they must provide a written explanation for the reason that type of leave is necessary as well as the schedule for treatment, if applicable. CAA may request that treatments be scheduled at times that will not unduly disrupt business operations, subject to approval by the employees’ healthcare provider.

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Notice of Need for Leave When the need for FMLA leave is foreseeable, employees must provide 30 days’ written notice to the Human Resources Department. In situations where 30 days’ notice is not possible, the employee should notify Human Resources as soon as they are aware of the need for leave.

Employees must provide completed FMLA documentation to Human Resources within 15 days of receiving the documents.

Medical Certification Prior to approving FMLA for an employee’s own illness or the serious health condition of a family member, CAA may require medical certification of the condition and the need for leave from the employees’ healthcare provider. Recertification may also be required periodically during the FMLA leave. If the employee’s medical evidence is deemed inconclusive, the Company may arrange for a medical examination at its own expense to determine the need for FMLA leave.

Benefits While an employee is on an approved FMLA leave, CAA will maintain the employee’s health coverage on the same terms as if the employee had continued to work. While on FMLA:

• The employee must continue to pay any portion of benefit premiums that the employee would otherwise pay as an active employee. An employee’s failure to pay his or her portion of the premiums for any reason may result in loss of coverage.

• Premiums must be paid by the employee to CAA and are due on the date they would have been paid by payroll deduction if the employee was not on leave.

• If an employee is on FMLA and receives pay through the application of accrued vacation or PTO time, or for working a reduced schedule, the employee’s portion of premiums will be deducted from his or her paycheck.

Abuse of FMLA The following situations constitute abuse of FMLA and may be subject to corrective action up to and potentially including termination of employment:

• Failure to return to work at the end of the approved leave period, except when a request for an additional Leave of Absence has been approved by the CAA Board of Directors.

• Employment by another employer while on FMLA, except when prior approval has been received from the CAA Board of Directors.

• Falsification of records and failure to correct records known to be false (even if true when given).

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Return to Work Rights Employees returning from approved FMLA leave for their own illness must provide medical certification indicating fitness to return to work. Employees returning from approved FMLA will be reinstated to their current or a substantially equivalent position. If the leave exceeds the maximum approved leave, there is no guarantee of reinstatement.

Employees should contact the Human Resources Department for more information on FMLA.

Financial Planning

CAA contracts with a professional financial advisory group to provide all employees with comprehensive financial planning services, including advice related to CAA’s 401(k) Profit Sharing Plan. Employees who would like additional information on these services may contact CAA’s Director of Human Resources.

Health & Welfare Benefits

All full-time CAA employees, and part-time CAA employees who meet specific scheduling requirements, are eligible to participate in CAA’s health and welfare benefits plans. CAA offers comprehensive medical and dental coverage, and eligible employees may enroll in these plans for coverage effective on the first calendar day of the month following their date of hire. Enrolled employees pay a portion of the premiums for their medical and dental insurance through pre-tax, bi-weekly payroll deductions. Individual, Employee + Spouse, Employee + Child(ren), and Family coverage options are available in these plans. Qualified domestic partners and their children may also be eligible for enrollment, subject to the terms and conditions outlined in CAA’s Domestic Partnership Policy and the appropriate plan documents.

CAA also offers voluntary life insurance and accidental death and dismemberment insurance to employees interested in these plans. Complete details are shared with eligible employees during the new employee orientation process.

Additional information regarding the various benefit programs described in this Handbook is set forth in more elaborate plan documents, such as the insurance policies, official plan documents, and summary plan descriptions that are available through the Human Resources Department. If any real or apparent conflict exists between the brief summaries and descriptions contain in this Handbook and the terms, conditions or limitations of the official plan documents, the provisions of the official plan documents will control.

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Holidays

CAA recognizes the following holidays:

New Year’s Day Labor Day Memorial Day Thanksgiving Day July 4th Christmas Day

Based on the requirements for patient care at the facilities CAA serves, a small number of physicians and CRNAs will be scheduled to work on each Company-recognized holiday.

Physicians and CRNAs who choose to select a vacation week during a week containing a Company-recognized holiday should be aware that they will be using five (5) vacation days during that week off, not four (4) vacation days. Employees who are scheduled to work a partial week containing a Company-recognized holiday must work three (3) days of the week to avoid using a vacation day for the actual holiday. Employees who are scheduled to work two (2) or fewer days of a holiday week will use a vacation day for the holiday. Please refer to the Vacation Policy in this Handbook for additional details.

From a scheduling perspective and contemplating the exceptions noted above, employees who are scheduled to work the entire week containing a Company-recognized holiday must meet the following criteria to be paid for the holiday:

• CAA employees normally scheduled to work five (5) weekday shifts (Without Call; Limited Call; Full Call) will have their regular salary paid in full for the holiday.

• CAA employees normally scheduled to work four (4) weekday shifts (Without Call; Limited Cal; Full Call) must schedule three (3) ten (10)-hour shifts during the week of the holiday to receive their regular salary for the week.

• CAA employees normally scheduled to work three (3) weekday shifts (Without Call; Limited Call) must schedule two (2) twelve (12)-hour shifts and one (1) ten (10)-hour shift during the week of the holiday to receive their regular salary for the week.

• CAA employees normally scheduled to work three (3) weekday shifts who work Full Call must schedule two (2) twelve (12)-hour shifts and one (1) eight (8)-hour shift during the week of the holiday to receive their regular salary for the week.

Requests for exceptions to these criteria must be submitted in writing to the Director of Human Resources, for consideration by CAA’s Workforce Committee.

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Jury & Witness Duty

CAA encourages employees to fulfill their civic responsibilities by serving Jury Duty when requested.

If an employee is summoned for Jury or Witness Duty, he or she is eligible to receive his or her regular salary or wages for each day of jury duty up to a maximum of ten (10) business days.

To be paid for these days, employees are required to provide their Notice to Serve Jury Duty to the Human Resources Department, upon receipt of the notice, and to submit a signed Certificate of Jury Service indicating the number of days served. Employees may not be actively employed elsewhere while on approved leave for jury or witness duty.

Exceptions to this policy require approval of CAA’s Board of Directors.

Medical Professional Liability Insurance

CAA maintains medical professional liability insurance for all active clinical staff members. CAA employees are protected against covered claims while acting within the scope of their duties as employees of CAA. Employees are not protected while acting in a non-medical capacity. In addition, CAA employees are not covered by this policy while engaged in clinical work for anyone other than Commonwealth Anesthesia Associates. In addition, employees are required to formally request approval of the CAA Board of Directors to engage in anesthesia-related clinical work for anyone other than CAA prior to commencing such work, and may be required to provide proof of medical professional liability insurance for that work.

CAA employees who become aware of a patient incident that may result in a claim being filed are required to immediately contact their Chief of Anesthesia and CAA’s Administrator to report the specifics of the incident.

This statement is not a contract of insurance coverage nor is it intended to provide insurance coverage. In all cases, insurance benefits, coverage, and eligibility requirements, etc., are subject to the terms of the insurance policies. For additional information or questions about medical professional liability insurance coverage, contact CAA’s Administrator.

Paid Time Off Program (PTO)

Paid Time Off (PTO) is a flexible leave program that allows employees to take time off for personal or family illnesses or emergencies, holidays that are not recognized by the Company, volunteer work, child involvement, or other personal commitments. PTO provides an opportunity for employees to plan intermittent time off in advance and allows CAA to plan work coverage efficiently.

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Employee absences that are not attributed to vacation or another excused event will automatically be deducted from the employee’s PTO balance. If the employee’s PTO has been exhausted, vacation time will be reduced accordingly.

It is important to note that for the purposes of premium pay and overtime calculations, Paid Time Off is not considered “time worked”.

PTO Allowances Eligible employees receive annual PTO allowances according to the following schedule:

• Employees regularly scheduled for five (5) weekday shifts receive three (3) shifts of PTO annually.

• Employees regularly scheduled for four (4) weekday shifts receive two (2) shifts of PTO annually.

• Employees regularly scheduled for three (3) weekday shifts receive one (1) shift of PTO annually.

During the first calendar year of employment, newly hired employees will receive a pro-rated PTO allowance as follows:

Employees Scheduled for Five (5) Weekday Shifts

• Hired between January 1st and March 31st = 3 PTO days

• Hired between April 1st and June 30th = 2 PTO days

• Hired between July 1st and September 30th = 1 PTO

• Hired on or after October 1st = No PTO awarded in that calendar year

Employees Scheduled for Four (4) Weekday Shifts

• Hired between January 1st and March 31st = 2 PTO days

• Hired between April 1st and June 30th = 1.5 PTO days

• Hired between July 1st and September 30th = 1 PTO

• Hired on or after October 1st = No PTO awarded in that calendar year

Employees Scheduled for Three (3) Weekday Shifts

• Hired between January 1st and March 31st = 1 PTO day

• Hired between April 1st and June 30th = 6 hours of PTO day

• Hired between July 1st and September 30th = 4 hours of PTO

• Hired on or after October 1st = No PTO awarded in that calendar year

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Requesting PTO Requests for PTO must be made through an email request to the Human Resources department as far in advance as possible, but no less than ten (10) days in advance of the requested day. In emergency situations and at the discretion of CAA’s scheduling team, PTO may occasionally be used without advance approval. These situations should be rare and the result of extenuating circumstances.

In certain situations, employees may wish to request PTO for a portion of a day (versus a full day). PTO may be scheduled in half-day increments, subject to the same process and rules that apply to full-day scheduling. Employees will have one-half (1/2) day of PTO deducted for absences of up to four (4) hours of the employee’s shift. Absences of greater than four hours will have a full day of PTO deducted from the employee’s accrued PTO balance.

Employees may cancel PTO by contacting the Human Resources Department at least 24 hours in advance of the scheduled day. Notice is required to ensure that CAA can plan work coverage efficiently.

PTO Carryover Employees may carry over their accrued PTO from one year to the next, up to a maximum of ten (10) days of PTO. Requests for PTO carryover of more than 10 days must be submitted in writing to the Director of Human Resources. CAA’s Workforce Committee will ultimately make all decisions related to the approval of PTO carryover requests of more than 10 days.

Payment of PTO upon Termination of Employment or Change in Status Employees will be paid the balance of their unused, accrued PTO upon termination of their employment if appropriate notice of resignation is given. PTO may not be used in lieu of notice or to extend the employee’s termination date. Instead, termination will be deemed to have occurred on the last day worked.

If an employee resigns or is terminated having taken PTO in excess of time actually accrued, he or she will be responsible for reimbursing CAA for the excess PTO in question. Pay for the excess days will be deducted from the employee’s final paycheck.

Employees whose employment status changes from Full-Time to Flex Pool will be paid for their unused, accrued PTO balances.

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Professional Development Expense Policy

CAA is committed to the continuing education and development of its employees. In that regard, CAA provides active, full-time and part-time employees with a Professional Development Expense Fund, to provide for reimbursement of expenses related to Continuing Medical Education for the employee, professional fees and licenses, and eligible business expenses incurred by the employee and related to their work at CAA. CAA adheres to IRS guidelines regarding the approval and handling of submitted expenses, and corroborating receipts will be required prior to processing reimbursement of these expenses. Employees who require additional information on the program should contact Human Resources for additional details.

401(k) Profit Sharing Plan

CAA’s 401(k) Profit Sharing Plan offers eligible employees a powerful way to invest in their long-term financial well-being. We encourage all employees to invest in themselves and their future by participating in this plan. Employees may contribute to the plan through either pre-tax or after-tax payroll deductions. CAA may also make a discretionary non-elective Profit Sharing contribution to eligible employees’ accounts on a periodic basis.

Vesting refers to employees’ “ownership” in the funds in their account. Employees are always 100% vested in the contributions they make to the plan, including any rollover or transfer contributions that have been made, and any earnings on their contributions. CAA employees become 100% vested in employer contributions to their account after three (3) years of service, subject to plan requirements. For additional information on this plan, contact CAA’s Director of Human Resources.

Unemployment Insurance

All employees are eligible to apply for unemployment compensation benefits in the event they are separated from service with CAA. The Virginia Employment Commission will determine the employee’s eligibility to receive these benefits. The entire cost of this benefit is paid by CAA.

Vacation Policy

CAA believes that every employee needs time away from work to rest and relax. This policy is designed to provide employees with time away from work for vacations and continuing education pursuits. All full-time and part-time employees will be paid their regular salary for approved vacation time taken during the calendar year. It is important to note that for the purposes of premium pay and overtime calculations, vacation is not considered “time worked”.

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Vacation Accrual Vacation accrual is managed through CAA’s web-based timekeeping system. A Year of Service for vacation accrual purposes is calculated as the period between an individual’s date of hire (i.e., his or her start date) and that same date, the following year.

Vacation accruals will be reviewed on a quarterly basis by the Human Resources Department to ensure that each employee is accruing vacation time at a rate commensurate with the individual’s expected accrual, relative to his or her Years of Service with the Company. All employees are encouraged to self-monitor vacation accrual and usage via CAA’s web-based timekeeping system and the CAA Provider Scheduling System, and to report discrepancies as quickly as possible to the Human Resources Department, so that they may be investigated and resolved.

No vacation will accrue for new employees who begin employment with CAA during the months of November or December. Vacation accrual will begin January 1st of the following calendar year for these employees.

Vacation time will continue to accrue during periods of military leave and jury duty that do not exceed 60 calendar days. Vacation time will not accrue during periods of unpaid leave of absence, FMLA, Short-Term Disability, Long-Term Disability, and Workers’ Compensation related absences, if these periods extend beyond 30 calendar days.

Vacation Allowance Schedules Vacation allowances are for the most part dependent on Years of Service with the Company. All new employees receive a copy of their specific Vacation Policy as part of the new employee orientation process. During the first calendar year of employment, vacation allowances are pro-rated based on the employee’s date of hire, as outlined in their vacation allowance schedule.

Vacation Allowances for Rehired CRNAs and Physicians CRNAs and physicians with previous Commonwealth Anesthesia Associates service who return to CAA may have a portion of their previous period of employment credited as service, for vacation allowance calculation purposes. The amount of service credited will be calculated as follows:

• If the employee is rehired within 12 months of the break in service, all service is restored from the original date of hire through the rehire date (including the time away from CAA).

• If the employee is rehired after 12 months but within five (5) years of the break in service, the employee receives credit from the original date of hire up to the date of the break in service. This credit does not include credit for the time away from CAA.

• If the employee is rehired more than five (5) years after the break in service, no service credit for prior employment with CAA will be granted.

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Vacation Selection Process For the most part, vacation time will be selected in one-week increments during the fall of each year, for vacation allowances available the following year. Employees will be awarded their preferred weeks of vacation based on seniority and the availability of the week on CAA’s Master Provider Schedule. Employees are required to actively participate in the Vacation Selection process and adhere to all the conditions and timeframes established within that protocol. Failure to adhere to these conditions may result in the employee being “passed” in the process, enabling CAA to move on with the Vacation Selection process to the individual with the next highest level of seniority.

Vacation Taken during a Holiday Week Physicians and CRNAs who choose to select a vacation week during a week containing a Company-recognized holiday should be aware that they will be using five (5) vacation days during that week off, not four (4) vacation days. Employees who work a partial week containing a Company-recognized holiday must work three (3) days of the week to avoid using a vacation day for the actual holiday. Employees who work two (2) or fewer days of a holiday week will use a vacation day for the holiday. Employees who select a vacation week containing a Company-recognized holiday may not subsequently change their selection and request to work part of that holiday week until the entire Vacation Selection process has been completed.

Vacation Carryover All employees are encouraged to take their vacation during the year the vacation time is accrued. Employees may carry over their accrued vacation from one year to the next, up to a maximum of ten (10) days of vacation. Requests for vacation carryover of more than 10 days must be submitted in writing to the Director of Human Resources. CAA’s Workforce Committee will ultimately make all decisions related to the approval of vacation carryover requests of more than 10 days.

Selling Vacation Days CAA employees may sell up to five (5) vacation days per year back to the Company, based on their daily pay rate in effect at the time. An employees’ daily pay rate is determined through the following calculation:

Salaried Employees: Daily Pay Rate = Bi-Weekly Pay Rate divided by 10 (business days)

Hourly Employees:

Daily Pay Rate = Hourly Rate of Pay x 8 (hours)

Vacation may only be sold during the month of November. Employees wishing to sell back vacation days must send a written request to the Human Resources Department.

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Vacation Pay upon Termination of Employment or Change in Status Employees will be paid the balance of their unused, accrued vacation allowance upon termination of their employment if appropriate notice of resignation is given. To accrue vacation time for the month in which the employee terminates, the employee must work the last workday of that month. Vacation time may not be used in lieu of notice or to extend the employee’s date of termination. Instead, termination will be deemed to have occurred on the last day worked. An exception to this guideline will be granted if the last working day of the month is a Company-recognized holiday.

If an employee resigns or is terminated having taken vacation days in excess of vacation time actually accrued, he or she will be responsible for reimbursing CAA for the excess days in question. Pay for the excess days will be deducted from the employee’s final paycheck and will be calculated using the Daily Rate of Pay calculation noted above.

Employees whose employment status changes from Full-Time to Flex Pool will be paid for their unused, accrued vacation balance through this same methodology. Physicians and CRNAs whose employment status changes from Per Diem to either full-time or part-time will receive credit for prior service as it relates to the seniority list used during the vacation selection process. However, these Physicians and CRNAs must work on a full-time or part-time basis and meet the years of service requirements outlined in the appropriate Vacation Allowance Schedule prior to being awarded additional vacation time.

Policy Administration CAA’s Vacation Policy is administered by the Human Resources Department, in coordination with Chiefs of Anesthesia and CAA’s Workforce Committee. All questions related to this policy should be directed to the Human Resources Department.

Workers’ Compensation

All CAA employees are covered by Workers’ Compensation insurance, which provides for payment of medical expenses and for partial salary continuation in the event of a work-related accident or illness. The amount of benefits payable and the duration of the payment depend on the nature of the employee’s illness or injury. In general, however, medical expenses incurred relating to a work-related injury or illness are paid in full and partial salary payments will be made through CAA’s Workers’ Compensation insurance carrier, once the claim has been approved by the carrier. Employees are required to use accrued vacation and/or PTO for wage continuation during the elimination period for a lost-time Workers’ Compensation claim. FMLA runs concurrent with any leave associated with a Workers’ Compensation injury or illness; please refer to the Family Medical Leave Act section of this Handbook for additional details.

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Employees who are injured or become ill while at work must immediately report their injury or illness to their Chief of Anesthesia or Attending Anesthesiologist, and to the Human Resources Department. This ensures that CAA can assist the employee in obtaining appropriate medical treatment. Failure to follow this procedure may result in a failure to file Workers’ Compensation claim forms with CAA’s insurance carrier, which may in turn jeopardize the employee’s right to benefits relating to the injury or illness.

Employees may not be actively employed elsewhere while on leave associated with a Workers’ Compensation injury or illness. Questions regarding Workers’ Compensation claims should be directed to Human Resources.

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HUMAN RESOURCES PRACTICES

Employment of Family Members

Employment References & Wage Verifications

Exit Interviews

Health & Safety

Immigration Reform & Control Act

Inclement Weather

Open Door Policy

Ownership of Work Product

Performance Management

Personal Vehicles

Personnel Files

Romantic Relationships

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Employment of Family Members

CAA permits the employment of qualified relatives of employees if the employment does not, in the opinion of the Company, create actual or perceived conflicts of interest. For purposes of this policy, “relative” is defined as: spouse or qualified domestic partner, child, parent, sibling, grandparent, grandchild, and corresponding in-law and “step” relations.

CAA will exercise sound business judgment in the placement of related employees in accordance with the following guidelines:

• Family members are permitted to work in the same Company facility, provided no direct reporting relationship exists. That is, no employee is permitted to work within the” chain of command” of a relative such that the other relative could influence one relative’s work responsibilities or career progress. The Company reserves the right to make an exception to this in cases where it deems it is in the best interest of the business to allow such a reporting relationship.

• Employees who marry while employed will be treated in accordance with these guidelines. If, in the opinion of the Company, a conflict or an apparent conflict arises because of the marriage, one of the employees may be transferred at the earliest practical time.

• This policy applies to all categories of employment, including Full-Time, Part-Time, and Flex Pool.

Employment References & Wage Verification

Current and former employees who require employment and wage verifications should contact Human Resources. A signed release with the employee’s written authorization to comply with the request is required prior to the completion of employment or wage verifications. Only Human Resources staff members are authorized to respond to these inquiries.

Upon receipt of a valid authorization, Human Resources will verify employment to the extent of confirming dates of employment and position held. Requests for employment verifications with financial information, such as for credit applications or mortgage applications, will only be processed with an employee’s written authorization for release of the information to that specific institution or business.

Apart from matters related to credentialing and facility privileges for current employees, CAA does not provide letters of reference for either current or former employees. Please forward all reference requests to the Director of Human Resources for handling.

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Exit Interviews

CAA respects the opinion of our employees regarding their job-related experiences. An exit interview offers an employee the opportunity to share any information that he or she feels may help CAA to improve its day-to-day operations. At the time of separation, separating employees may be provided a web-based Exit Interview Questionnaire. A follow-up phone call or face-to-face meeting with the Director of Human Resources may also be coordinated.

Health and Safety

CAA takes extensive measures to ensure the safety of its employees and patients. Employees are expected to comply with all policies and practices created by the Company, hospital facilities, and regulatory agencies as it relates to employee and patient safety, and to exercise the appropriate standard of care at all times. In addition, employees are expected to use common sense in avoiding unsafe situations and to recognize and report any hazardous or unsafe working condition.

An employee who becomes ill or is injured on the job, regardless of the severity of the injury, is required to report the injury immediately to his or her Chief of Anesthesia and to Human Resources. Copies of incident report forms may be found in CAA anesthesia offices at each CAA site or on the CAA intranet. These forms should be completed as soon as possible and forwarded to Human Resources for handling.

Immigration Reform and Control Act

CAA is committed to employing only United States citizens and aliens who are legally authorized to work in the United States. The Company does not unlawfully discriminate on the basis of national origin or citizenship status.

In compliance with the Immigration Reform and Control Act of 1986, every new employee, as a condition of employment, must complete the Employment Eligibility Verification Form I-9, and must present documentation establishing identity and employment eligibility within three (3) business days from the date of employment with CAA. In addition, CAA utilizes e-Verify, an internet-based program run by the Federal government, to compare information provided on the I-9 form to government records, and to confirm employee eligibility to work in the United States.

Former employees who are rehired must also complete the form if they have not completed an I-9 with CAA within the past three (3) years or if their previous I-9 form is not on file or is invalid.

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Inclement Weather

CAA considers every position to be essential; therefore, it is important that all employees report to work as scheduled during inclement weather. In the event of a severe weather situation, CAA staff will follow the operational policies for the specific facility that they are assigned to work at that day. Depending on needs at various CAA sites, staff should be aware that they may be assigned to work at an alternate site on an inclement weather day, should OR needs require it.

Open Door Policy

CAA believes in a free and open atmosphere, and believes that open lines of communication and mutual respect among all staff is necessary to be efficient and effective. When an employee has a concern or question, his or her Chief of Anesthesia is often the best person to handle the problem or answer the question. Chiefs should address employee concerns as promptly as possible after seeking an understanding of the issue at hand and the employee’s personal viewpoint.

If the Chief of Anesthesia is unable to resolve a problem to the employees’ satisfaction, or if the question or concern is related to payroll or employee benefits, the employee should contact a member of the Human Resources Department for assistance.

Ownership of Work Product

Work Product is defined as all copyrights, patents, trade secrets, trademarks, service marks, or other intellectual property or proprietary rights associated with any ideas, concepts, techniques, inventions, processes, or works of authorship developed or created by any employee of the Company during the course of performing work for the Company. All such Work Product will belong exclusively to the Company and will, to the extent possible, be considered a work made for hire within the meaning of Title 17 of the United States Code. Publication of any such Work Product requires prior written consent of the CAA Board of Directors and should prominently reference Commonwealth Anesthesia Associates’ name.

If an employee wishes to create or develop, other than on the Company’s time or using CAA resources, anything that may be considered Work Product but to which an employee believes he or she should be entitled to the personal benefit of, the employee must seek approval from the CAA Board of Directors, as follows:

• Before beginning any such work, an employee must give the Company advance written notice and provide the CAA Board of Directors with a written description of the work under consideration. The CAA Board of Directors will consider the employee’s request at a regularly scheduled Board meeting, and decide as to whether rights in such work will be claimed by CAA, or may be claimed personally by the employee.

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• The decision of whether such work is the property of the Company shall be at the sole discretion of the CAA Board of Directors. If the CAA Board decides that it does not claim rights in such work, the Board will notify the employee in writing and the employee may retain ownership of the work to the extent that such work has been expressly disclosed to the Company. The employee must submit for further review any significant improvement, modification, or adaptation so that it can be determined whether the improvement, modification, or adaptation relates to the business or interests of the Company.

Performance Management

High quality patient care and outstanding service at the facilities that we serve are primary goals at CAA. Service-focused employees build patient satisfaction, and providing superior service is a key factor in an employee’s success with CAA.

The Performance Management Process encourages communication between employees and their Chief of Anesthesia and promotes an understanding of job expectations and the employee’s performance relative to those expectations. CAA employees participate in performance reviews at periodic intervals.

This review is intended to document an employee’s performance by measuring his or her effectiveness on the job, identifying areas of strength, and discussing areas where an employee needs additional training or performance improvement.

Performance management should not be viewed as a one-time event. Rather, employees are encouraged to seek feedback from their Chief of Anesthesia, other Attending Anesthesiologists, CRNAs and their peers. Employees are also encouraged to express their opinions about their performance in the form of comments added to their performance review form. Questions about the performance management process should be directed to Human Resources.

Personal Vehicles

CAA recognizes that the use of an employee’s personal vehicle may occasionally be necessary in the performance of one’s job duties. CAA’s insurance policy does not cover incidents that may occur while driving one’s personal vehicle. The reimbursement that an employee receives for mileage covers all costs associated with the use of a personal vehicle, including maintenance, insurance, and deductible costs. CAA reimburses business-related mileage at the mileage reimbursement rate approved by the IRS. Contact CAA’s Controller for additional information on IRS requirements regarding mileage reimbursement.

Personnel Files

CAA maintains a personnel file for each employee, which contains confidential information about the employee and other work-related documents. Separate benefits files are maintained and contain documents related to an employee’s benefit elections,

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401(k) Profit Sharing Plan participation, and disability leaves of absence and workers’ compensation claims. These files are the sole property of CAA, and contain only information that is relevant and necessary to the proper administration of business, or that is required by law or regulation. Documents related to medical records or information are kept in a confidential file separate from the employee’s other personnel information.

It is important that employee personnel files be accurate at all times. All employees have a responsibility for promptly notifying Human Resources of any change in name, home address, telephone number (home, cell and/or pager), email address, marital status, beneficiary designations, emergency contacts, or other pertinent information that is relevant and necessary to proper management of the business and employee benefit programs.

Personnel files are kept in a secure location and access is limited to the employee, Human Resources staff, the CAA Board, or other members of the CAA leadership team who have a legitimate need to review the file. An employee may review his or her personnel file in the presence of a Human Resources staff member at a time mutually convenient for both parties. Written requests for information from an employee’s personnel file should be directed to Human Resources. A reasonable copying fee may be charged.

Romantic Relationships

Consenting romantic or sexual relationships between employees, particularly Attending Anesthesiologists and CRNAs or RNs, may at some point lead to complications and significant difficulties for all concerned. This is due to the potential supervisory nature of the work relationship. Any such relationship may be contrary to the best interests of the Company because of these potential ethical and administrative problems. CAA discourages such relationships.

If a consenting romantic or sexual relationship between employees should develop, both employees have a responsibility and mandatory obligation to promptly disclose the relationship to the Director of Human Resources or CAA’s Administrator. This requirement allows the Company to take appropriate steps to ensure that no supervisory relationship exists between the employees. It also enables CAA to avoid any real or perceived conflicts of interest related to patient care or administrative activities or decisions (including, but not limited to, hiring, evaluations, compensation, work assignments, and corrective action) that may potentially reward or disadvantage an employee.

All CAA employees are expressly prohibited from participating in romantic or sexual relationships with Student Registered Nurse Anesthetists (SRNAs) who train at CAA facilities. There is an inherent conflict of interest in this relationship because CAA provides evaluations on these students to their university. Further, most universities have a policy that precludes the student from having this type of relationship, and the students’ status in their program may be jeopardized should a relationship be pursued.

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STANDARDS OF CONDUCT

CAA Code of Conduct

Attendance & Punctuality

Computer Usage Policy

Confidential Information

Conflict of Interest

Contact with News Media

Corrective Action

Criminal Charges and Convictions

Employee Privacy

Health Insurance Portability and Accountability Act (HIPAA)

Medical Billing Compliance

Personal Communication Devices

Social Media Policy

Solicitation and Distribution

Substance Abuse Policy

Violence in the Workplace

Treatment of Family Members

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CAA Code of Conduct

CAA expects employees to behave professionally at all times and to follow rules of conduct that will protect the interests and safety of all employees and CAA as an employer.

While under some circumstances CAA may initiate corrective action to address employee performance issues or conduct, it is not required to do so, and instead may decide to terminate the employment relationship. Decisions to take corrective action or terminate the employment relationship are within the sole discretion of CAA. It is not possible to list all forms of behavior that are considered unacceptable in the workplace, but the following are examples of infractions of rules of conduct that may result in corrective action, up to and potentially including termination of employment:

• Theft or inappropriate removal or possession of property

• Falsification of timekeeping records, or inaccurate reporting of time worked

• Excessive absenteeism or absence without notice

• Working under the influence of alcohol or illegal drugs

• Possession, distribution, sale, transfer, or use of alcohol or illegal drugs in the workplace, while on duty, or while operating work-related equipment

• Fighting or threatening violence in the workplace

• Boisterous or disruptive activity in the workplace

• Negligence or improper conduct leading to damage to employer-owned, facility-owned, coworker-owned, or patient-owned property

• Insubordination or other disrespectful conduct

• Covert recording of conversations

• Violation of Code of Conduct, safety, or health rules at contract facilities

• Refusal to accept medical staff assignments, or to participate in committee or required departmental meetings or events

• Failure to renew required professional licenses and/or certifications prior to expiration

• Smoking in prohibited areas

• Sexual or other unlawful harassment

• Posting or distributing obscene material or material that violates CAA’s anti-harassment policies

• Possession of dangerous or unauthorized materials, such as explosives or firearms, in the workplace

• Unauthorized absence from the workplace during the workday

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• Unauthorized use of telephones, mail system, or other employer or contract facility-owned equipment

• Unauthorized disclosure of confidential, proprietary trade secrets of the company

• Unauthorized disclosure of employee information

• Violation of patient privacy/HIPAA policy

• Violation of Company policies

• Unsatisfactory performance or conduct

Anyone who believes that a violation of CAA’s Code of Conduct has occurred is encouraged to immediately contact their Chief of Anesthesia, the Director of Human Resources, CAA’s Administrator, or the CAA Board of Directors. The situation will be promptly investigated, and corrective action will be taken consistent with CAA policy. Employees are prohibited from retaliating against anyone who makes a good faith complaint or participates in good faith in any investigation into a complaint, regardless of whether the complainant or witness is a CAA employee.

Attendance and Punctuality

CAA’s commitment to quality patient care depends on having adequate staff available at all times. Employees are expected to be at work as scheduled and ready to begin work promptly at the established time for their position. Employees in an “Out Order” may not leave their workplace without first checking with the Anesthesiologist “running the board” to confirm they have been released for the day.

When an employee takes excessive time off from work, or frequently arrives late to work or leaves early, patients, hospital staff, coworkers and productivity suffer. Unscheduled time off from work will be closely monitored to determine if these absences are excessive or if there is any notable pattern of absenteeism. As a general guideline, an employee taking more than three (3) instances of unscheduled time off in a six (6) month period is considered excessive. Employees with excessive unscheduled time off or lateness, or those who fail to follow the notification procedures outlined in this Handbook, may be subject to corrective action up to and potentially including termination of employment. In addition, base compensation may be decreased for the pay period affected by the lateness or absences.

Reporting Unexpected Absences & Late Arrivals Employees who are going to be absent or late to work for any reason must immediately contact their facility’s On-Call Anesthesiologist, or the Anesthesiologist “running the board” (depending on the time of day). The Anesthesiologist and employee must also notify the Human Resources Department of any unexpected absences, so that this time away from work may be appropriately captured in CAA’s timekeeping system.

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Failure to Report Depending on circumstances, an employee who fails to report to work as scheduled, fails to follow the notification procedures outlined in this Handbook, and/or leaves work without notice or permission prior to the end of his shift, may be considered to have abandoned his job. When this occurs, CAA will assume that the employee has voluntarily resigned his or her position with the Company. If the employee still wishes to be employed by CAA, the Company will evaluate the reason for the employee’s violation of these procedures and will decide as to whether the employee may continue employment with CAA. Corrective action will also be taken to address this policy violation.

On-Call Coverage CRNAs that are “on-call” are waiting to be engaged for work, and may go about their normal off-duty activities. There are rare situations where employees who are not formally scheduled for call are informed that, due to extenuating circumstances, they are required to carry their beeper in case their facility needs to recall them to work once they have been released for the day.

In both situations, these CRNAs must remain accessible to their designated facility within 30 minutes from the time they are contacted and informed that they are needed at work. They must not be under the influence of alcohol or any substances that affect their ability to provide safe patient care, consistent with CAA’s Substance Abuse Policy. Failure to promptly respond to a call to work, and/or failure to be ready, able, and available to work when called, is considered misconduct and will result in corrective action up to and potentially including termination of employment.

Computer Usage Policy

Technical advances are simplifying the sharing of information with others, via cellular phones, networks, email, and the Internet. These are useful tools, but these advances also dictate a need for valuable information to be protected from unwanted access, use, or disclosure.

Every CAA employee is responsible for protection of information. This applies at all times, whether an employee is using a CAA computer or accessing CAA’s systems in CAA’s office, in one of our contracted facilities, from an outside location, or while traveling.

General Use All CAA or facility-issued telephones, electronic communication devices, and computer systems, including, but not limited to, computers, laptops, iPads and tablets, servers, networks, mainframes, cell phones, and pagers are CAA property. The sole purpose of these systems is to conduct CAA business.

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• CAA systems are not to be used to solicit others for commercial ventures or religious or political causes. Users are prohibited from distributing chain letters. Further, Company systems must not be used in any way that would violate any CAA policy, including the Company’s policies against discrimination or harassment.

• Users have the responsibility to operate all work-related computer systems in a professional, lawful, and ethical manner.

• Use of electronic communications must conform to CAA’s business standards and policies, including electronic security standards and privacy policies.

• Occasional and limited use of CAA systems for personal reasons such as telephone calls, email, and limited Internet usage is permissible provided such personal use does not violate CAA policies or law, interfere with an employee’s job responsibilities or hours of work, or overburden Company resources on an individual or aggregate basis.

• The Company reserves the right to terminate an employee’s right to use Company systems for personal communications and to take further appropriate corrective action if, in the judgment and sole discretion of the Company, such personal use of Company systems is inappropriate.

• All documents and data, as well as any email, voice mail, or other form of electronic messages composed, sent, stored, and received on or over the Company’s systems are the property of the Company.

• The Company reserves the right to monitor all information systems. This includes, but is not limited to, telephone and computer systems, voice mail, websites (Internet and intranet), and email systems to prevent abuses or misuses, or for any other legitimate business reason.

• Since information technology resources are the property of the Company, users of these systems are advised that there is no expectation of privacy while using these systems.

• Use of the Company’s systems must be in compliance with all applicable laws and regulations of the United States. Compliance includes ensuring that proper licensing agreements are in effect, and that copyrights and other intellectual property rights are not being infringed. Any questions regarding these issues should be addressed to CAA’s Administrator.

• The authenticity, confidentiality, and integrity of electronic communications cannot be guaranteed, whether transmitted over the Internet or through the email or voice mail systems. Although these systems accommodate the use of security passwords and firewalls, their reliability for maintaining confidentiality cannot be guaranteed. Employees should assume that all messages might be accessed and read by someone other than the designated recipient. It should be noted that even when a message is erased, it might still be possible to recreate the message. Therefore, ultimate privacy of messages cannot be ensured.

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Internet Usage Policy Access to the Internet is provided to employees for the benefit of the organization and its customers. Every employee has a responsibility to use the Internet in a productive and professionally appropriate manner. To ensure that all employees are responsible, productive Internet users, the following guidelines have been established for using Company-provided Internet access.

• Employees using Internet access via Company hardware and software are representing the Company. As such, their conduct must be ethical and lawful at all times.

• Internet access should not be used for personal gain or advancement of personal views, for solicitation of non-Company business, or result in the disruption of the Company network operation or interfere with personal productivity at work.

• Employees are responsible for the content of all text, audio, or images they place or send over the Internet. Fraudulent, harassing, or obscene messages are prohibited. Employees may not obscure the origin of messages, and the information published should not violate or infringe upon the rights of others.

• Employees may not download software to a CAA or contract facility computer without the express acknowledgement and support of CAA IT to ensure that proper licenses are obtained and viruses are not transmitted.

• Employees may not send/upload Company copyrighted materials, trade secrets, or confidential proprietary information to third parties. Employees may not violate copyright laws regarding receipt/download of materials available on the Internet by copying and disseminating information, except for purposes falling under the category of “fair use.”

• Care should be exercised when posting messages to bulletin boards, as these messages may be easily searched by competitors or hackers to gather information about the Company and its computer network and systems.

• Harassment of any kind is strictly prohibited. Messages with derogatory or inflammatory remarks regarding race, religion, national origin, sexual orientation, or other protected attributes may not be transmitted.

• Violations of the Computer Usage Policy may result in corrective action up to and potentially including termination of employment, and illegal activities may result in prosecution by legal authorities.

• Limited personal use of the Internet is allowed by CAA. However, the employee is reminded that use of any and all CAA property is primarily for CAA business. Any personal use of the Internet must not interfere with the employee's job responsibilities.

• Inappropriate use of Internet access is strictly prohibited and includes, but is not limited to, sites publishing pornographic or otherwise explicit sexual material, gambling, computer hacking, or the promotion of hatred or violence.

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• CAA’s server logs Internet usage and a report of an employee's activity will be available to Human Resources upon request when investigating possible incidents of misuse or abuse.

Confidential Information

CAA will maintain the confidentiality of “protected health information” as defined by HIPAA (“PHI”) and/or other sensitive or private information involving patients, employees, students, donors, research, or proprietary information about financial and business plans and operations (collectively, “Confidential Information”). Confidential information may be information in any form – written, electronic, oral, overheard, or observed.

During an employee’s daily work, he or she may be exposed to PHI or Confidential Information. This information should not be discussed with anyone, including other patients, coworkers, other families, your family and friends. Employees must always be alert to others overhearing their professional discussions regarding a patient’s condition.

Employees are prohibited, during and subsequent to their employment with the Company, regardless of whether such employment terminates voluntarily or involuntarily, from using, divulging, disclosing, or communicating to any person, firm, or corporation, in any manner whatsoever, any PHI or Confidential Information except as necessary to provide patient care and subject to applicable law. Further, upon termination of employment, the employee is required to return all Confidential Information and/or company property in his or her possession to the Company.

If an employee is ordered to disclose any Confidential Information, whether in a legal or a regulatory proceeding or otherwise, the employee must provide CAA with prompt written notice of such request or order unless such notification would violate the law. Employees with questions about this policy are encouraged to contact CAA’s Administrator or CAA’s Administrative Compliance Officer. Violations of this policy may result in corrective action, up to and potentially including termination of employment.

Conflict of Interest

CAA employees must avoid even the appearance of any impropriety or conflict of interest. Employees may not accept gifts or favors from anyone with whom the Company does business or from anyone who the Company is attempting to do business with. This includes, but is not limited to, patients, hospital personnel, vendors, and representatives from any pharmaceutical or medical supply company.

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Questions about whether a situation may violate this policy should be directed to CAA’s Administrator before such favors or gifts are accepted by the employee. In addition, CAA employees must advise the CAA Board of Directors of any board memberships or hospital committee appointments prior to accepting such commitments. Violations of this policy may result in corrective action, up to and potentially including termination of employment.

Contact with News Media

At times, CAA employees may be contacted by the media (television, radio, print reporter, social media blogger) regarding work related matters – either related to CAA or related to the facilities in which CAA provides services. Employees should direct the reporter to CAA’s Administrator for handling, and advise the reporter that a Company official will respond as soon as possible. No one other than CAA’s Administrator, or a designated member of the CAA Board of Directors in his absence, is authorized to represent CAA in media inquiries.

Employees should secure the following information from the reporter and provide it to CAA’s Administrator as soon as possible following the inquiry:

• The reporter’s name

• The name of the organization that he or she represents

• His or her telephone number and email address

• The location and details of the inquiry

• The caller’s deadline, if one exists

Corrective Action Process

Appropriate behavior and strong job performance are critical to individual and collective success at CAA. Unacceptable behavior or work performance will not be tolerated. CAA’s Corrective Action Process has been designed to be consistent and equitable based on the facts and circumstances available.

The Corrective Action Process provides employees with feedback that they need regarding deficiencies in their behavior and/or job performance, so that they may improve in these areas and become valuable members of CAA’s clinical team. An employee’s ability to professionally receive and respond to feedback received during the Corrective Action Process is critical to performance improvement.

Corrective action may be communicated either verbally or in writing, depending on the severity of the situation and, at CAA’s discretion, may result in an administrative leave of absence with or without pay. Generally, the employee’s Chief of Anesthesia will inform the employee when corrective action is being initiated, although it may be initiated by other members of CAA’s leadership team, CAA’s Administrator, or the Director of Human Resources.

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This Corrective Action Process is a guide, and may include multiple steps, each progressively more serious depending on the situation. Each situation will be evaluated on its own merits. Depending on the severity of the situation, as determined by CAA, it may become necessary to accelerate the Corrective Action Process, or to skip one or more steps in the process. Notwithstanding the availability of various corrective action options, employment is at-will and the Company reserves the right to discharge an employee at its discretion, with or without notice.

CAA’s Corrective Action Process may include:

• Verbal Counseling

• Formal Written Warning

• Probation

• Termination

Employees with an Employment Agreement with the Company will be terminated and/or have corrective action initiated in a manner that is consistent with the terms of their Employment Agreement and the processes outlined in this Employee Handbook.

Criminal Charges and Convictions

The nature of CAA’s business and our responsibility as healthcare providers in the communities we serve mandate that employees abstain from all criminal activity. Any criminal activity committed during or after working hours is expressly prohibited. An employee who is arrested and/or charged with any crime, excluding minor traffic violations, must report the arrest or charge to CAA’s Administrator or Director of Human Resources within 24 hours of the arrest or charge. The employee will be asked to provide detailed information about the criminal charge and the timeframe for resolution. This information will be shared with the CAA Board of Directors.

Depending on the circumstances and conduct underlying the charge or arrest, and the timeframe for resolution, the CAA Board of Directors may elect to allow the employee to return to work, or to place the employee on unpaid administrative leave of absence, or to terminate the employee while the charge is pending. Any criminal convictions while employed by CAA must be reported to CAA’s Administrator or the Director of Human Resources within 24 hours of the conviction. Failure to report criminal charges or arrests, or a conviction, will result in corrective action, up to and potentially including termination of employment.

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Employee Privacy

Employees should have no expectation of privacy with respect to CAA and contract facility property. CAA and contract facility property is subject to search at any time and at the discretion of CAA. Searches of CAA and contract facility property may include, but are not limited to, vehicles, computers, files, lockers, containers, desks, or offices.

Searches of an employee’s personal property may be conducted to investigate violations of workplace policies or for any other business-related purpose. CAA may search personal property that is on CAA or contract facility premises. Searches of personal property may include, but are not limited to, vehicles, purses, briefcases, backpacks, and packages.

Searches conducted by CAA, or its designated agents, will be conducted in a reasonable manner. Refusal to consent to a search may result in corrective action, up to and potentially including termination of employment.

Health Insurance Portability and Accountability Act (HIPAA)

The Health Insurance Portability and Accountability Act of 1996 (HIPAA) is a federal law that applies to health plans, health care providers, and health care clearinghouses. The HIPAA legislation is complex and has many components. The three areas of legislation that are the major focus for CAA are:

• Privacy – provides rules regarding how an individual’s health information may be used and disclosed.

• Transaction and Code Sets – requires the use of standard transaction formats and code sets when an individual’s financial health information is transmitted electronically.

• Security – requires specific security measures to be in place to protect an individual’s health information that is sent or stored electronically.

All new CAA employees are required to complete HIPAA training within five (5) business days of their date of hire, as well as periodic refresher training as deemed appropriate by the Company. This training provides the employee with a HIPAA overview and outlines their responsibilities as health care providers. Violations of HIPAA are extremely serious and may result in corrective action, up to and potentially including termination of employment.

As a protection for employees, HIPAA limits the circumstances under which coverage may be excluded for medical conditions present prior to enrollment in health coverage. Full details on these provisions are available in the Summary Plan Descriptions and formal plan documents for CAA’s medical and dental insurance programs.

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Medical Billing Compliance

Commonwealth Anesthesia Associates must meet high standards for ethical and legal conduct. This is not only required from a regulatory perspective, but also makes good business sense. CAA’s reputation for integrity in all its business dealings is essential to continued success. This commitment to lawful and ethical business practices is a key concept reflected in our Mission Statement.

To help meet these important objectives, CAA has developed a Medical Billing Compliance Plan and a Compliance Hotline ([email protected], 804-461-3883). The plan provides a framework to promote the prevention, detection, and resolution of personal and business conduct that is illegal or that does not conform to CAA’s high ethical standards. One important role of the program is continuous education and making all employees aware of the important standards that CAA has established for personal and business conduct. An effective Compliance Plan requires help and cooperation from all employees. Employees who are not committed to strong ethical practice management concepts have no place in our organization.

Personal Communication Devices

CAA employees are expected to exercise professionalism regarding the use of personal cell phones, laptops, iPads, personal headsets or Bluetooth devices, and other electronic communication devices while at work. Excessive use of personal communication devices for non-work-related purposes can interfere with patient safety and productivity, and can be distracting to others. CAA has therefore established the following policy for the use of personal communication devices in the workplace:

• The use of cell phones or other electronic devices for personal phone calls, text messages, or accessing the Internet for non-work-related purposes is strictly limited to times when the employee is not involved in direct patient care.

• Cell phones may not be used by employees for personal business or social networking purposes while in clinical areas including the OR, pre-op, and post-op areas. Personal phones must be turned off or set to vibrate when the employee is not on an approved break or meal period, unless the phone is being used for work communication purposes.

• Wearing of personal headsets or Bluetooth devices for non-work-related purposes is not permitted while at work.

• The use of camera phones or other audio or video recording capable devices within the workplace may violate patient privacy, and may also result in HIPAA violations. The use of personal cameras or other recording devices in patient or clinical work areas is therefore strictly prohibited. Streaming of non-work-related videos in the workplace is also not permitted.

• Employees who choose to bring personal communication devices to the workplace assume full liability in the event of theft or physical damage to the device.

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It is important to note that contract facilities may have their own policy related to personal communication devices. CAA employees are expected to familiarize themselves with those policies and adhere to them. Violations of this policy may result in corrective action, up to and potentially including termination of employment.

Social Media

In today’s world of “cyber” communications and virtual communities, employees frequently use social media to connect with colleagues and network with coworkers. CAA condones these behaviors if the employee acts in a professional manner and follows rules of conduct that will protect the interests and safety of all employees, patients, CAA client facilities, and CAA as an employer.

As a member of the CAA team, everything you say or do in a social media setting may connect back to the Company or its patients and clients.

The same principles and guidelines found in other CAA policies apply to your activities online. Ultimately, you are solely responsible for what you post online. Before creating online content, consider some of the risks and rewards that are involved. Keep in mind that any of your conduct that adversely affects your job performance or the performance of your coworkers, or adversely affects the Company or its patients or clients, may result in corrective action up to and potentially including termination of employment.

• Know and follow the rules.

Carefully read these guidelines and other CAA Standards of Conduct, including the Confidential Information and HIPAA policies, and CAA’s policies against Sexual Harassment and Other Unlawful Harassment, and ensure your postings are consistent with these policies. Inappropriate postings that may include discriminatory remarks, harassment, and threats of violence or similar inappropriate or unlawful conduct will not be tolerated and may subject you to corrective action, up to and potentially including termination of employment.

• Be respectful.

Always be fair and courteous to coworkers and CAA patients and clients. Also, keep in mind that you are more likely to resolve work-related complaints by speaking directly with your coworkers than by posting complaints to a social media outlet. Avoid using statements, photographs, video or audio that disparage CAA employees, patients or clients, or that might constitute harassment or bullying. Examples of such conduct might include offensive posts meant to intentionally harm someone’s reputation or posts that could contribute to a hostile work environment on the basis of race, sex, disability, religion or any other status protected by law or company policy.

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• Be honest and accurate.

Make sure you are always honest and accurate when posting information or news, and if you make a mistake, correct it quickly. Be open about any previous posts that you have altered. Remember that the Internet archives almost everything; therefore, even deleted postings can be searched. Never post any information or rumors that you know to be false about CAA, CAA employees, or CAA patients or clients.

• Post only appropriate and respectful content.

Maintain the confidentiality of CAA’s trade secrets and private or confidential information. Trade secrets may include information regarding the development of systems, processes, products, know-how and technology. Do not post internal reports, policies, procedures or other internal business-related confidential communications.

• Respect financial disclosure laws.

It is illegal to communicate or a give a “tip” on inside information to others so that they may buy or sell stocks or securities.

• Make it clear that you do not speak for CAA.

Do not create a link from your blog, website, or other social networking site to the CAA website without identifying yourself as a CAA employee. Express only your personal opinions. Never represent yourself as a spokesperson for CAA. If CAA is a subject of the content you are creating, be clear and open about the fact that you are an employee, and make it clear that your views do not represent those of CAA, its employees, or its patients or clients. If you do publish a blog or post online related to the work you do or subjects associated with CAA, make it clear that you are not speaking on behalf of CAA. It is best to include a disclaimer such as “The postings on this site are my own and do not necessarily reflect the views of CAA.”

• Using social media at work.

Refrain from using social media while on work time or on equipment that CAA provides. Do not use CAA email addresses to register on social networks, blogs or other online tools utilized for personal use.

• Retaliation is prohibited.

CAA prohibits taking negative action against any employee for reporting a possible deviation from this policy or from cooperating in an investigation. Any employee who retaliates against another employee for reporting a possible deviation from this policy or for cooperating in an investigation will be subject to corrective action, up to and potentially including termination of employment.

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Anyone who believes that a violation of these standards has occurred is encouraged to immediately contact the Director of Human Resources, or CAA’s Administrator. The situation will be promptly investigated and corrective action will be taken consistent with CAA policy.

For more information on using social media responsibly, refer to the following sections of this Handbook: “Code of Conduct,” “Contact with News Media,” “Confidential Information,” and “HIPAA.” Questions about this policy may be forwarded to the Human Resources.

Solicitation and Distribution

Individuals not employed by CAA are not permitted to solicit CAA employees, distribute or post materials or electronic announcements on Company premises, or utilize CAA facility property at any time except on matters related to the Company’s business, including, but not limited to, Company-subsidized programs and charitable or community activities supported by CAA. Anyone seeking permission to solicit CAA employees or utilize its premises or property in accordance with these limitations must submit, in advance, a written request for approval to Human Resources. The Director of Human Resources and the CAA Board of Directors have the authority to determine compliance with this policy.

CAA recognizes that employees may have interests in events and organizations outside the workplace. However, employees are not permitted to solicit for any purpose during the working time of either employee involved in the solicitation. Additionally, employees may not distribute materials of any kind in working areas or during the working time of any of the employees involved. For purposes of this policy, working time does not include authorized breaks or meal periods, and those times before and after work is designated to begin or end.

Questions about this policy should be directed to Human Resources.

Substance Abuse Policy

CAA’s Substance Abuse Policy provides employees with a safe, drug-free workplace and promotes the highest standards of employee health and patient safety. This policy is also designed to comply with all applicable governmental regulations, to protect the Company’s reputation and property, and to protect the safety of the public.

Policy CAA will maintain a work environment free from substance abuse and its effects and will comply with applicable federal and state laws and regulations.

CAA requires all employees to report for work and remain in condition to perform their duties free from any influence of alcohol or drugs, illegal or legal. The unlawful distribution, dispensation, possession, transfer, sale, manufacture, or use of a controlled substance or alcohol while on the job or on Company or contract facility premises,

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including during meal periods and breaks, is absolutely prohibited. Violation of this policy may result in corrective action, up to and potentially including termination of employment. Depending on the circumstances, it may also result in referral to the appropriate law enforcement agency.

Employees must notify CAA of any criminal drug statute arrest, charge and/or conviction within 24 hours of the event. CAA will act after considering the best interest of CAA patients and the Company, and as required by law.

CAA encourages any employee who feels that he or she has a problem with substance abuse to come forward with the problem prior to violating this policy.

All employees must comply with this policy as a condition of employment. CAA reserves the right to modify this policy, as well as practices and procedures relating to the policy, at any time.

Policy Guidelines With these basic objectives in mind, CAA has established the following guidelines:

• Illegal Drugs

Illegal use, possession, presence in the body, distribution, or sale of drugs (including marijuana) on Company property, in contract facilities, or on Company business is prohibited. The illegal off-duty use, possession, distribution, or sale of drugs (including marijuana) is also prohibited. No one will report or return to work under the influence of any illegal drug. Any employee reporting to work or returning to work with a detectable presence of any illegal drug may be subject to termination of employment, even for the first offense.

• Legal Drugs

The abuse of legal or prescription drugs which could have an adverse effect on an employee’s ability to perform his or her duties in any way is prohibited. This includes drug use which could impact the safety of co-workers or other people, the employee’s job performance, or the safety or efficiency of CAA operations. Violation of this guideline will result in the immediate removal of the employee from the workplace, and the employee will be subject to corrective action up to and potentially including termination of employment.

Employees who are taking prescription or over-the-counter medications which may result in side effects such as, but not limited to, drowsiness, may be asked to provide a statement reflecting their physician’s permission to engage in work. No prescription drugs shall be brought onto Company premises by any person other than the person for whom the drug is prescribed by a licensed medical practitioner, and such drug shall be used only in the manner, combination, and quantity prescribed.

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• Alcoholic Beverages

No employee will use, possess, or distribute alcoholic beverages on the job. No employee will report to work or return to work within four (4) hours after using alcohol or while under the influence of alcoholic beverages. Employees in violation of this policy will be removed from the workplace and subject to corrective action up to and potentially including termination of employment. No employee required to take a “for cause” alcohol test shall use alcohol within eight (8) hours following the incident that prompted the decision to test, or until he or she undergoes the “for cause” alcohol test, whichever occurs first.

Substance Abuse Screening CAA has appointed a Medical Compliance Officer to oversee its’ drug and alcohol screening program and review reports of individual drug tests as needed. In general, required screening is at CAA’s expense. A signed consent to pre-employment and for cause, post-employment screening is required prior to consideration for employment and continued employment. Refusal to provide such consent or refusal to submit to a timely alcohol or drug screen under any of the following conditions will be treated as having a positive test and will result in revocation of an applicant’s conditional offer of employment or, for a current employee, will result in termination of employment. Confirmatory tests will be performed on all positive, for cause, post-employment tests. Employees will have the opportunity to discuss a positive test result and clarify if a prescribed medication was involved.

• Pre-Employment

All applicants will be required to sign a consent release form authorizing a drug screening test and submission of the results to CAA. Applicants who refuse to sign the consent form or who show traces of drugs on their post-conditional offer test will not be considered for employment.

• For Cause, Post-Employment

An employee whose actions, behavior, or job performance gives rise to suspicion of alcohol misuse or substance abuse will be screened. Employees will be placed on a paid administrative leave of absence, pending the results of tests and a leadership decision as to next steps.

Testing for drugs other than alcohol will be by urinalysis, using established standards. All post-employment tests will be confirmed according to established standards prior to any action by CAA. Testing will be aimed at threshold levels for use of: cocaine; amphetamines; marijuana; opiates/morphine; phencyclidine; benzodiazepine; barbiturates; methadone; methaqualone; propoxyphene; oxycodone; and methylenedioxy-methamphetmine (MDMA), as well as any other drug for which there is reasonable suspicion of use.

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Testing for alcohol will be by breath or blood analysis. A positive breath analysis will be confirmed by another breath analysis device prior to any action by CAA. Following a positive breath analysis, an employee may request a further confirmation through a gas chromatographic analysis of blood.

All offers of employment to applicants are conditional upon the successful completion of a pre-employment drug test. CAA will notify an applicant of the results of this test, provided the applicant requests such results within 60 days of being notified of the disposition of the employment offer. In the event of a positive test result, CAA will notify the employee of the results of a “for cause”, post-employment test, and the substance that was discovered.

CAA’s Medical Compliance Officer will review all positive drug tests. Any employee who tests positive for drugs will be given an opportunity to appeal to the Medical Compliance Officer.

Procedures Following Positive Drug and Alcohol Tests Any employee who tests positive for illegal drugs, controlled substances not prescribed under the care of a physician, or alcohol will be subject to corrective action, up to and potentially including termination of employment. Employees who have not tested positive on a drug or alcohol test may voluntarily request a leave of absence for drug or alcohol rehabilitation. Such employee may be granted an unpaid administrative leave of absence when it is deemed to be in the best interest of CAA and its patients. Successful completion of a rehabilitation program approved by management will be a condition of continued employment. Once the employee has successfully completed the program, they may petition the CAA Board of Directors for permission to return to active duty. Should their request be granted, periodic unannounced follow-up testing will be required for a period of 60 months following their return to work. Any positive test during the 60-month period or thereafter will result in termination.

This policy is not to be interpreted as constituting any waiver of CAA’s responsibility to manage performance or right to invoke corrective action in the case of misconduct which may result from, or be associated with, the use of alcohol or drugs.

Failure to comply with any portion of this Substance Abuse Policy will result in termination of employment.

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Violence in the Workplace

CAA expects all employees to enjoy a safe workplace free from violence, threats, or intimidation. CAA does not tolerate any type of workplace violence committed by or against employees. Employees are prohibited from making threats or engaging in violent activities.

Prohibited conduct includes, but is not limited to:

• Causing, or attempting to cause, physical injury to another person

• Making threatening remarks

• Aggressive or hostile behavior that creates a reasonable fear of injury to another person or subjects another individual to emotional distress

• Intentionally damaging employer property or property of another employee, patient, or client

• Possession of a weapon and/or ammunition at the workplace or while on Company business

• Committing acts motivated by, or related to, sexual harassment, other harassment, or domestic violence

Through the credentialing and hiring processes, Human Resources takes reasonable measures to conduct background investigations to review candidates’ backgrounds and reduce the risk of hiring individuals with a history of violent behavior.

Employees are expected to exercise good judgment and to inform Human Resources if any employee exhibits behavior that could be a sign of a potentially dangerous situation. Such behavior includes, but is not limited to:

• Discussing weapons or bringing them to the workplace

• Displaying overt signs of extreme stress, resentment, hostility, or anger

• Making threatening remarks

Threats, threatening conduct, or any other acts of aggression or violence in the workplace will not be tolerated. Any employee determined to have committed such an act will be subject to corrective action, up to and potentially including termination of employment. Employees and non-employees engaged in violent acts at CAA’s workplace will be reported to the proper law enforcement authorities.

Restraining Orders If an employee applies for or obtains a temporary or permanent protective or restraining order that specifically identifies any CAA workplace, the employee is required to notify the Director of Human Resources or CAA’s Administrator and provide a copy of appropriate documentation, so that security concerns can be considered and addressed as needed.

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Treatment of Family Members

CAA policy strictly prohibits clinical staff from providing anesthesia to their immediate family members without the advanced approval of CAA’s Chief of Anesthesia for that facility, or the CAA President. Absent such approval, this care must be provided by another member of CAA’s staff.

It is our belief that it may be difficult or impossible to establish objectivity during an immediate family members’ surgery, and therefore it is in the best interest of the patient to have care provided by another CAA employee. In addition, contract facilities have policies governing this situation, and it is important that CAA remain compliant with those policies at all times.

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ACKNOWLEDGEMENT OF RECEIPT COMMONWEALTH ANESTHESIA ASSOCIATES

EMPLOYEE HANDBOOK AND

CODE OF CONDUCT

I acknowledge that I have received access to an electronic copy of the Commonwealth Anesthesia Associates’ (CAA) Employee Handbook, as revised effective September 2017. I understand that I may request a paper copy of this Handbook. This supersedes all other versions. The information contained in this Handbook is merely a summary of the present policies, rules, and benefits of Commonwealth Anesthesia Associates. I understand that it is my responsibility to read this Handbook, and I agree to act in accord with these policies and procedures as a condition of my employment with CAA. I have read and understand the CAA Code of Conduct and I agree to act in accord with the Code of Conduct as a condition of my employment with CAA. I understand that if I have questions or concerns at any time about this Handbook or the CAA Code of Conduct, I will consult with my Chief of Anesthesia, CAA’s Administrator, the Human Resources staff, or the CAA Board of Directors for clarification. While the Company offers and intends to apply the policies, procedures, rules, and benefits described herein, they are not an offer of employment, and are not intended to guarantee employment or job security. I understand that the Employee Handbook is not a contract, express or implied, and that CAA reserves the right to make changes to the policies, procedures, and benefits contained in the Employee Handbook as it deems appropriate, and that these changes may be implemented even if they have not been communicated, reprinted, or substituted in this Handbook. I further acknowledge that the Company reserves the right in its sole discretion at any time to modify, interpret, revoke, suspend, terminate, or change any or all plans, policies, or procedures, in whole or in part, with or without advance notice. I understand that nothing contained in the Handbook may be construed as creating a promise of future benefits or a binding contract with CAA for benefits or for any other purpose.

Date: ________________________ Employee Signature: ______________________________

Print Name: ______________________________

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ACKNOWLEDGEMENT OF RECEIPT COMMONWEALTH ANESTHESIA ASSOCIATES

EQUAL EMPLOYMENT OPPORTUNITY, SEXUAL HARASSMENT, AND

OTHER UNLAWFUL HARASSMENT POLICIES

This is to acknowledge that I have received access to an electronic copy of and have read the Commonwealth Anesthesia Associates’ Anti-Harassment and Anti-Discrimination Policies. I also acknowledge that I have a responsibility to ask any questions necessary for my understanding of these policies. I understand that it is my responsibility to read these policies, and that I may request a paper copy of these policies. I agree to comply with these policies and understand that I may be asked periodically to reconfirm my understanding of my compliance. I understand that the Company requires my compliance with these policies and that my non-compliance may be grounds for corrective action, up to and potentially including termination of employment.

Date: ________________________ Employee Signature: ______________________________

Print Name: ______________________________

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ACKNOWLEDGEMENT OF RECEIPT CONFIDENTIAL INFORMATION POLICY

This is to acknowledge that I have received access to an electronic copy of and have read the Commonwealth Anesthesia Associates’ policy regarding Confidential Information. I also acknowledge that I have a responsibility to ask any questions necessary for my understanding of this policy. I understand that it is my responsibility to read this policy, and that I may request a paper copy of the policy. I agree to comply with this policy and understand that I may be asked periodically to reconfirm my understanding of my compliance. I understand that the Company requires my compliance with this policy and that my non-compliance may be grounds for corrective action, up to and potentially including termination of employment.

Date: ________________________ Employee Signature: ______________________________

Print Name: ______________________________

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ACKNOWLEDGEMENT OF RECEIPT COMPUTER USAGE POLICY

This is to acknowledge that I have received access to an electronic copy of and have read the Commonwealth Anesthesia Associates’ policy regarding Computer Usage. I also acknowledge that I have a responsibility to ask any questions necessary for my understanding of this policy. I understand that it is my responsibility to read this policy, and that I may request a paper copy of the policy. I agree to comply with this policy and understand that I may be asked periodically to reconfirm my understanding of my compliance. I understand that the Company requires my compliance with this policy and that my non-compliance may be grounds for corrective action, up to and potentially including termination of employment.

Date: ________________________ Employee Signature: ______________________________

Print Name: ______________________________

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Acknowledgement Forms - 63 -

ACKNOWLEDGEMENT OF RECEIPT SUBSTANCE ABUSE POLICY

This is to acknowledge that I have received access to an electronic copy of and have read the Commonwealth Anesthesia Associates’ policy regarding Substance Abuse. I also acknowledge that I have a responsibility to ask any questions necessary for my understanding of this policy. I understand that it is my responsibility to read this policy, and that I may request a paper copy of the policy. I agree to comply with this policy and understand that I may be asked periodically to reconfirm my understanding of my compliance. I understand that the Company requires my compliance with this policy and that my non-compliance may be grounds for corrective action, up to and potentially including termination of employment.

Date: ________________________ Employee Signature: ______________________________

Print Name: ______________________________