Related Policies and Training: PHS has implemented policies aimed at preventing the filing of false claims. Those policies include the False Claims Act Education policy (COM.PHS-E.105), the Required Training policy (HR.PHS-E.335), and the Compliance/Ethics Program (COM.PHSE.103). In addition, PHS will require that all members of the PHS workforce receive training information on these issues upon entry into a business relationship with PHS. Duty to Report: PHS requires that any workforce member having knowledge of or suspecting the existence of fraudulent activities immediately contact an immediate supervisor, the facility human resources manager, or another member of the facility management staff. Workforce members may also report fraudulent activities to Andrea Kinsley, Vice President Corporate Compliance, via telephone (505)923-8547, the Compliance Hotline (888)435-4361, or the PHS Compliance Officer email (akinsley@phs.org). Reports made to the Compliance Hotline may be made anonymously. DRUG FREE/TOBACCO FREE WORKPLACE (Revised 6/2006) PURPOSE/POLICY STATEMENT PHS wishes to ensure a drug-free workplace. We believe the use of alcohol and unlawful drugs on and off the job can have serious work related effects. The following policy is intended to help PHS maintain a drug-free environment. If a volunteer is found to be in violation of this policy, formal corrective action up to and including dismissal may occur. INTERPRETATION & GUIDELINES 1. Reporting for duty under the influence of or possession, use, sale, distribution or purchase of alcohol/illegal drugs, controlled substances or related paraphernalia on PHS property is prohibited and is a violation of this policy. Volunteers found to be in violation will be subject to the corrective action process up to and including dismissal. 2. The possession and/or consumption of alcohol on PHS premises, as part of a sponsored social event must be approved in advance by a vice president or facility administrator. Reference to the availability of alcohol should not be made in invitations or other promotional materials. TESTING FOR ALCOHOL OR DRUGS Testing for alcohol or drugs may occur in the following situations: 1. Following an occurrence in which a patient, employee, volunteer or visitor is injured and human error is suspected. 2. In situations where management has reasonable suspicion that any portion of this policy is being violated. 3. In situations outside the workplace where a volunteer is involved in possession, use, sale or distribution of controlled or illegal substances. VOLUNTEERS 1. When a staff member has reason to suspect drug-related misconduct including use, possession and/or distribution on PHS premises, use of alcohol or drugs while on duty or reporting to work under the influence of alcohol or a controlled or illegal substance, the volunteer(s) may be asked to submit to a urine and/or blood tests. Failure to consent to testing procedures will result in termination. 47 44