Drug Free/Tobacco Free Workplace

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 isbeing violated.

3. In situations outside the workplace where a volunteer is involved in possession, use, saleor 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 beasked to submit to a urine and/or blood tests. Failure to consent to testing procedures will result in termination.

2. If drug related misconduct occurs, the following guidelines should be followed by the department director or house supervisor. • Immediately secure all evidence in a safe location. • Advise the Volunteer Director and determine the appropriate process to follow in resolving the situation. • Gather supporting documents or statements from the individual(s) who have observedor reported relevant incidents. • Volunteers suspected of drug related misconduct will be tested even if they admit to being

“under the influence.” Specimen collection will take place in the employee health serviceor emergency department. * If the specimen is collected in the emergency department, the collection container should be sealed and held in the emergency department until it can be transported to the employee health service.

CONFIDENTIALITY AND TESTING PROCEDURES

1. Volunteer testing will be handled in a confidential manner and chain of custody proceduresstrictly followed. 2. Test results will be called to the director of employee health service or the designate in the employee health service who in turn will release the results to the volunteer departmentdirector.

TOBACCO-FREE ENVIRONMENT

Effective November 17, 2005, Presbyterian prohibits tobacco use by employees, volunteers, family members and patients on all Presbyterian campuses. It is not the responsibility of any volunteer to tell visitors/staff/other volunteers, not to smoke on PHS property. Notify Security or facility staff, if needed.

The following activities are not allowed at any time on all Presbyterian property and campuses (including parking lots & personal vehicles located in parking lots): • smoking tobacco (cigarettes, cigars or pipes) and • use of smokeless tobacco products such as, but not limited to, chewing tobacco, snuff or smokeless (a.k.a. “E” or “electronic”) cigarettes. If your clothes smell of tobacco or smoke, your supervisor may ask you to change your clothing and/or restrict you from accessing patient areas. In addition to protecting themselves, each other and Presbyterian’s patients and visitors, employees/volunteers are expected to respect the Presbyterian brand name by not smoking or using smokeless tobacco products in the proximity of Presbyterian property, signage, name or logo. At any time, in a public location, but not limited to Presbyterian property and campuses, Presbyterian employees/volunteers are not allowed to smoke and/or use smokeless tobacco products while • wearing any clothing with the Presbyterian name or logo onit, • wearing a Presbyterian identification badge and /or • near any Presbyterian signage.