An EMS agency needs to have a number of workplace policies in order to operate effectively. These policies can be grouped into seven basic policy categories:
- Compliance Program
- OSHA
- HIPAA
- Conduct
- Call-Related (Operational)
- Employment-Related
- Billing-Related
Most agencies have these basic policies covered. But, it is some of the less common policies that seem to come into play when people contact us with problems. We find that some agencies do not have policies dealing with these less-common topics at all, while others’ policies are woefully deficient. In no particular order, here are three less-common policies we believe every EMS agency needs to have, train personnel on, monitor compliance with, and regularly update:
1. Conflict of Interest/Outside Employment
Now that the IRS has been asking tax-exempt organizations if they have a conflict of interest policy on their federal 990 information returns, more tax-exempt organizations are adopting conflict-of-interest policies [1]. But, every EMS agency needs a policy on conflicts of interest and outside employment, not just those that are nonprofit.
Unfortunately, with the relatively low pay in EMS, it is common for EMS employees to have multiple jobs. Every EMS agency needs to know which employees have multiple jobs, who is working where, and what potential business ventures your employees are into or getting into.
Many employers think that they are covered because they have a confidentiality policy. But, most confidentiality policies do not go far enough to prevent potential conflicts. Therefore, every agency needs a conflict of interest/outside employment policy.
This policy needs to include a requirement that all employees report all outside employment and volunteering they do, but also report the names of all companies in which they have a 5 percent or greater ownership interest. This disclosure should be updated at least annually. If your organization is a nonprofit organization, there needs to be a specific requirement that no one is able to vote on any topic in which they would in any way personally benefit.
When employees have multiple jobs, it is also important to ensure that they always show up for your job well-rested. This is why, if you do not have a separate policy on reporting to work well-rested, the policy on reporting outside employment is a good place to mention this requirement.
2. Medication storage, control, security and reconciliation, and drug-free workplace
Many organizations have a drug-free workplace policy. Many organizations also have one or more policies on proper medication storage, control, security and reconciliation. But, many organizations’ policies on these have not been reviewed or updated in many years.
The drug-free workplace part of the policy should apply to everyone equally who provides any services for the EMS agency, regardless of whether they are paid or volunteer. The policy should be clear that the unlawful manufacture, distribution, dispensing, possession or use of drugs, alcohol or other intoxicating substances while on duty is strictly prohibited.
The policy should describe who is covered by the policy, when the policy applies, and what types of behavior are prohibited. It should require covered personnel to notify the employer of any drug-related convictions, and it should permit certain drug-related searches and testing.
The policy needs to describe the consequences of a violation, and whether employee assistance may be possible. It also needs to discuss the confidentiality of information received as part of the drug-free workplace program.
We are including a drug-free workplace policy, as well as medication control, storage, security and reconciliation in this list because drug addiction is a serious issue in EMS, and a large part of the problem is the access that EMS providers have to the medications on board the ambulances and in other places where EMS agencies store the medications.
Having a comprehensive drug-free workplace program that encourages employees to seek help and treatment for their addiction, and tries to eradicate drugs and alcohol from the EMS workplace is one aspect of fixing the problem.
The other part of fixing the problem is to take better measures to try to stop EMS providers from having the ability to steal medications in the first place by tightening up each EMS agency’s medication storage, control, security and reconciliation policy. Unfortunately, no system is foolproof or theft-proof. Utilizing some form of tamper-evident system on all of the medications is important, as is having a minimum of two locks on all scheduled drugs, with at least one of the locks requiring some sort of identification number or card that identifies exactly who is opening the locks. It is also important that two separate people regularly inventory all of the medications at an EMS agency.
Whenever a drug is administered, it is also important that the patient care report include information as to the administration of the drug by patient name, drug identification, date and time of administration, route of administration, dosage, name of the medical command physician who gave the order to administer the drug and the name of the person administering the drug.
3. Incident scene photos and videos
The posting of incident scene photos by EMS providers has received quite a bit of press over the past several years. Yet, based on the fact that we continue to see these stories in the news, this issue is not going away any time soon.
Therefore, it is important for all EMS agencies to have a written policy on incident scene photos and videos. Incident scene photos and videos can be valuable as a training tool, to help fire or accident investigators determine what happened and how, and to have the emergency room physicians truly see the mechanisms of injuries. But, it is important that the policy only permit photographs and videos at incident scenes with company-issued equipment, and that all photos and videos taken at a scene are the sole property of the EMS agency.
Protecting the security of photos and videos must also be addressed. The policy should specify what scene content is permissible, and where and when scene photography and videography is permissible.
With any luck, having a comprehensive Incident Scene Photography and Videography Policy should help prevent your EMS agency and its staff from being the next news story on this topic.
References
- http://www.irs.gov/pub/irs-pdf/f990.pdf. See Part VI, Section B, Number 12a.
