OHC Employee Policies

Purpose and Scope

Occupational Health Connections (OHC) is committed to providing a safe and healthy workplace for all our employees. OHC has developed the following COVID-19 plan, which includes policies and procedures to minimize the risk of transmission of COVID-19, in accordance with OSHA’s COVID-19 Emergency Temporary Standard (ETS).

Occupational Health Connections has multiple workplaces that are substantially similar, and therefore has developed a single COVID-19 plan for the substantially similar workplaces.

Click on Occupational Health Connections’ COVID-19 ETS Plan to continue reading.

  1. Introduction

It is the goal of Occupational Health Connections (OHC) to promote a workplace that is free of unlawful discrimination, harassment, sexual harassment, and retaliation. OHC expects all of its employees to treat their fellow employees in a professional manner, with respect and dignity. Employees have the right to work in a respectful workplace free from discrimination and harassment.

Discrimination, harassment, or sexual harassment of employees occurring in the workplace or in other settings in which employees may find themselves in connection with their employment is unlawful and will not be tolerated by this organization. Further, any retaliation against an individual who has complained about discrimination, harassment, sexual harassment, or retaliation against individuals for cooperating with an investigation of a complaint is similarly unlawful and will not be tolerated. To achieve our goal of providing a workplace free from discrimination, harassment, and sexual harassment, the conduct that is described in this policy will not be tolerated and we have provided a procedure by which inappropriate conduct will be dealt with, if encountered by employees.

Because Occupational Health Connections takes allegations of discrimination, harassment, and sexual harassment seriously, we will respond promptly to complaints of such conduct and where it is determined that such inappropriate conduct has occurred, we will act promptly to eliminate the conduct and impose such corrective action as is necessary, including disciplinary action where appropriate.

Please note that while this policy sets forth our goals of promoting a workplace that is free of discrimination, harassment, and sexual harassment, the policy is not designed or intended to limit our authority to discipline or take remedial action for workplace conduct which we deem unacceptable, regardless of whether that conduct satisfies the definition.

  1. Definitions

Discrimination is conduct based on one or more Protected Statuses that adversely impacts an applicant’s hiring or an employee’s compensation or terms and conditions of employment.

Harassment is conduct of any type (including oral, written, electronic, internet, social media, graphic, or physical) that is severe or pervasive and unreasonably interferes with a person’s work or creates a work environment that a reasonable person would find hostile, offensive, humiliating or intimidating. Harassment is not limited to the workplace location itself. For example it may occur away from the workplace, on personal devices, or during non-work time.

Sexual harassment is defined as: “sexual harassment” means sexual advances, requests for sexual favors, and verbal or physical conduct of a sexual nature when:

  1. submission to or rejection of such advances, requests or conduct is made either explicitly or implicitly a term or condition of employment or as a basis for employment decisions; or,
  2. such advances, requests or conduct have the purpose or effect of unreasonably interfering with an individual’s work performance by creating an intimidating, hostile, humiliating or sexually offensive work environment.

Under these definitions, direct or implied requests by a supervisor for sexual favors in exchange for actual or promised job benefits such as favorable reviews, salary increases, promotions, increased benefits, or continued employment constitutes sexual harassment.

The legal definition of sexual harassment is broad and in addition to the above examples, other sexually oriented conduct, whether it is intended or not, that is unwelcome and has the effect of creating a work place environment that is hostile, offensive, intimidating, or humiliating to anyone may also constitute sexual harassment.

While it is not possible to list all those additional circumstances that may constitute harassment and sexual harassment, the following are some examples of conduct which if unwelcome, may constitute harassment or sexual harassment depending upon the totality of the circumstances including the severity of the conduct and its pervasiveness:

  • The use of slurs, epithets, jokes, written or oral references to one’s membership in a protected group
  • Gossip regarding one’s membership in a protected group
  • Displaying offensive objects, pictures, cartoons, or demeaning gestures
  • Other derogatory comments
  • Unwelcome sexual advances — whether they involve physical touching or not
  • Sexual epithets, jokes, written or oral references to sexual conduct, gossip regarding one’s sex life; comment on an individual’s body, comment about an individual’s sexual activity, deficiencies, or prowess
  • Displaying sexually suggestive objects, pictures, cartoons
  • Unwelcome leering, whistling, brushing against the body, sexual gestures, suggestive or insulting comments
  • Inquiries into one’s sexual experiences, and
  • Discussion of one’s sexual activities

All employees should take special note that, as stated above, retaliation against an individual who has complained about discrimination, harassment, or sexual harassment, and retaliation against individuals for cooperating with an investigation of such complaint is unlawful and will not be tolerated by this organization.

III. Complaints of Discrimination, Harassment, or Sexual Harassment

If any of our employees believes that he or she has been subjected to discrimination, harassment, or sexual harassment, the employee has the right to file a complaint with our organization. This may be done in writing or orally.

If you would like to file a complaint you may do so by contacting Nicole Cirino, [email protected] 512-572-6393. This person is also available to discuss any concerns you may have and to provide information to you about our policy and our complaint process.

  1. Investigation

When we receive the complaint we will promptly investigate the allegation in a fair and expeditious manner. The investigation will be conducted in such a way as to maintain confidentiality to the extent practicable under the circumstances. If applicable, our investigation will be conducted in cooperation with our client and will include a private interview with the person filing the complaint, witnesses, and the person alleged to have committed inappropriate conduct. When we have completed our investigation, we will, to the extent appropriate inform the person filing the complaint and the person alleged to have committed the conduct of the results of that investigation.

If it is determined that inappropriate conduct has occurred, we will act promptly to eliminate the offending conduct, and where it is appropriate we will also impose disciplinary action.

  1. Disciplinary Action

If it is determined that inappropriate conduct has been committed by one of our employees, we will take such action as is appropriate under the circumstances. Such action may range from counseling to termination from employment, and may include such other forms of disciplinary action as we deem appropriate under the circumstances.

  1. State and Federal Remedies

In addition to the above, if you believe you have been subjected to sexual harassment, you may file a formal complaint with either or both of the government agencies set forth below. Using our complaint process does not prohibit you from filing a complaint with these agencies. Each of the agencies has a short time period for filing a claim (EEOC – 300 days; MCAD – 300 days).

The United States Equal Employment Opportunity Commission (“EEOC”) The Massachusetts Commission Against Discrimination (“MCAD”)

OHC’s Exposure Control Plan has been developed in accordance with the OSHA Bloodborne Pathogens Standard 29 CFR 1910.1030. This plan is specifically designed to eliminate or minimize employee occupational exposure to blood or certain other body fluids.

This plan affects all employees including management.

Please click to read more: BBP Exposure Plan 2024

Occupational Health Connections (OHC) aims to project a professional image for our clients, patients and colleagues. Dress attire is a very important way to establish a favorable image in order to gain confidence and respect from others whom we interact with.

The following information is intended to serve as a guide to help define appropriate business wear and grooming for all OHC’s employees during designated work days.

These guidelines are not intended to be all-inclusive, rather this content should help set the general parameters for proper business wear and encourage OHC employees to make intelligent judgments about items that are not specifically addressed.

Name Tags
The MA Board of Nursing’s regulation at 244 CMR 9.03(8): Identification Badge, requires that a nurse who holds a valid license and who examines, observes, or treats a patient in any practice setting shall wear an identification badge which visibly discloses at a minimum his or her first name, licensure status and, if applicable, advance practice authorization.

Clothing should be clean, neat and in good condition. Torn, dirty, or frayed clothing is unacceptable. All seams must be finished. Any clothing that has words, terms, or pictures that may be offensive to other employees is unacceptable.

Clothing that reveals too much cleavage, back, chest, stomach or underwear is not appropriate for a place of business.

Hats, caps bandanas, unless for medical conditions, safety purposes or established religious customs are not allowed.

Lab coats
White lab coats should be worn by Occupational Health NPs and RNs interacting with employees.

Dress slacks are acceptable provided they are well fitting, clean and wrinkle-free.

Inappropriate items include jeans of any color, sweatpants, wind suits, short shorts, Bermuda shorts, bib overalls, leggings, spandex or other form-fitting pants.

Dress shirts and pants without tie are acceptable.

For women, shirts, blouses, sweaters and turtlenecks are acceptable.
Inappropriate items include sweatshirts and shirts with large lettering, logos or slogans, and halter-tops.

Dresses and Skirts
Dress and skirt length should be no shorter than four inches above the knee.
Mini-skirts and spaghetti-strap dresses should not be worn to the office.

Dress shoes, loafers, boots, flats, clogs and leather deck shoes are acceptable.

Athletic shoes and sneakers are acceptable provided they are clean and professional in appearance.

High heels are not allowed.

Thongs, and rubber flip-flops and slippers are not acceptable.

As specified by OSHA standards, personnel providing direct patient care must wear closed toe shoes.

There should be no visible body piercing other than pierced ears.

Colognes, perfumes or other products that emit a fragrance are not allowed. There are many visitors to Occupational Health who are sensitive to fragrances.

Questions or Concerns
Any questions regarding the Dress Code policy should be directed to Nancy Clover.

No dress code can cover all contingencies so Occupational Health employees must exert a certain amount of judgment in their choice of clothing to wear when at work. If you experience uncertainty about acceptable attire for work, please ask your supervisor for clarification.

If an item of clothing is deemed to be inappropriate for the office by the employee’s supervisor, the employee may be sent home to change clothes and will be given a verbal warning for the first offense, and progressive disciplinary action will be taken for further dress code violations

Glove Requirements:
Gloves are not mandatory for immunizations
Gloves are mandatory if there is possible exposure:

  • to blood
  • to bodily fluids
  • or if the provider has a open cuts on hands

Glove Change:

  • Gloves need to be changed if they are exposed to infection, pathogen, or bodily fluids

Gloves MUST be changed between every person when performing fingersticks

  • Gloves need to be changed after touching anything unsanitary
  • Avoid sneezing, wiping, or touching unsanitary areas while wearing gloves

Proper Glove Removal:

  1. Carefully peel one glove by grabbing the outside cuff so that the glove turns inside out as it is removed.
  2. Place removed, inside-out glove into the hand that is still gloved.
  3. While holding the removed glove, slide ungloved fingers under cuff of second glove.
  4. Use the inside to turn the glove inside out around the first glove that you are holding. Touch only the inside of the gloves.
  5. End result: both gloves are inside-out with one glove inside the other.
  6. Properly dispose of gloves.
  7. Wash hands after removing gloves or use hand sanitizer.

Important Reminders:

  • Gloves cannot prevent a needle stick injury.
  • Gloves cannot be washed or reused.


Occupational Health Connections (OHC) has adopted a policy that protects the privacy and confidentiality of protected health information (PHI) whenever it is used by company representatives. The private and confidential use of such information will be the responsibility of all individuals with job duties requiring access to PHI in the course of their jobs.

Protected Health Information Defined

PHI refers to individually identifiable health information received by a health care provider, health plan or health care clearinghouse that relates to the past or present health of an individual or to payment of health care claims. PHI information includes medical conditions, health status, claims experience, medical histories, physical examinations, genetic information, and evidence of disability.

The HIPAA Compliance Officer

The company has designated OHC partners as the HIPAA compliance officers (HCO), and any questions or issues regarding PHI should be presented to the HCO for resolution. The HCO is also charged with the responsibility for:

  • Issuing procedural guidelines for access for PHI.
  • Developing guidelines for describing how and when PHI will be maintained, used, transferred, or transmitted.

Activities Necessitating Use of PHI

OHC will provide training on HIPAA on hire and as needed.

All information related to PHI will be maintained in confidence, and employees will not disclose PHI except as provided by administrative procedures approved by the HCO. General rules follow:

  • Disclosures that do not qualify as PHI-protected disclosures include:
    • Disclosure of PHI to the individual to whom the PHI belongs.
    • Requests by providers for treatment or payment.
    • Disclosures requested to be made to authorized parties by the individual PHI holder.
    • Disclosures to government agencies for reporting or enforcement purposes.
    • Disclosures to workers’ compensation providers and those authorized by the workers’ compensation providers.
  • Information external to the health plan is not considered PHI if the information is being furnished for claims processing purposes involving workers’ compensation or short- or long-term disability and medical information received to verify Americans with Disabilities Act (ADA) or Family and Medical Leave Act (FMLA) status.

Records Retention

Personnel records and disclosures of PHI will be maintained for a period of six years as required by federal law unless a state law requires a longer retention period. Records that have been maintained for the maximum interval will be destroyed in a manner to ensure that such data are not compromised in the future in accordance with the company record destruction policy.

This is adapted from the CDC and is OHC’s Policy:

OHC policy on prefilling syringes, or drawing up vaccine into syringes in advance of the need for it.

We STRONGLY discourage this practice. Loading vaccine into syringes before you are ready to use it increases the risk for medication errors, vaccine contamination, and vaccine wastage.

When time and staff are limited and demand is high, most commonly- used vaccines are available in prefilled syringes from the manufacturer. Manufacturer prefilled syringes are prepared under sterile conditions that meet standards for proper handling and storage and they are individually labeled. Varicella, MMR, and yellow fever vaccines must NEVER be drawn up ahead of time. But there may be situations in which a single vaccine is going to be administered- such as a large influenza campaign- and manufacturer’s prefilled syringes are not available. In these situations, each person giving injections may choose to prefill a few syringes shortly before administration.

In keeping with nursing medication administration guidelines, OHC’s policy is that the person who prepares the medication should be the same person who administers the medication. We recommend that any prefilled syringes should be properly stored and should be used on the same day they are filled. Label each syringe carefully, and keep the filled syringes cool.

1.0. Purpose

Persons who are impaired by substance abuse endanger patients, themselves, and their fellow workers. By prohibiting substance abuse, and by establishing a program to determine whether employees are engaged in substance abuse, this policy seeks to prevent its risks and ill effects. This policy replaces all existing policies concerning substance abuse and drug testing of employees.

2.0. Definitions

2.1. Substance abuse shall mean:
The use or possession of any drug in a manner prohibited by law; and
The use of alcohol or any legal drug or other substance in such a way that the user’s performance as a health care provider is impaired.

2.2. Impaired shall mean that a person’s mental or physical capabilities are reduced below their normal levels (with or without any reasonable accommodation for a disability).

2.3. A positive drug test shall mean any drug test whose results indicate that the employee has committed substance abuse, according to the current NIDA standards and the definitions in this policy.

2.4. A negative drug test shall mean any drug test whose results do not indicate a positive drug test.

2.5. Reasonable cause shall mean that evidence which forms a reasonable basis for concluding that it is more likely than not that a person has engaged in substance abuse. Facts which could give rise to reasonable cause include, but are not limited to:
The odor of alcohol or drugs;
Impaired behavior such as slurred speech and decreased motor coordination;
Marked changes in personality or job performance; and
Unexplained accidents.

2.6. Covered employees shall mean all Occupational Health Connection’s (OHC) employees and contractors.

3.0. Work Rules

3.1. Substance abuse is prohibited. Any employee who engages in substance abuse at work or at the client’s site with be discharged.

3.2. Employees who refuse to participate in a drug test required under this policy may be discharged.

3.3. In no event should employees perform their official duties while they are impaired.

3.4. If an employee is convicted (or given first offender treatment, or pleads nolo contendere) in any court for a crime which constitutes substance abuse, they must report this to their supervisor. Employees who fail to do so may be discharged.

4.0. Drug Testing Procedures

4.1. The drug tests required by this policy shall be performed in accordance with the current procedures of the Laboratory or Clinics.

4.2. The tests shall screen for the use of drugs whose use is either illegal, or which are prone to abuse, as determined at the discretion of the President of OHC.

4.3. The results of an employee’s drug test shall be communicated by the laboratory to the President of OHC, who shall notify the employee of any positive drug test.

5.0. Pre-employment Drug Testing

5.1. OHC employees may undergo a drug screening test prior to beginning work or within ten days of reporting for duty as an employee of OHC.

5.2. Any applicant who fails to provide a sample for pre-employment drug testing shall be discharged, or not hired. Any applicants with a positive pre-employment drug test will be discharged, or not hired.

6.0. For Cause Drug Testing

6.1. All employees shall undergo a drug screening test when reasonable cause exists to believe that they have committed substance abuse.

6.2. If authorization for a drug test for cause is given by the President of OHC, then the employee shall be directed to provide a sample for testing immediately. Pending the results of such a test, the employee shall be placed on paid administrative leave, and they shall be removed from duty. It is the responsibility of the impaired employee to arrange for their own safe transportation.

6.3. Employees with a positive for cause drug test may be discharged.

7.0. Counseling and Rehabilitation

7.1. It is recognized and accepted that early treatment is the key to rehabilitation for substance abusers. Employees are encouraged to voluntarily request counseling or rehabilitation before their substance abuse leads to disciplinary or work related problems. If, prior to an arrest for substance abuse, an employee notifies their immediate supervisor that they illegally use a controlled substance, marijuana, or a dangerous drug and is receiving or agrees to receive treatment under a drug abuse and education program, such employee shall be retained for up to one year as long as the employee successfully follows the treatment program.

If the employee fails to successfully follow the program, they must be discharged. No statement made by an employee to their supervisor in complying with this program shall be admissible against the employee in any proceeding. The rights granted in this section shall be available to an employee only once during a five year period, and shall not apply to an employee who has been asked to provide a sample for cause, or an employee who has refused a drug test, or tested positive for controlled substance, marijuana, or a dangerous drug.

8.0. Appeals

8.1. Employees who are disciplined for substance abuse may appeal the discipline.