Agenda Cover Memorandum for 02/ - City of West Palm Beach

City of West Palm Beach
employment: Are you currently excluded, suspended, debarred or otherwise ineligible to
participate in the Federal health care programs, or have you been convicted of a criminal
offense related to the provision of health care items or services but not yet been excluded,
debarred, or otherwise declared ineligible?
d. Each employee of a Company-affiliated facility must disclose immediately any
debarment, exclusion or other event that makes him or her an Ineligible Person.
e. All Company-affiliated facilities, including hospitals, ambulatory surgery centers, home
health agencies, and physician practices must immediately terminate any current
employee who is listed as an Ineligible Person.
3. Employment of Minors
Normally, candidates for employment must have reached their eighteenth birthday. However, persons who have reached their sixteenth
birthday may be considered for employment within the limits of state and federal law.
4. Employment of Relatives and employees with common domicile
a. Employment of immediate family members and employees with common domicile at
Company-affiliated facilities may cause the perception of inequitable hiring practices and/or
conflicts of interest by fellow employees or others. Therefore, prior written approval must
be obtained from a manager one level above the hiring manager and may only be approved
after determining that such employment will not create the appearance of a conflict of
interest or have other adverse consequences to business operations. Immediate family is
defined as spouse, parent, parent-in-law, brother, sister, child, step-child and grandparent;
common domicile is the same legal residence.
b. Members of an immediate family or employees with common domicile shall not supervise
one another directly.
c. Members of an immediate family or employees with common domicile shall not supervise
one another indirectly without prior written approval from a senior manager at least one
level above the hiring manager.
d. If marriage, promotion or other action creates a supervisory relationship among related
employees or employees with common domicile, one of the related employees or
employees with common domicile must either resign or transfer in order to resolve the
situation within one calendar month.
e. No Company affiliated facility shall employ a relative or an individual with common
domicile of its Human Resources Director or any member of Senior Management without
written approval of a senior manager at least one level above the hiring manager.
5. Use of Contract Personnel
a. Contracts with independent contractors should be reviewed in advance by the Legal
Department. Generally, if an individual is subject to the Company’s control or direction
only regarding end results (and not as to the details by which those results are
accomplished), the individual may be classified as an independent contractor.
b. The agreement should include the Federal Tax ID number and the proof of workers
compensation insurance certificate.
DEFINITION
SanctionCheck.com is the Compliance Concepts, Inc. (CCI) website that enables Companyaffiliated
facilities to verify exclusions using an individual name or a batch file of multiple
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