Health Emergency/Business Continuance Policy
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|Policy:||Health Emergency/Business Continuance Policy|
|Date Last Reviewed:|
|Scheduled Review Date:|
|Supersedes:||All previous Policies and/or Statements|
|Approved by:||Management Committee|
On Top of the World Communities, LLC (the Company) strives to provide a safe and healthy workplace for all employees. This policy outlines our overall response to a health emergency and our emergency preparedness and business continuity plan. It outlines specific steps the Company takes to safeguard employees’ health and well-being while ensuring the Company’s ability to maintain essential operations and continue providing essential services to our residents and customers.
In addition, it provides guidance on how we intend to respond to specific operational and human resource issues in the event of a health emergency.
IDENTIFICATION OF ESSENTIAL PERSONNEL:
The Company has identified and designated as essential personnel certain employees whose jobs are vitally important to our continued operation in emergencies. We expect designated essential personnel to be available for work during a health emergency unless state and/or local officials mandate otherwise. Whenever possible, the Company will equip essential personnel with all the resources needed, including computers and cell phones, in the event that these employees need to work remotely during emergencies.
We acknowledge, however, that even essential personnel might become ill and unavailable to work or may not be able to reach our worksite because of conditions beyond their own or our control.
REMOTE WORK LOCATIONS:
The Company acknowledges that during a health emergency, local, state, or federal authorities might prohibit or severely curtail individuals’ access to and use of public services and public transportation; close or prevent access to buildings or public highways; isolate or quarantine certain locations and their occupants; and prevent or delay inter- or intrastate delivery of goods and services. We cannot predict and have no control over such authorities’ actions and acknowledge our legal duty to comply with outside authorities’ directives. We are prepared to continue essential operations from a number of remote work locations, including employees’ home offices, and are prepared to install all the equipment necessary for off-site telecommuting operations if necessary. Other employees’ telecommuting requests will be handled on a case-by-case basis. While not all positions will be eligible, requests for temporary telecommuting should be submitted to the employee’s supervisor for consideration. If an employee falls into a “high-risk” category, every effort will be made to allow the employee to work from home or in an office environment that minimizes exposure.
INFECTION CONTROL MEASURES:
The Company takes a number of steps to minimize to the extent practicable exposure to and spread of infection in the workplace, which is a common site for contagion because of workers’ close proximity to one another. As appropriate, the Company will recommend measures that employees can take to protect themselves outside the workplace and encourages all workers to discuss their specific needs with a family physician or other appropriate health or wellness professional.
In light of the global novel coronavirus pandemic, coupled with recommendations from the CDC and Florida Department of Health concerning the current threat posted by COVID-19, the Company will implement the following social distancing guidelines to minimize the spread of the disease among the staff.
All employees are requested to:
- Stay home if you are sick. Employees who have symptoms of acute respiratory illness (fever, cough, sore throat, or shortness of breath) must stay home and may not come to work until they are free of fever (100° F [37.8° C] or greater using an oral thermometer), other signs of a fever such as feeling feverish or having chills, and any other symptoms for at least 24 hours, without the use of fever-reducing or other symptom-altering medicines (e.g., cough suppressants, Tylenol, Advil, etc.). Employees also must stay home if they have acute gastrointestinal illness (vomiting or diarrhea). The Company expects such workers to notify us as soon as possible of exposure or illness, by calling their supervisor.
- Wash your hands frequently, with soap and water, and for at least 20 seconds.
- If soap and water are not available, use an alcohol-based hand sanitizer that contains 60-95% alcohol to disinfect your hands. Soap and water should be used if hands are visibly soiled.
- Cover your nose and mouth with a tissue when coughing or sneezing (or an elbow or shoulder if no tissue is available). Immediately throw out the used tissue and then wash your hands with soap and water or an alcohol-based hand sanitizer.
- Avoid touching your face, eyes, nose, and mouth, especially with unwashed hands.
- Avoid close contact (about 6 feet) with sick people.
- Routinely clean all frequently touched surfaces and objects in the workplace, such as workstations and desks, countertops, doorknobs, remote controls, controls on kitchen appliances, kitchen utensils, etc. Use the cleaning agents that usually are used in these areas and follow the directions on the label. Note that the Company has taken measures to increase the frequency of cleaning common areas and frequently touched surfaces.
- Use disposable wipes to wipe down commonly used surfaces (for example, doorknobs, keyboards, remote controls, desks, controls on kitchen appliances) before each use.
- Educate yourself about COVID-19. Make sure the information comes from reliable sources – your healthcare provider, local public health agency, the World Health Organization website, or the Centers for Disease Control Website.
- Avoid meeting people face-to-face whenever possible. Employees are encouraged to use the telephone, online conferencing, e-mail or instant messaging to conduct business as much as possible, even when participants are in the same building.
- If a face-to-face meeting is unavoidable, minimize the meeting time, choose a large, well ventilated meeting room and sit at least six feet from each other if possible; avoid person-to-person contact such as shaking hands, hugging, kissing, or using other physical greetings.
- Avoid any unnecessary travel and cancel or postpone nonessential meetings, gatherings, workshops, face-to-face interviews and training sessions.
- Do not congregate in small supply rooms, copier rooms or other enclosed areas where people would be in close proximity to one another.
Bring lunch and eat at your desk or away from others (avoid breakrooms and crowded restaurants).
- Encourage residents and others to request information via phone and e-mail in order to minimize person-to-person contact. Have the materials and information ready for fast pick-up or delivery.
- If you are uncomfortable having a face-to-face meeting with a resident or customer who shows signs of illness, you may politely decline the meeting. Signs have been created for the doors of customer-contact areas that read as follows:
”The health of our residents and guests is our highest priority. To protect residents, guests and staff, we are implementing precautions to ensure everyone remains healthy and safe. If you are experiencing a fever, cough, shortness of breath, or any flu like symptoms, we ask that you remain at home. If you are exhibiting flu-like symptoms or other symptoms consistent with the novel coronavirus, management reserves the right to deny customers service or entrance to this facility consistent with our obligation to maintain a safe workplace for our employees.”
We have prepared a communication to residents informing them of the precautions and protective measures we are implementing for them and our employees. It also discusses the protocols that should be followed before entering any resident’s home.
Employees are encouraged to the extent possible to:
- Avoid crowded public transportation, concerts, movies, parades and sports events.
- Avoid recreational or other leisure classes, meetings, activities, etc., where they cannot practice social distancing.
Employees are strongly encouraged to refrain from traveling to a country experiencing widespread transmission of respiratory illness caused by COVID-19 (e.g., China, South Korea, Italy, other countries in Europe, Iran, Japan, etc.), or to a city in the United States experiencing widespread transmission of COVID-19. Before travelling abroad, check the CDC’s Travelers’ Health website (www.cdc.gov/travel) for the latest guidance and recommendations for each country to which you will travel as well as general travel health advice.
Employees should also check themselves for symptoms of acute respiratory illness before starting travel and stay home if they are sick.
Employees who travel to a foreign country, should find out before they leave whether they will be subject to quarantine in that country or denied entry back to the United States and make sure they have the resources to pay for a stay of at least 14 extra days. The CDC’s Travelers’ Health website (www.cdc.gov/travel) contains this information, as do others.
EXPOSURE TO NOVEL CORONAVIRUS/COVID-19
Employees (1) who have taken a cruise, (2) who have traveled to a country experiencing widespread transmission of respiratory illness caused by COVID-19 (e.g., China, South Korea, Italy, most countries in Europe, United Kingdom and Ireland, Iran, Japan, etc.), or who have come into contact with a sick person who has visited one of these countries, or have been exposed to a person diagnosed with COVID-19 in the United States, or have visited a city in the United States experiencing widespread transmission of COVID-19:
- Must notify the Human Resources Department of such travel (preferably in advance of travel) or possible exposure to a person diagnosed with COVID-19.
- Are prohibited from coming to work for at least fourteen (14) days after the last possible exposure.
- Should seek immediate medical advice and tell the healthcare provider about their possible exposure.
- Should avoid contact with others. (Employees also are encouraged to follow advice from the CDC, available at https://www.cdc.gov/coronavirus/2019-ncov/travelers/after-travel-precautions.html).
- If diagnosed with COVID-19, should advise their medical provider or public health officials of the names of people with whom they have come into contact since their symptoms started.
- If diagnosed with COVID-19, must provide a release to return to work from a medical provider, in accordance with applicable law. Employees who are unable to obtain a release due to inability to obtain an appointment with a healthcare provider should contact the Human Resources Department.
Employees who are prohibited from coming to work as set forth above, or who are subject to quarantine imposed by public health officials, shall be eligible for a leave of absence in accordance with the Company’s regular leave policies. The Company’s goal is to encourage employees who are sick or who may be sick to stay home, not to punish them for doing the right thing. Employees who do not comply with these provisions or who abuse this policy will be disciplined accordingly.
Please note that it is likely that COVID-19 will continue to grow in numbers around the globe, including the United States. The references to China, South Korea, Iran, and European countries are based on information available as of the development of this policy, but changes almost daily. Any country selected for travel restrictions by the federal government will be deemed added to the countries included in this policy. As the virus spreads to other countries, please be aware of exposure to people in or from those countries (see www.cdc.gov/COVID-19 for up-to-date information). You also can consult https://www.cdc.gov/coronavirus/2019-ncov/locations-confirmed-cases.html, which tracks all countries with confirmed COVID-19 cases. Please also be aware of the spread of COVID-19 domestically and follow recommendations of local health officials and the CDC.
MANDATORY EMPLOYEE TRAINING:
All employees are at risk of exposure to contagious diseases, both in and outside the workplace; therefore, the Company requires all employees to attend online training to become informed about what to do when a health emergency occurs. Supervisors are responsible for ensuring every employee’s participation in required training.
The Company maintains adequate supplies of recommended personal-protection equipment such as protective gloves and anti-bacterial hand gels and wipes, which the Company can require workers to use. We urge all employees to speak with their personal physician about types and proper use of personal-protection equipment in the home.
Facilities Maintenance regularly inspects the workplace to determine and use, wherever possible, improved equipment or cleaning methods to guard against the spread of infection in the workplace. Additionally, each supervisor should designate an individual or individuals to be responsible for disinfecting common surfaces in their workplace or office.
EMPLOYEE LEAVE AND PAY:
In the event of a health emergency, employees who develop serious complications, or are caring for family members who experience such complications, may qualify for leave under the Family Medical Leave Act if such complications qualify as a serious health condition. Please see the terms of our FMLA policy.
In a health emergency, employees may take emergency leave due to one or more of the following reasons:
- Self-isolation due to being diagnosed with COVID-19
- To obtain a medical diagnosis
- Preventive care for the novel coronavirus
- To comply with an order from public officials or a health care provider that the presence at would jeopardize health of others due to exposure or symptoms of COVID-19
- To care for a family who is self-quarantining or symptomatic or has been ordered to be quarantined
- To care for a child due to closure of a school or childcare provider
Additionally, the Company, at its discretion, may choose to place employees on administrative leave. When on leave, employees should first use their PTO and vacation. Those who have exhausted their PTO and vacation or who are not eligible for PTO and vacation will be eligible to be paid from the Company’s established sick leave fund (PTO bank). At its discretion, the Company may add additional funds to the PTO bank if needed to provide employees with income while on leave. Documentation will be required and may include (1) recommendation from a public health official or health care provider that the employee has symptoms or should be quarantined, (2) documentation or evidence of exposure, or (3) notice of school or childcare provider closure. When applicable, an employee may be authorized to work remotely instead of being placed on leave.
FAMILY MEDICAL LEAVE:
If an employee falls seriously ill or must be absent from work to care for a seriously ill family member they may qualify for leave under the Family Medical Leave Act (FMLA) if the illness qualifies as a serious health condition and they meet the eligibility requirements under the law. Employees should notify the Company as soon as possible of the need for family medical leave.
Employees should make all reasonable efforts to eliminate the need for travel by taking advantage of technology that allows us to communicate or otherwise operate electronically. Generally, in the event of a health emergency, travel on the Company’s behalf is immediately suspended and limited to employees who have obtained required travel authorizations from the Company and, if necessary, outside authorities.
EMERGENCY CONTACT INFORMATION:
Employees are required to notify their immediate supervisor and Human Resources of any change in emergency-contact information within two weeks of the change. When providing such information, employees, especially those who have children or care for elderly relatives, should identify individuals on whom they can depend if the employees themselves become sick at work and must be isolated and quarantined. Supervisors are required to maintain, in the workplace and at home, an up-to-date emergency-contact list for their unit or department.
SPECIAL NEEDS AND ACCOMMODATIONS:
The Company is required by law to notify first responders about employees with medical conditions that could be compromised because of a health emergency. The Company urges such employees to confidentially self-identify to Human Resources so that we can prepare first responders to provide any special medical expertise you might require if you become severely ill on the job. Human Resources maintains the confidentiality of any information you provide, making it available solely on a need-to-know basis.
COMMUNICATION WITH OUTSIDE AUTHORITIES:
The Company and its Emergency Operations Team will partner with local, state, and federal emergency-response and health agencies to ensure legal compliance with emergency-response protocols to which the Company is subject and to coordinate efforts to maintain safety and security in and outside the workplace.
In the event of a conflict between directives issued by the Company and directives issued by local, state, or federal authorities, such as the CDC or federal Department of Homeland Security, the Company directs all employees to obey all orders issued under local, state, or federal law.
The Company’s Emergency Operations Team, which is responsible for ensuring our company’s ability to continue operating in emergencies, has devised a system under which essential employees can be directed to take specific actions at a specific time based on a series of alerts or triggers that take into account the seriousness of conditions at hand.
If needed, the Company’s remote emergency-response hotline may be activated during a serious contagious disease outbreak.
OTOW Ocala Campus Employee Hotline
(352) 387-7447 – landline (first call)
(727) 215-3886 – alternate mobile line (call only if landlines not available)
OTOW Clearwater Campus Employee Hotline
Additionally, hotline information will be placed on the intranet and website. Employees are instructed to log onto the intranet, the website or call the hotline for messages. At the Company’s discretion, assistance from live operators may also be provided. The Company maintains separate plans for communications with residents, customers, suppliers, vendors, and government officials.
The Company maintains a secure intranet and website, devoted to health emergency issues in general and to the Company’s responses specifically. The intranet will have an icon on employee’s desktop computers and can be only be accessed from inside the company. The dedicated website, https://ontopoftheworldinfo.com/emergency-guidelines/, can be accessed by employees on their mobile devices or home computers. The intranet and website will contain messages from the company and easy-to-understand descriptions of the health emergency and recommended infection-control protocols for home, workplace, and travel.
If you have a question to which you cannot find an answer on the intranet or website, please use the “Ask Us” function on the site. Your question will be directed to the appropriate person. If appropriate, your question and the answer, if not confidential, may be posted to the FAQ section. The Company has designated a specific company representative to staff “Ask Us” in a health emergency; however, you should be aware that the Company’s ability to maintain this service could be compromised during a health care crisis.
The Company expects all employees to know how to access this site and to become familiar with the site’s information, some of which may be downloaded and distributed periodically in emergency-information packets distributed to all employees.
EMPLOYEE ASSISTANCE PROGRAM SERVICES:
The Company’s employee assistance program (EAP) services remain available to you to the extent practicable and reasonable during an outbreak. Our provider partners with the Company and local authorities as appropriate to ensure the reasonable availability and continued provision of critical information as well as psychological and emotional support during a health emergency, including assistance and support following the death of an infected family member. Contact information for our EAP is:
Go to: www.GuidanceResources.com
Company Web ID: Lincoln
The company provides telemedicine access through My Ideal Doctor to all employees, even if they do not participate in the company’s other benefit options. All employees should sign up for telemedicine as it is an excellent source for employees who have basic questions about their symptoms or those of their family members. Instructions for setting up a telemedicine account are as follows:
- Go to myidealdoctor.com and click member Login at the top of the page.
- Click Register
- Validate your membership by completing the fields on the registration page.
- On the last field, it asks if you have services through your employer or insurance provider.
- Select “Yes” and type in employer information in the next field (On Top of the World Communities, LLC).
- Click continue.
- Create your account by entering your email address and password.
CHANGES AND UPDATES:
This plan is the result of many hours of discussion and planning with industry partners, public health experts, and other appropriate parties. The Company regularly reviews and updates to the plan as conditions change. Any changes to the plan will be communicated via the Company’s intranet, the emergency response website and the emergency hotline.
The Company will use its best efforts to respect the privacy and confidentiality of any employee who reports an illness. Please be aware that due to the seriousness of exposure to the novel coronavirus/COVID-19, the Company may need to inform co-workers and others who came in close proximity to an infected employee, without identifying the employee by name. The Company also may be required to notify governmental authorities, including the public health department, the CDC, and the Occupational Safety and Health Administration.
The Company will enforce and apply this policy in a non-discriminatory manner and in compliance with all applicable federal, state, and local laws, rules, and regulations.
The Company reserves the right to modify the terms of this policy or to depart from the policy if necessary for business needs, because of medical developments, to comply with applicable law, or because of changes in the information available regarding the control and treatment of communicable diseases covered in this policy, including COVID-19.