COPC Handbook April 2025 Q2

4.5

Pre-Employment Applicants being considered for hire must pass a drug test before beginning work. The offer of employment is contingent on successfully passing Reasonable Suspicion Employees are subject to testing based on (but not limited to) observations by at least two members of management of apparent workplace use, possession, or impairment. Management should contact Human Resources and use the Reasonable Suspicion Observation Checklist to document specific observations and behaviors that create a reasonable suspicion that an employee is under the influence of drugs or alcohol. When reasonable suspicion testing is warranted, both management and Human Resources will meet with the employee to explain the observations and the requirement to undergo a drug and/or alcohol Consequences Employees who test positive under reasonable suspicion are subject to discipline, up to and including termination of employment. Depending on the circumstances and the employee’s work history/record, COPC may offer an employee who violates this policy or tests positive the opportunity to return to work on a last-chance basis pursuant to mutually agreeable terms, which could include follow-up drug testing at times and frequencies determined by COPC for a minimum of one year, but not more than two years, as well as a waiver of the right to contest any termination of employment resulting from a subsequent positive test. If the employee either does not complete the rehabilitation program or tests positive after completing the rehabilitation program, the employee will be subject to immediate termination of employment. Employees who, 1) refuse to cooperate in required tests, 2) who use, possess, buy, sell, Confidentiality Information and records relating to positive test results, drug and alcohol dependencies, and legitimate medical explanations provided by a Medical Review Officer (MRO) should be kept confidential to the extent required by law and maintained in secure files separate from normal

the drug test. Refusal to submit to testing or a positive test may result in disqualification of further employment consideration.

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test as soon as reasonably possible. Refusal by an employee will be treated as a positive drug test and will result in immediate termination of employment The Reasonable Suspicion Protocol Checklist and other related forms can be found on COPConnect under Manager Guide in the Performance and Behavior section. Under no circumstances will the employee be allowed to drive themself to the testing facility. A member of management must transport the employee or arrange for transportation for the employee to the testing facility. manufacture, or dispense an illegal drug or alcohol or, 3) use legal drugs/substances (including but not limited to prescription medications, over- the-counter medications, alcohol, or marijuana) that results in impairment while working and/or threatens the safety, productivity, public image, or property of the Company or its employees or patients are in violation of this policy and may face termination of employment. Employees will be paid for time spent in alcohol or drug testing and then suspended pending the results of the drug or alcohol test. After the results of the test are received, a date and time will be scheduled to discuss the results of the test; this meeting will include a member of management and Human Resources. Should the results prove to be negative, the employee will receive back pay for the times/days of suspension.

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4.8

personnel files. Such records and information may be disclosed among managers and supervisors on a need-to-know basis and may also be disclosed, when relevant, to a grievance, charge, claim, or other legal proceeding initiated by or on behalf of an employee or applicant.

Questions and concerns can be directed to your immediate supervisor, Human Resources (614) 304-2080 or the Compliance Hotline (866) 539-5813

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