III.    FACILITY/AGENCY’S POLICY AND PROCEDURES

 

It is important for you and your staff to be thoroughly familiar with the policy and procedures of your agency or business.  Policy and procedures determine program, safety and legal guidelines and are critical for quality service provision.  Most agencies have a policy and procedure handbook that is given to each employee as part of their orientation process.

 

Make sure you understand agency policy and procedures and have a method to insure your staff also has access to and an understanding of them. Do not assume that one training session or discussion means mastery of the information or the ability to use the information.  Most knowledge requires repeated training before learning occurs.

 

You may also wish to take a proactive role to insure appropriate policy development in several areas that have important implications for serving persons with disabilities.  There are many resources available to assist you.

 

The following areas may not have been addressed or may need to be reviewed when a program or business has a community based vocational program:

 

A Human Rights Committee or Commission is essential for ethics review and as a method of investigating and resolving grievances, complaints and problems.  This committee is required if you are serving individuals with funding from the Department of Human Services Developmental Disability Services Division.

 

Every agency needs to keep updating policy and procedures on sexual harassment and confidentiality, especially since the issues in both of these areas are experiencing a great deal of litigation.  Not being current on new legal rulings could create agency liability.

 

It is surprising, but true, that many agencies and businesses have not developed policy and procedures on universal precautions and/or HIV/AIDS.  It is critical that these areas be covered.  Precautions and procedures have been developed by the Centers for Disease Control and Prevention and have been incorporated into OSHA guidelines.  This information and these guidelines can be used as the basis for policy and procedures.

 

Use of a Business Advisory Council can provide a broad base of community expertise in areas of public relations, marketing, advocacy and organizational management and planning.  Some agencies and businesses form a Business Advisory Council as an task force or work group created as a part of an existing advisory group or Board.


A.      The Human Rights Commission

 

The Enforcement and Compliance Division of the Oklahoma Human Rights Commission receives, processes, and investigates complaints of discrimination in the areas of employment, housing, and public accommodation.

 

In accordance with the Title 25, Oklahoma Statutes 1991, Section 1101 et seq., the Enforcement and Compliance Division processes employment discrimination complaints on the classification basis of race, color, religion, sex, national origin, age, or handicap.  Employment discrimination complaints concerning age and handicap are additional duties for the Enforcement and Compliance Division with handicap complaints being processed since October, 1981.  The objective of the Oklahoma Human Rights Commission in the area of employment discrimination is to ensure equal opportunity for all persons by prohibiting discrimination that would deprive, limit, or otherwise adversely affect an individual’s status as an applicant or employee.

 

Complaints in either area of employment, housing, or public accommodation may be filed in person or by mail at the Commission offices in either Oklahoma City or Tulsa, or with a member of the Commission offices in either Oklahoma City or Tulsa, or with a member of the Commission.  In employment and public accommodation complaints, the official date of filing, which must occur within 180 days after the alleged discriminatory practice occurs, is the date of personal delivery to either office or to authorized persons, or the postmarked mailing date.  If all jurisdictional requirements are met, the official complaints will be investigated by the Enforcement and Compliance Division of O.H.R.C.  The Division’s findings will be reviewed by the Executive Director who will be reviewed by the Executive Director who will indicate concurrence, non-concurrence, or return the complaint to the Division for additional investigation.

 

When a complaint is initially brought to the Commission’s attention, a Commission intake officer will hear the complaint, provide the Complainant with information or assistance, and determine if the complaint is within the Commission’s jurisdiction.  If the complaint is determined to be within the Commission’s jurisdictional requirements, the Commission intake officer will continue to interview the individual wishing to file the complaint in order to ascertain additional information.


B.      Sexual Harassment

(Example of a Sexual Harassment Policy)

 

(Agency Name) is committed to providing its employees with a working environment free of discrimination.  In keeping with this policy, (Agency Name) will not tolerate any sexual harassment of its employees by supervisory personnel, co-workers, subordinates or third parties who deal with (Agency Name).  All employees must be diligent in preventing such conduct.

 

The following is a sample list of prohibited practices:

 

Abusing the dignity of an employee through unwelcome, insulting or degrading sexual remarks or conduct;

 

Threats, demands or suggestions that an employee’s work status or any employment decisions affecting an employee is contingent upon his/her tolerance of or acquiescence to sexual advances or requests for sexual favors;

 

Substantially interfering with an employee’s work performance or creating an intimidating, hostile or offensive work environment;

 

Sexual relationships in the work place which adversely affects the employment opportunities of other employees; and

 

Retaliation against employees for complaining about such behavior, furnishing information or participating in any manner in any investigation of such behavior.

 

1.   The Executive Director is responsible for administering this policy.  If an employee believes that he/she has been or is being harassed, the employee should immediately contact his/her immediate supervisor.  The supervisor will file a report with the Executive Director.  However, employees can come directly to the Executive Director to discuss these issues.  If the complaint is against the Executive Director it can go to the President of the Board.  Complaints of sexual harassment must be made in writing and signed by the complaining party and must detail the facts of the incident.  (Agency Name) also encourages employees who believe they are being harassed to notify the offender promptly and firmly that his/her behavior is unwelcome.

 

2.  The Executive Director has the responsibility of investigating and resolving any complaints of sexual harassment.  All complaints will be fully investigated and, where necessary, appropriate action taken.  All actions taken to investigate and resolve such complaints are conducted in the strictest confidence where able unless otherwise authorized by the complaining party.  Upon completing the investigation, (Agency Name) will communicate its findings and intended actions to the complaining party and the party accused of engaging in the harassment.

 

3.  (Agency Name) considers sexual harassment to be a very serious matter.  Any employee found to have sexually harassed another employee will be subject to disciplinary action, up to and including termination.

 

4.  (Agency Name) does not condone sexual relationships between supervisors and their staff.  If such relationship develops, the supervisor must disclose the relationship and identity of the employee to the immediate supervisor and the Executive Director.  The supervisor may not participate in personnel decisions involving the employee.  In addition, if such a relationship develops one of the individuals must transfer to another position within the organization if one is available, or leave the organization.

 

5.  The agency will make reasonable efforts to ensure that all employees are familiar with this policy and know that any complaint received will be thoroughly investigated and appropriately solved.


C.      Universal Precautions

FOLLOW UNIVERSAL PRECAUTIONS

 

Universal precautions are procedures developed by the Centers for Disease Control and Prevention (CDC) and incorporated into the Office of Safety and Health Administration (OSHA) guidelines.  These procedures state that workers should treat all blood and body fluids as infectious.  Workers should practice universal precautions whenever they may be exposed to blood or other body fluids.  This rule is important because it is usually impossible to tell if the person you come in contact with is infected with Hepatitis B Virus (HBV) or Human Immuno Deficiency Virus  (HIV).

 

In an emergency situation when you cannot identify body fluids or tell whether they contain blood, treat all body fluids as potentially infectious.

 

Gloves:

1.  Use well-fitting disposable latex gloves for any task involving exposure to blood or any other body fluids.  Make sure extra pairs are available.

2.  Before putting on gloves, make sure they are intact with no holes, cracks, or tears.

3.  Change gloves if they become torn or dirty.

4.  Change gloves between contacts with different people.

5.  Remove gloves by grasping the cuffs and pulling them off inside out.

6.  Dispose of used or soiled gloves in identifiable medical-waste containers.  Wash hands following glove removal.

7.  Use utility gloves when handling containers of waste, broken glass, or other sharp objects and when cleaning spills.

8.  Utility gloves should be discarded in fluid-resistant containers when soiled or old.

 

 

Masks, Eyewear, Gowns

1.  Wear a mask and safety glasses (or a face shield) if you could be splashed with blood or other body fluids.

2.  Appropriate protective clothing such as gowns, aprons, lab coats, clinic jackets, or similar outer garments should be worn in occupational exposure situations.

 

HOW CONTACT WITH THESE VIRUSES CAN OCCUR ON THE JOB

You can be exposed to HBV and/or HIV if you have direct contact with infected blood or other body fluids in one or more of the following ways:

 

1.  Being stuck by infected needles or other sharps.

2.  Having infected blood or other body fluids splashed

-    into mouth, eyes, or nose

-          onto skin that is cut, scratched, or has sores, rashes, or other

     skin  conditions

3.  Being bitten by a human

-    saliva carrying HBV may be infectious

 

Human Immuno Deficiency Virus (HIV)/Acquired Immune Deficiency Virus (AIDS)

HIV and AIDS are already affecting many large and small business.  Other businesses are preparing for the impact of the AIDS epidemic.  Business owners and managers are gathering information, talking with their trade and professional associations, learning more about HIV/AIDS, and preparing strategies for HIV/AIDS programs suitable for their companies.

 

What is an HIV/AIDS policy?

An HIV/AIDS policy defines your company’s position and practices as they relate to an employee with HIV infection.  Businesses that have addressed the HIV/AIDS issue suggest that it is useful to have a written policy stating the company’s position and procedures that tell employees what is expected of them.  An HIV/AIDS policy:

 

* is the foundation for your entire HIV/AIDS program

* establishes consistency within the company

* is the standard for communication about HIV/AIDS

* sets standards of behavior expected of all employees

* lets all employees know where to go for assistance

* instructs supervisors on how to address HIV/AIDS in their workplace

 

It is not complicated or difficult to develop an HIV/AIDS policy.  A company can accomplish this through a specific HIV/AIDS policy or as a section of a life-threatening illness and disability policy.  A policy does not provide you with an entire HIV/AIDS program, but it is the foundation upon which a strong program can be built.

 

In some companies, a crisis such as work stoppage, general discrimination, or coworker fear might occur when an employee discloses that he or she has HIV.  A well-constructed policy outlines the employee’s expectation of supervisors, the employee with HIV infection or AIDS, and the coworkers.  The best prevention for such a crisis is education.

 

Having your policy in place before a case of HIV/AIDS arises is essential.  However, if you are confronted with a situation in which you need to make immediate decisions concerning HIV/AIDS in your workplace, the best advice is to stay calm, assess the resources available to you, and determine the best course of action.

 

In order to create a policy that best reflects your company’s needs, make sure you are aware of certain medical and legal issues associated with HIV/AIDS.

 

The Medical Facts

HIV cannot be transmitted through casual contact.  That means that a person cannot become infected with HIV from a handshake, a sneeze, a hug, or from sharing cups and dishes, tools, telephones, computer keyboards, bathroom facilities, or drinking fountains.  You cannot simply “catch” HIV from air, food, water, insects, or animals.  Your policy should make these facts very clear.

 

HIV, the virus that causes AIDS, is transmitted in the following ways:

 

* by having sexual intercourse (vaginal, anal, or, oral) with a man or woman who is infected with the virus.

 

* by sharing needles or syringes with someone who is infected with the virus

 

* from an HIV infected woman to her child during pregnancy or childbirth, or in rare cases, through breast feeding (this risk can be reduced significantly with new drug therapies)

 

* by receiving HIV infected blood, blood products, plasma, or transplanted tissues or organs (this has been very rare since 1985, when blood centers across the nation were required to begin testing all donated blood for presence of HIV antibodies

 

* by blood-to-blood contact with a person infected with HIV when no physical barrier such as vinyl or latex gloves are used.

 

The Legal Issues

Federal Law and The Americans with Disabilities Act (ADA)

 

The Americans with Disabilities Act (ADA) of 1990 covers HIV and AIDS as disabilities subject to the requirements of the law.  Any business which “affects commerce” is subject to the ADA’s requirement prohibiting employment discrimination accommodations.  The ADA’s requirement prohibiting employment discrimination covers all businesses which have had 15 or more employees working at least 20 weeks in the current or preceding calendar year.  The Rehabilitation Act of 1973 prohibits discrimination against persons with disabilities, including persons with HIV and AIDS by entities receiving federal financial assistance.

 

Under ADA and the Rehabilitation Act, a covered employer may not refuse to hire a qualified applicant who can perform the essential job functions with or without reasonable accommodations because the applicant has or is perceived to have a disability - including HIV/AIDS. 

 

The law also requires that the employer provide reasonable accommodation - such as job modifications, flexible scheduling, and leaves of absence - to allow an employee with HIV/AIDS to continue to perform the essential job functions, unless such accommodations create an undue hardship for the business.

 

Employers must ensure that applicants or employees with a disability covered by the ADA are not subject to discrimination in hiring, job assignments, performance appraisals, eligibility for benefits, termination, and any other terms or conditions of employment because of their disability.  These antidiscrimination provisions also apply to an applicant or employee who is related to, is a care giver for, or is associated with an individual with a disability, even through volunteer work.

 

Enactment of the ADA provides additional information needed for workplace policies about disabilities and for training supervisors regarding the importance of confidentiality and sensitivity to the problems of such employees.

 

Integrating HIV/AIDS Within Existing Policies

Some employers include their HIV/AIDS policies within general company policies on life-threatening illnesses or disabilities.  These organizations take the point of view that since there is no reason to treat HIV/AIDS differently from other major illnesses, a policy covering all life-threatening illnesses is preferable.  Generally, HIV/AIDS, cancer heart disease, or other life-threatening illnesses are cited in such policies.

 

Some employers prefer this approach because it affirms their concern about all major life-threatening illnesses without singling out or favoring one over another.  However, HIV/AIDS can be cited as one example of the types of illnesses addressed by the policy.  Some employers are now expanding their policies around life-threatening illnesses and disabilities to conform to the ADA.

 

Developing an HIV/AIDS-Specific Policy

Many employers have developed their policies to focus specifically on HIV/AIDS.  This approach acknowledges that HIV/AIDS is a major health issue and highlights the employer’s commitment to addressing it in an appropriate way.  These policies acknowledge the potential impact of HIV/AIDS in the workplace.  They also address employee concerns that are specific to this disease by stating clearly that HIV/AIDS is not transmitted through casual contact and that employees with HIV/AIDS are not a health risk to their own co-workers.

 

As with more general life-threatening illness policies, HIV/AIDS-specific policies protect the rights of employees who may be infected, provide guidelines for management, and encourage sensitivity and understanding among co-workers.  Yet, by addressing the issues that are specific to HIV/AIDS, the policies can help to alleviate employee fears and misperceptions that may be specific to this disease.  The policy itself represents the basic principles of an educational program about HIV/AIDS.

 

The Components of Your Policy

Most successful HIV/AIDS policies are divided into two components..  What is contained in each component depends on how you want your policy to be presented.

 

Component 1

The first component includes a general policy statement that clearly sets forth your position on HIV/AIDS or life-threatening illnesses.  This section identifies and highlights the major issues, whether you choose the HIV/AIDS-specific approach or the integrated policy approach.  Component 1 states generally what the policy is about.

 

Component 2

The second component establishes specific procedures that provide step-by-step guidance for managers and employees to clarify what is expected of them.  In this sections, you may want to expand on some of the issues identified in your general policy statement, explaining how they apply to the way your organization operates.  This component states how the policy should be carried out.

 

Writing Your Policy

Successful HIV/AIDS policies can cover numerous pages or can be as short as one page.  Some may be parts of existing policies, and others provide detailed and precise instructions and procedures.  Whether the policy is long or short, concise or detailed, general or specific, the effectiveness of an HIV/AIDS policy will be influenced by the company’s philosophy and implementation.

 

Issues to Consider While Developing Your Policy

All successful HIV/AIDS policies address issues of concern to employers and employees alike.  These may include:

 

Discrimination

A simple statement can be used to establish a policy which complies with the provisions of the ADA.

 

Sample:

(Company name) does not discriminate against a qualified individual with a disability with regard to job applications, hiring, advancement, access to special equipment, discharge, compensation, training, or other terms, conditions, or privileges of employment.

 

Desire and Ability to Work

Increasingly, employers are recognizing that employees with life-threatening illnesses or other disabilities are often physically able and want to continue to work.  This can be acknowledged in HIV/AIDS policies or general life-threatening illness policy by saying:

 

Sample:

(Company name) recognizes that employees with HIV/AIDS (or some other life-threatening illnesses) may continue to engage in as many of their normal pursuits as their illness allows, including work.

 

Some policies go further by saying:

 

Sample:

Management is sensitive to the fact that continued employment for an employee with HIV/AIDS (or other life-threatening illnesses) sometimes may be therapeutically important in the remission or recovery process or may help to prolong that employee’s life and that such an employee is valuable to the workplace.

 

These statements provide reassurance that the company supports employees with HIV/AIDS or other disabilities.

 

Many employers suggest that your policy be reviewed for legal and Equal Employment Opportunity considerations before implementation to be sure that it reflects the law accurately.

 

When everyone who participated in developing your policy agrees with the final draft, be sure to get support from top management - and union leaders where appropriate - so that the final policy is officially endorsed.

 

Having an HIV/AIDS policy prepares you to deal with HIV/AIDS in your workplace smoothly, responsibly, and cost-effectively.  Though some people in your organization may not think a policy is necessary, most will respect your leadership and appreciate the direction and clarity that your policy provides.  Now HIV/AIDS issues in your workplace can be addressed with confidence.

 

10 Principles for the Workplace

1.  People with AIDS or HIV infection are entitled to the same rights, benefits, and opportunities as people with other serious or life-threatening illnesses.

2.  Employment practices must, at a minimum, comply with Federal, State, and local laws and regulations.

3.  Employment practices should be based on the scientific and epidemiological evidence that people with AIDS or HIV infection do not pose a risk of transmission of the virus to coworkers through ordinary workplace contact.

4.  The highest levels of management should unequivocally endorse nondiscriminatory employment practices and education programs or information about AIDS.

5.  Small-business owner/managers should communicate their policies and practices to workers in simple, clear, and unambiguous terms.

6.  Small-business owners/managers should provide employees with sensitive, accurate, and up-to-date information about risk-reduction.

7.  Small-business owners/managers and coworkers must protect the confidentiality of employee’s medical/insurance information.

8.  To prevent work disruption and rejection by coworkers of an employee with AIDS or HIV  infection, small-business owners/managers should undertake education for all employees before such an incident occurs and as needed thereafter.

9.  Small-business owner/managers cannot require HIV screening as part of pre-employment or general workplace physical examinations unless screening is required of all applicants.  HIV infection may not be used as a consideration in hiring, promoting or firing an employee.  No employer may request information about an employee’s HIV status in the course of making these decisions.  The only criterion that may be used legitimately, even if the employer knows about an employee’s HIV status, is the criterion that applies to hiring, promotion and firing decisions about all disabled employees:  is the person otherwise qualified to do the job?  If the answer is yes, the employee cannot legally be fired, because of the disability.

10. In those special occupational settings where there may be potential risk of exposure to HIV (for example, in some health care settings), small-business owners/managers should provide specific, ongoing education and training, as well as the necessary equipment, to reinforce appropriate infection-control procedures and ensure that they are implemented.

In certain occupational health care settings, specific procedures should be made available to any employee who has had an exposure incident.  Should there be percutaneous exposure (e.g., needle stick), the exposed employee may take a post-exposure therapy.

11. The Americans with Disabilities Act does not:

·       provide an advantage to a  person with a disability in applying for a job or a promotion.  Rather, it prevents discrimination against an otherwise  qualified individual with a disability.

·       Prevent an employer from using progressive discipline, including termination, when a person with a disability is not fulfilling the essential functions of the job, with or without reasonable accommodation.

·       Provide “special  rights” to persons with disabilities in the workplace.  Rather, it levels the playing field so that persons with disabilities may compete equally with non-disabled individuals in the marketplace.

 

THE ADA DOES NOT GUARANTEE ANYONE’S JOB.

 

Confidentiality of Medical Information

l.       In the workplace, a person who is HIV-infected is not obligated to    reveal his or her diagnosis to anyone, with rare exceptions.  Disclosure is a personal decision.  Nevertheless, respecting confidentiality of medical information is a skill many employers and co-workers need to learn. 

2.    If a co-worker tells you about a positive HIV test, you do not have the right to share that information with others unless the HIV-infected person explicitly tells you that you have the right.  If, as a supervisor, you disclose someone else’s HIV status without that person’s permission and the disclosure leads to discrimination, your employer becomes potentially liable.  It is not legitimate to disclose because a supervisor or anyone else has a “right to know” or a “need to know”. Neither the right nor the need exists.

3.    If a supervisor is concerned about a medical condition that could be contagious – a concern frequently expressed about tuberculosis, now that its incidence is rising – then the employer ay request that the employee provide certification from the treating physician about accommodations the employee requires, without ever naming the condition.  Of course, this is true for all diagnoses, not just for HIV infection.  All employees’ privacy is protected by this law.


 

D.              Confidentiality

General Principles

 

1.                The consumer has fundamental right to privacy and confidentiality in his/her relationship with a provider agency and staff.  It is the provider agency and its staff’s responsibility to protect the consumer’s privacy and confidentiality.

 

Consumer-staff relationships should be governed by mutual trust, respect, courtesy, honesty, and confidentiality.

 

2.                Privacy and confidentiality are the privileges of the consumer, so only he or she, or legal designate, may waive them, in an informed, meaningful and non-coerced fashion.

 

Release of information for a specific purpose should not require waiver of the total right to privacy and confidentiality.

         

3.                An individual’s rights to privacy and confidentiality should not be compromised.

 

4.                Conflict between a consumer’s right to privacy and a third party’s need to know would be resolved in favor of the consumer’s privacy and confidentiality. If the consumer makes threats that may result in serious harm to his or her self and/or others it must be reported to the appropriate authority.

 

5.                The development and acceptance of new information technologies should include measures that strengthen, not jeopardize, consumer privacy and confidentiality.

 

6.                The provider agency has an ethical responsibility to understand issues of privacy and confidentiality, educate their staffs, and make reasonable efforts to inform their consumers of these issues.


612:10-1-5.        Confidentiality

 

(a) General guidelines. All client or applicant information acquired will remain the property of DRS. All casework materials are to be maintained in the appropriate case record. The terms “release of information”, “release of personal information”, and similar terms refer to providing access to the record, or providing copies, summaries, descriptions, or other reproductions of the actual case record materials and not to the materials themselves. All applicants, clients or client representatives will be informed of the Department’s policies on confidentiality of personal information. This information will only be used and release for purposes directly related to the administration of the Vocational Rehabilitation and Visual Services programs. Information containing identifiable personal information will not be shared with advisory or other bodies who do not have official responsibility for the administration of these programs. In the administration of the program, the DVR and DVS units may obtain personal information from service providers and cooperating agencies under assurances the information will not be further divulged. Use and release of personal information will conform to applicable state and federal laws and regulations. Questions regarding release of information are to be directed to the Department’s general counsel.  Staff are to consult the general counsel before providing trial testimony, depositional testimony, or a sworn affidavit concerning consumer information.  Moreover, if serviced with a subpoena for the release of client information, staff should notify the general counsel immediately. In a legal proceeding, client information can only be released without the client’s consent in response to a court order.

 

(b) Written release required. Release of personal information must be by written consent of the individual or authorized representative. The Department’s Authorization for Release of Information form is provided for this purpose, and may also be used to request confidential information from other sources. Other release forms are acceptable, as long as they provide the required information. Written authorization for release of information must include:

 

            (1) the nature of the information to be released;

            (2) designation of the parties to whom the information is to be released;

(3) the specific purpose for which the released information may be used;

(4) designation of the agency or person authorized to disclose the information; and

(5) dates of initiation and termination of consent.

 

(c)     Release of information to the individual. The individual, or the individual’s representative, will be given access to the relevant case record, or provided copies of requested information upon providing a written authorization for   release of information, except as in (1) through (3) of this Subsection.

 

(1)            The individual is or has been a patient of a physician, psychologist, mental health institution or facility, a drug or alcohol abuse treatment facility or service, a community mental health service or agency or a community social service agency for the purpose of mental health or drug or alcohol abuse care and treatment, and the requested information was copied from his or her psychiatric or psychological records. Under these circumstances, refer the individual, or the individual’s representative, to the treating health professional.

 

(2)            When a DRS professional staff person believes medical or other information not covered in (1) of this Subsection may be harmful to the individual, the information may not be released directly to the individual but must be provided through his or her representative, a physician, or a licensed/certified psychologist.

 

(3)            Information obtained from another organization or agency may be released only through that agency, or under the conditions established by the outside agency, organization or providers. Information from the Veteran’s Administration, Social Security Administration, information regarding the diagnosis and treatment of AIDS, or drug treatment of veterans may not be released. Refer the individual requesting such information to the source from which the information was obtained.

 

(d)            Request for information correction. An individual who believes that information in the individual’s case record is inaccurate or misleading may request that the information be amended. Even if the information is not amended, the request for amendment must be documented in the case record.

 

(e)             Release of information to other programs or authorities. Paragraphs (1) through (4) of this Subsection provide the rules governing release of personal information to other programs or authorities.

 

(1)            Upon receiving the informed written consent of the individual, or the individual’s representative, information may be released to another agency or organization. Only that information that would be released to the involved individual, or the individual’s representative will be released, and only to the extent that the other program or organization demonstrates that the information requested is necessary for its program.

(2)            Personal information will be released if required by Federal law or regulations.

(3)            Personal information will be released in response to investigations in connection with law enforcement, fraud, or abuse, unless expressly prohibited by Federal or State laws or regulations, and in response to an order issued by a judge, magistrate, or other authorized judicial officer.

(4)            Personal information may be released in order to protect the individual or others if the individual poses a threat to his or her safety or to the safety of others.

 

(f)              Release of information for audit, evaluation or research. Personal information may be released to an organization, agency, or individual engaged in audit, evaluation, or research, only:

 

(1)            for the purposes directly connected with the administration of the DVR or DVS program;

(2)            for purposes which would significantly improve the quality of life for persons with disabilities; and

(3)            if the organization, agency or individual assures:

(A)          The information will be used only for the purpose it is being provided;

(B)          The information will be released only to persons officially connected with the audit, evaluation or research;

(C)          The information will not be released to the individual;

(D)          The information will be managed in a manner to safeguard confidentiality; and

(E)           The final product will not reveal any personal identifying information without the informed written consent of the involved individual or the individual’s representative.

 

Taken from the State Department of Rehabilitation Services/Vocational Rehabilitation and Visual Services manual, effective 7-1-99.


E.      THE BUSINESS ADVISORY COUNCIL (BAC)

 

What is a BAC

The Business Advisory Council (BAC) is a group of people who serve to advise and facilitate placement efforts. The BAC can serve many functions.

 

Advisory Function of the BAC

§       The BAC can help identify the growth industries in a community.

§       The BAC can help identify particular businesses or locales to target for placement efforts.

§       The BAC can provide guidance to your agency about the types of skill and job training needed by job applicants.

§       The BAC can provide guidance on client pre-employment                   training (e.g., “Job Club”).

 

Public Relations Function of the BAC

The BAC can serve in a public relations capacity:

§       The BAC can take on formal efforts in the community through BAC-sponsored public service announcements.

§       BAC members can be used to make initial contacts with other (new) employers on behalf of your agency.

§       BAC members can deliver information/testimonial presentations at their trade association and related meetings.

§       The BAC can organize participation in “job fair” activities with your agency.

§       The BAC may assist in fundraising efforts for your placement programs.

 

Training Assistance Function of the BAC

The BAC can assist in your agency’s pre-employment training efforts with job candidates:

§       The BAC, in addition to identifying the skills and training needed by job applicants, may be able to provide actual training sites.  This may be in the form of OJT or special programs set up by the BAC members.

§       The BAC can prove a valuable resource in conducting “Job Club” type training. The benefits for using real employers in job interview role-plays and application reviews cannot be surpassed.

§       TheBAC may help to identify, develop and refine “disability awareness training” and related special community training efforts.

 

Organizing Document

 

Before you begin considering the practical aspects (e.g., size, composition, recruiting) of your BAC, take the time to develop an organizing document to guide your efforts.

 

The organizing document should specify the overall purpose of your BAC. It should also list specific goals or objectives and the activities your BAC will be responsible for to meet these needs.

 

This document is, in fact, a “working plan” and should reflect your agency’s needs and goals.

 

A sample “Organizing Document” may be found  at the end of this chapter.

 

Size

The BAC should be manageable in size depending on the activities it will participate in and the size of the community targeted. An important consideration should be the number of agency staff available to conduct the “detail” work required to keep the BAC active.

 

As a rule of thumb, each sub-committee to the BAC should be made up of 3-7 members. The total BAC should consist of approximately 10-20 members for ease of operation. A larger group of members may be invited to participate for yearly meetings aimed at enhancing community awareness.

 

Composition

Your BAC should be developed to meet your needs. The BAC should consist mostly of employers; keep agency representatives to a minimum. You should include several employers with whom you have a firmly established successful relationship.  One or two employers from the growth industries in your community should be included. Representatives from service industries (e.g., restaurants and related; hospitality industry; health services) should also be invited to join. Where possible, a program administrator

from local vocational-technical trade schools should be included. This person may be able to offer specific training assistance in addition to job lead contacts.

 

The skills of your BAC membership should reflect your needs in the three function areas listed above (advisory, public relations, training). If your agency wishes to set up additional separate committees (e.g., fundraising), members should be solicited with skills to address these special needs.

 

Recruiting Members: Develop a Contact List

In determining the composition of your BAC, you will no doubt have names of specific people as well as vague references to the types of industries or business you want as members. Begin recruitment efforts by meeting with one of the employers you have a solid relationship with.  Ask this employer to identify people to contact in the businesses you have identified. This should result in a list of names to work with (where possible identify “alternates” in the event that some employers turndown your request).

 

Recruitment Contacts

Once you have your potential members listed you should:

1.    Make initial contact in person (by appointment) or by telephone. A letter at this stage is too impersonal to encourage employers’ enthusiasm. Where possible, name a referral source:

“Mr. Jones from ACME services recommended that I contact you. He thought you would be interested in this opportunity...”

2.    Give a brief description of your agency citing what it is (goals), and who it serves.

3.    Use your Organizing Document to describe the purpose and goals of your BAC. Describe the activities BAC members will be involved in. Stress the importance of the BAC activities for insuring success in achieving your goals.

4.    Give additional specifics (e.g., how often the BAC will meet, what time of day, where, etc.). (These specifics are discussed later in this chapter). Let the potential BAC members know what this commitment will require – this will help them to make an informed decision.

5.    Follow up your initial contact with a letter summarizing the information discussed. You may wish to include your organizing document (you may want to call it a “Steering Document”). Include promotional material describing your agency and services as well.

 

Structure

For the most part, the day-to-day activities and organization of your BAC will be your responsibility. Therefore, it is advisable to keep the structure simple.

 

§       For the first several meetings, you must determine the agenda and run the meetings. Under your guidance, your BAC should evolve on its own and may conform to one of the following structures:

 

Board of Directors

§       President/Chairperson

§       Vice President/Vice-Chairperson

§       Secretary

§       Committees Report to Chairperson

 

Committee Structure

§       BAC Chair/President

§       Committee Chairs

(e.g.)      Public Relations

              Training

              Labor Market Trends

              Fundraising, etc.

 

In either situation, it is advisable for your agency to serve in a “recording secretary” fashion to keep written records of meetings, activities and assignments. This would be done at the BAC Chair’s discretion. You or your agency designate will be responsible for

keeping in close contact with your BAC chairperson. Preparing for the First Meeting of Your BAC.

 

Meeting Frequency

The members of your BAC will be people with busy schedules. You want your BAC meetings to occur regularly (to maintain interest and activity levels) and at a convenient time.

 

Many agencies have found evening meetings (e.g. 6-8 pm) to be the best attended. This allows for people who leave work at 5:00 pm to grab a quick bite to eat before attending. It also reduces the BAC “refreshment budget” to coffee, tea, and light snacks.  Others recommend a lunch meeting (11:30 – 1:00 pm). A lunch meeting is best when agenda items are few and brief.  It is possible that smaller committee meetings can be held during lunch with full BAC’s convening during the early evening.

 

Unless your BAC is highly involved in an activity, there is no need to meet more than quarterly (i.e., every 3 months). Committee meetings may occur on a more frequent basis of needs, e.g., the Public Relations Committee may have plans for “National Employment of Persons with Disabilities” month (October) or “Better Hearing and Speech Month” (May) that would require more meetings.

 

1.    Be sure the room is clean and set up with the correct table/chair configuration (horseshoe or “U” is recommended). Any A.V. needs (overhead, VCR) will need to be set up and tested prior to the meeting.

2.    Arrange for coffee, tea and possibly a light snack (e.g., cookies) to be available. Include napkins, cups, sugar, sugar substitute, etc.

3.    Develop the agenda and handout materials. The first meeting will “set the tone” for future meetings (and therefore affect member commitment to the BAC).

 

Your agenda should be as action-oriented as possible. See the following sample agenda for guidance.

 

Sample Agenda

 

Your Agency Business Advisory Council Meeting

 

Date: 00/00/00

 

I.                  Welcome and Introductions

§                     Agency Staff

§                     BAC Members

II.                 BAC Purpose

III.               Goals/Activities

§         Plan of operation

IV.       Assignments

 
 

 

 

 

 

 

 

 

 

 

 

 


Handout Materials for First Meeting

BAC members should each be given a file on which you have typed “Agency BAC” on the tab.

 

Within the folder there should be:

§       Agenda

§       Promotional material describing your agency

§       Your business card (taped on the left side cover) or a list of contact people

§       A list of all BAC members, including job title and address

§       Any articles written about your agency or your job candidates

 

Conducting the First Meeting

Begin the meeting promptly at the specified time (indicate in your letter that refreshments will be available from 5:30 – 6:00 pm, meeting will begin at 6:00 pm).

 

§       Follow your agenda. Give opportunities for questions and suggestions, but gently direct discussion to avoid random tangential discussions.  At those times, you might indicate that “These are great ideas and we are taking them down.  At the next meeting will arrange for time to discuss them in more depth. This will give me/my staff time to do some background research."” You might also arrange for a separate meeting to discuss these topics.

§       Make assignments in clearly identifiable terms. These can be typed up and mailed to members in the minutes (have blank “assignment” forms available to be sure that these are written).

 

Sample (Completed) Assignments Form

 

 

 

Assignment                          Who?                     By When?

 

1.  Contact new                     Mr. Jones              Date

industrial park                                                       (agreed

developer to                                                          upon)

get list of

tenants going

in

2.        Develop new                 Mr. Smith               Date

brochure

 
 

 

 

 

 

 

 

 

 

 

 

 


§       End the meeting promptly on or before the assigned time. If there are agenda items yet to be covered, put them on a list to be addressed by committee in the interim between meetings (or postpone until next meeting).

 

REMEMBER

How you handle your BAC will often tell BAC members more about your agency than what you tell them.

 

              BE ORGANIZED

              BE EFFICIENT

              FOLLOW-UP PROMPTLY

 

Make use of your BAC members. Most people need to be needed. In this situation, your BAC members will prefer to be overutilized than not utilized at all. Few BAC members will need the BAC to “look good on a resume”.  They will be interested in projects with goals and objectives that they can actively contribute to.

 

KEEP THE ACTIVITY LEVEL HIGH

 

TAKE ADVANTAGE OF YOUR BAC TO MEET YOUR NEEDS

 

The key to maintaining an active BAC is in maintaining the interest of your members. Specific attainable goals can be developed for each committee identified. Frequent utilization of the BAC will keep members interested and active.

 

 

 

 

 

 

Agency

 

Business Advisory Council

Organizing Document

 

Purpose:  To assist agency’s efforts to secure employment for its job candidates.

 

Objectives/Activities

 

Objective 1  To aid agency in determining the changing labor market needs in this community.

Activity:  Committee will be formed to track and report on employment trends.

 

Objective 2  To aid agency in identification of and access to particular businesses and companies experiencing growth.

Activity:  Committee will be formed to identify growth industries and initial contracts made on behalf of agency.

 

Objective 3  To assist agency in providing accurate pre-employment training to its job candidates.

Activity:  Committee will be formed to advise agency on areas of vocational skill training being required by employers in the community.  Where possible, BAC members will identify avenues for accessing such training for agency job candidates.

Activity:  Members of BAC will be asked to serve as interviewers for “mock interview” practices.

 

Objective 4  To promote agency programs and job candidates within the business community.

Activity:  BAC members will promote agency at trade association meetings and other gatherings of potential employers.

Activity:  Committee will be formed to address long range public relations program in the community.