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Published by admin, 2017-12-05 10:50:10

Clinician Handbook

This handbook provides information that is relevant and important to employees and contractors.

2017

Clinician Handbook

Sky Nurses
12/4/2017

0

Contents

Company........................................................................................................................................................... 3
Introduction.................................................................................................................................................... 3
About this Handbook.................................................................................................................................. 3
Purpose of this Handbook.......................................................................................................................... 3
Administrative Basics..................................................................................................................................... 4
Availability of Sky Nurses Office Staff ........................................................................................................ 4
Administrative Staff .................................................................................................................................... 4
Corporate Social Responsibility Statement .................................................................................................... 4
Corporate Social Responsibility within Sky Nurses .................................................................................... 5
Health and Safety ...................................................................................................................................... 5
Human Rights, Employment/Contract, and Ethics...................................................................................... 5
The Environment ....................................................................................................................................... 6
The Statement ............................................................................................................................................... 6
Our Mission, Vision, Values ....................................................................................................................... 7
Policy and Procedures................................................................................................................................... 7
Policy Changes.......................................................................................................................................... 7

Human Resources............................................................................................................................................. 8
Status ............................................................................................................................................................ 8
At-Will Employment.................................................................................................................................... 8
Contractors ................................................................................................................................................ 8
Equal Opportunity .......................................................................................................................................... 8
Americans with Disabilities Act ...................................................................................................................... 9
Employees................................................................................................................................................. 9
Contractors ................................................................................................................................................ 9
Personnel Files.............................................................................................................................................. 9
Access to Personnel Files........................................................................................................................ 10
Recordkeeping......................................................................................................................................... 10
Reference Responding ............................................................................................................................ 10
Releasing of Information .......................................................................................................................... 11
Social Security Number (US Citizens Only) ................................................................................................. 11
Background Screening ................................................................................................................................ 12
Health Information ....................................................................................................................................... 13
Assessing Competency at Sky Nurses ........................................................................................................ 14

Corporate ........................................................................................................................................................ 15
Non-Disclosure Agreement.......................................................................................................................... 15
Non-Compete .............................................................................................................................................. 16
Information Technology ............................................................................................................................... 16
Information Security ................................................................................................................................. 16
Conflicts of Interest ...................................................................................................................................... 17
Liability Insurance ........................................................................................................................................ 18
Nurses Services Organization (NSO)........................................................................................................... 19
Liability and Legal Protection for Good Samaritans...................................................................................... 19

pg. 1

United States Law.................................................................................................................................... 19
International Law ..................................................................................................................................... 20
Repatriation Insurance................................................................................................................................. 20
Corporate Responsibilities............................................................................................................................... 21
Ethics Line................................................................................................................................................... 23
Standards of Conduct .................................................................................................................................. 23
Ethics Policy ................................................................................................................................................ 25
Attendance .................................................................................................................................................. 25
Anti-Harassment.......................................................................................................................................... 26
Sexual Harassment Defined .................................................................................................................... 26
Harassment Defined ................................................................................................................................ 26
Customer Service ........................................................................................................................................ 27
Social Media ................................................................................................................................................ 27
Guidelines................................................................................................................................................ 27
Outside Sky Nurses ................................................................................................................................. 28
Sky Nurses Intranet ................................................................................................................................. 28
Retaliation is prohibited............................................................................................................................ 28
Media contacts......................................................................................................................................... 29
For more information................................................................................................................................ 29
Gift Acceptance ........................................................................................................................................... 29
Prohibited ................................................................................................................................................ 29
Payroll ............................................................................................................................................................. 30
Wage and Hour Policies .............................................................................................................................. 30
Compensation ............................................................................................................................................. 31
Employee Wages..................................................................................................................................... 31
Overtime Pay ........................................................................................................................................... 31
Deductions for Employees ....................................................................................................................... 31
Travel Expense for Employees ................................................................................................................ 31
Contractor Payments ............................................................................................................................... 31
Deductions for Contractors ...................................................................................................................... 32
Travel Expenses ...................................................................................................................................... 32
Clinical Requirements...................................................................................................................................... 33
Medical Escort staffing................................................................................................................................. 33
Working before a Medical Escort ............................................................................................................. 33
Performance Review ................................................................................................................................... 33
Dress Code.................................................................................................................................................. 33
Appearance ................................................................................................................................................. 34
Smoking Policy ............................................................................................................................................ 34
Travel .............................................................................................................................................................. 34
Global Entry................................................................................................................................................. 35

pg. 2

Company

Introduction

About this Handbook

Sky Nurses strives to maintain a high level of patient care as a core value by demonstrating our commitment to
excellence and by providing quality care in every medical escort. As a very important factor in our business,
the Commercial Flight Nurse and Allied Staff must meet all requirements and their performance must be
reviewed on an ongoing basis to maintain motivated, dedicated, compassionate caregivers.

This Handbook provides information that is relevant and important to employees and contractors. Most, if not
all of the information is obtained from the following:

• Health Insurance Portability and Accountability Act (HIPAA)
• The Joint Commission (JCAHO)
• International Joint Commission
• Commission on Accreditation of Medical Transport Systems (CAMTS)
• Occupational Safety and Health Administration (OSHA) is general information and not state or country

specific.
• Internal Revenue Service
• United States Department of Labor

Purpose of this Handbook

The purpose of this handbook is to provide you with general information about the clinical guidelines that are
followed at Sky Nurses. While we strive to keep this handbook and our policies up to date, from time to time
discrepancies can occur. In the event this handbook is contradictory with a policy, the policy supersedes this
handbook.

Definitions

• “Company” pertains to Sky Nurses, LLC.
• "Employee" refers to an employee of Sky Nurses, LLC.
• “Contractor” refers to an independent contractor contracted with Sky Nurses, LLC.
• "Handbook" refers to a handbook providing information to employees and independent contractors

employed or contracted with Sky Nurses, LLC.

The information in this handbook should help you familiarize yourself with our organization. Because of the
nature of our operations and variations necessary to accommodate individual situations, the provisions of this
handbook or any related policies, practices or guidelines may not apply to every employee or contractor in
every situation. Sky Nurses reserves the right to rescind, modify or deviate from this or any other policy,
practice or guideline as it considers appropriate in its sole discretion, either in individual or Company-wide
situations, with or without notice. As an employee or contractor, you have an obligation to keep the information
provided to you in this Handbook confidential. No employee or contractor should discuss the contents of this

pg. 3

electronic handbook with a person who is not an employee of Sky Nurses or an individual who does not have a
legitimate reason to know.
This Handbook is not a contract and nothing in this Handbook gives you any right, express or implied, to
continued employment or contract status. Furthermore, all terms, conditions, policies, and procedures as
stated in this document are subject to change, and nothing stated herein is guaranteed to remain a fixed term
or condition of your employment or contract status.
More information about the protocols and procedures summarized in this handbook can be found in the Policy
and Procedure section of the Sky Nurses Clinician Center.

Administrative Basics

Availability of Sky Nurses Office Staff

The Sky Nurses office, located in Boca Raton, FL is open Monday through Friday from the hours of 8:00 am -
6:00 pm. Our local telephone number is (561) 666-6417. Outside of normal business hours and in the event of
an emergency please contact us at the same number listed above. Sky Nurses on-call staff will be available to
assist you.

In the event of an emergency, natural disaster or other uncontrollable event, Sky Nurses will continue to
provide service to you through our network from a location where phones and computers are functional. Sky
Nurses will do everything possible to support you in meeting your needs during a crisis situation(s).

Administrative Staff

Medical Manager

The Medical Manager (Director of Nursing) provides clinical support for all healthcare professionals employed
or contracted by Sky Nurses. The Medical Manager will have an understanding of aviation medicine.

Human Resource Manager

It is the Human Resource Manager’s responsibility to identify and report the aberrant or illegal behavior to
professional boards and law enforcement agencies.

Corporate Social Responsibility Statement

Sky Nurses is committed to creating a successful business and ensuring that impact on the environment is
minimized and that all activities are conducted safely by trained and qualified employees. Sky Nurses is
committed to a Code of Conduct which describes our intention on how to behave when we do business and
how we interact with our clients and patients. Sky Nurses enjoys an invaluable reputation for corporate
trustworthiness around the world, based on consistently conducting business with integrity and in compliance
with the laws and regulations governing its activities.

pg. 4

What is a Corporate Social Responsibility?
It is the obligation of an organization’s management towards the welfare and interests of the society in which it
operates.
Corporate social responsibility (CSR) became popular in the 1960’s. CSR refers to a business practice that
involves participating in initiatives that benefit society. It is a form of corporate self-regulation integrated into a
business model. Many would say that it is about how one makes money rather than how one spends their
money. When discussing the CSR issues, the health sector clearly stands out as a leader.

Corporate Social Responsibility within Sky Nurses

The Sky Nurses Code of Conduct is the corporate policy and general reference document on ethical issues
and appropriate business practices. The Code of Conduct formalizes the principles that Sky Nurses shall
commit in relation to employees, business partners, and other stakeholders.

All Sky Nurses employees and contractors should know about the Code of Conduct since the policy is
applicable to all employees and contractors at all levels.

The following summarizes our policies and procedures.

Overall responsibility for developing corporate policies for social, ethical and environmental matters and for
reviewing their effectiveness lies with the Sky Nurses management team. It is then the responsibility of
individual employees and contractors to communicate and apply these policies to their respective departments
or geographical areas with due regard for legislation to ensure compliance with the policy and to maintain,
review and refine procedures accordingly.

Sky Nurses' policies and procedures, including those relating to social, environmental, health and safety,
employment and ethical matters, are communicated to all staff via the Sky Nurses employee and contractor
network. Policies and procedures are reviewed regularly, and any updates are communicated to staff.

The three (3) key areas of corporate social responsibility at Sky Nurses are:

1. Health and Safety
2. Human Rights, Employment, and Ethics
3. The Environment

Health and Safety

Sky Nurses recognizes its health and safety duties and responsibilities and complies with the relevant health
and safety legislation. The Medical Director and the medical team has overall responsibility for health and
safety. Sky Nurses health and safety policy are communicated to all staff and contractors via the Sky Nurses
employee and contractor network.

Human Rights, Employment/Contract, and Ethics

• It is our policy to adhere to all legislation relating to employment/contractor rights and equal
opportunities, with reference to non-discrimination on the basis of ethnic origin, religion, gender, age,
marital status, disability or sexual orientation.

pg. 5

• We ensure that physical, verbal and psychological abuse, sexual or other forms of harassment towards
employees/contractors are not tolerated. We ensure that disabled persons are recruited, trained and
promoted on the basis of aptitude and ability. If employees become disabled, every effort is made to
retain them and when necessary re-train them for a more appropriate position.

• We pay wages and benefits that meet or exceed national minimum requirements and adhere to working
time regulations where applicable. We do not use forced labor nor employ workers under the school-
leaving age.

• We provide a safe and secure workplace and promote good health and safety and environmental
practices.

• We adhere to applicable laws regarding the freedom of employees/contractors to associate or bargain
collectively without fear of discrimination. All employees/contractors are expected to behave with
integrity and honesty and adhere to the Code of Business Ethics.

• Employees/contractors may freely report any concerns they may have over unethical business
practices or conduct, dangers to health and safety, or breach of company policies. Any such
disclosures are appropriately investigated. In addition, Sky Nurses is committed to protecting the career
and reputation of employees/contractors who report wrongdoing in accordance with established
procedures, as long as their disclosures are delivered in good faith and seek to safeguard the best
interests of the company. We do not give or receive any bribes, extra-contractual gratuities,
inducements, facilitation fees or similar payments.

• We do not give to customers or business contacts or allow employees/contractors to receive any gifts,
whether in cash or kind, unless during normally accepted business entertainment or the subject of prior
written approval by management.

• We do not donate (including sponsorship, subscriptions or provision of employee time or facilities) to
any political party or similar organization. We ensure we purchase legal licenses to all software in use.

• Sky Nurses recognizes the value that its employees/contractors create for the business and its
commitment to training and personal development, together with remuneration policies that are
designed to reward achievement and emphasize the importance of retaining corporate and clinical staff.

• Sky Nurses provides information to employees/contractors on a regular basis. This information includes
matters relating to company performance, its prospects and future outlook for the business.

• Sky Nurses supports local charities and participates in a range of legitimate activities.

The Environment

Sky Nurses is committed to adopting environmentally responsible policies.

The Statement

As a medical escort, your attitude may be the most important factor for job security. A positive attitude is
essential for healthcare providers working in the ever-challenging healthcare industry. A positive attitude and
service excellence will make a substantial impact on the customer care experience and their perception of the
quality of service received. When “We Do Care” is perceived by our patients and their family members, it is a
positive impact on Sky Nurses.

Remember to SMILE and Remember ATTITUDE IS EVERYTHING!!

pg. 6

Our Mission, Vision, Values

Mission Statement

Sky Nurses will cost-effectively plan, manage and safely complete the transport of patients to their home or
nearby healthcare facility using commercial or private aircraft from anywhere in the world at any time.

Our Vision

To be the most respected, trusted and recognized medical transport organization in the world.

Value Statement

As a company, and as healthcare clinicians, we value honesty, integrity, excellence, quality, teamwork, trust,
caring, and compassion. We are committed to our patients and professional partners. We honor our
commitments by striving for the highest quality of patient care.

Policy and Procedures

This Handbook summarizes some of Sky Nurses' key expectations and policies. As such, it cannot provide
guidance for every possible circumstance that may arise during employment or contract and is not intended as
an exhaustive resource for all Sky Nurses policies. Employees and contractors that desire elaboration on
specific policies should refer to official policy documentation or consult a human resources manager.

This Handbook replaces all prior handbooks, express or implied, whether written or oral. In addition, this
Handbook is subject to the provisions of official Sky Nurses policy documents. All Sky Nurses employees and
contractors are required to abide by the terms of this Handbook as a condition of employment or contractor
status.

Policy Changes

As circumstances warrant, Sky Nurses may, in its sole discretion, deviate from the terms stated herein as it
sees fit. Sky Nurses has the express right to amend, modify, revoke, and add to the terms of this Handbook as
well as other official Sky Nurses policy documentation. The terms of this Handbook may only be altered
through official Sky Nurses written policy notices. No terms of this handbook may be altered via oral
statements or other representations. Sky Nurses' interpretation of the terms stated herein is absolute.
Employees and contractors that need clarification as to Sky Nurses' policy on a specific matter should consult
a human resources manager or such designated Sky Nurses officer or manager. Each employee or contractor
is responsible for remaining informed of policy changes.

pg. 7

Human Resources

Status

At-Will Employment

Unless expressly prohibited by statute, all employees without a written employment agreement to the contrary
are employed on an "at-will" basis. Either Sky Nurses or the at-will employee may conclude the employment
relationship with or without advance notice at any time and for any reason, and no term in this Handbook will
alter or restrict the right of Sky Nurses or an at-will employee to end the employment relationship accordingly.
Nothing in this Handbook impairs Sky Nurses' right to make changes in employment status, including, without
limitation, promotions and demotions, reassignments, transfers, and wage and benefit changes.

Sky Nurses may only enter into an employment relationship that is not on an at-will basis through a written
employment agreement signed by the CEO, President, or a Sky Nurses officer or manager authorized with
such capacity by the CEO or President.

Contractors

Nothing in this Handbook creates a binding contract between Sky Nurses and its contractor, nor does it provide
a guarantee of medical escorts. Contract status may only be altered through an express, signed, written
agreement between Sky Nurses and a contractor to that specific and intended effect.

All contractors will be required to sign an Independent Contractor Agreement (ICA). This ICA will be valid for 2
years from the date the contract is signed by both parties. During the contract period, the Contractor will not be
deemed as a servant, employee, partner or joint venture of Sky Nurses for any purpose.

Equal Opportunity

We believe that our continued success depends upon our ability to maintain a leadership role in the attraction,
development, and retention of a highly competent workforce and to create a climate for an effective and
productive use of our human capital. We are convinced the talent exists, across all population groups, to reach
this end. We will conduct our business with due regard to the human dignity and self-worth of each.

Sky Nurses provides equal opportunity in all of our employment and contract practices without regard to race,
color, religion, national origin, gender, age, sexual orientation, gender identity, disability, genetic information,
marital status, military status, or any other category protected by federal, state, or local laws. This includes
prohibiting unlawful discrimination against those associated with or perceived to belong to a protected class,
whether or not an employee falls into such class. Sky Nurses' equal opportunity practices are upheld in every
location that it operates and in all aspects of the employment or contractor relationship.

Equal opportunity violations must be taken seriously, and all Sky Nurses' employees must make every effort to
uphold and support Sky Nurses' equal opportunity policy. This includes reporting all instances of discrimination
or harassment to a Sky Nurses' Manager. Sky Nurses' policy is to investigate discrimination or harassment
promptly.

pg. 8

Americans with Disabilities Act

Employees

Sky Nurses does not discriminate against qualified employees with disabilities in any aspect of their
employment and will provide reasonable accommodations to such individuals as required by law so that they
may perform the essential job duties of the position. Sky Nurses is fully committed to upholding the Americans
with Disabilities Act (ADA) and any amendments or laws related thereto. The ADA requires employers with 15
or more employees to provide qualified individuals with disabilities an equal opportunity to benefit from the full
range of employment-related opportunities available to others. In compliance with the ADA, Sky Nurses does
not discriminate against qualified individuals in recruitment, hiring, promotions, training, pay, social activities,
and other privileges of employment. Sky Nurses also does not ask prohibited questions related to an
applicant's disability prior to making a job offer.

Sky Nurses provides reasonable accommodations for known physical or mental limitations of qualified
individuals that bring their needs to Sky Nurses' attention unless it would cause Sky Nurses' undue hardship. If
you are currently disabled or become disabled while employed, you should notify a human resources manager
to discuss any questions you may have and to request disability leave or accommodations that will enable you
to perform the essential functions of your job. Sky Nurses reserves the right to require that you provide
certification from your health care provider of your disability and your need for accommodation. If disability
leave is necessary, Sky Nurses will work with you to determine how to best accommodate your needs while
also balancing Sky Nurses’ needs.

Contractors

Sky Nurses does not discriminate against qualified contractors with disabilities. However, the disability cannot
be used as a reason for not rendering care to a patient during a medical escort.

A contractor with a disability must not be required to have medical clearance to board a commercial airline.

Personnel Files

The Company maintains complete and accurate employee and contractor records for business purposes.
Personal information that the Company obtains about employees and contractors is carefully protected and
shared only with those who have a legitimate need for it. It is the Company’s practice to handle personal
information in a confidential manner.

An employee or contractor file is comprised of documents and information related to each individual's
relationship with Sky Nurses, including among other items, the employment or contractor application,
employment or contract history verification documents, resumes, background checks, emergency contact
information, contracts of employment or contractor status, tax forms, payroll and benefits information, and
performance reviews, if any of these should exist and according to Sky Nurses policy.

You are required to notify human resources, as applicable, should any information provided to Sky Nurses
change, including information provided on an employment application or form, insurance form, or tax form.

pg. 9

Misrepresenting information in your employee or contractor file, or failing to correct a known mistake in your
file, is grounds for discipline, including termination of employment or contractor status.

Access to Personnel Files

Unless otherwise required by state law, current and former employees and contractors may be granted access
to their files upon providing reasonable notice. All employee and contractor files must be reviewed under the
supervision of the records keeper during regular business hours inside of the office or department where they
are normally stored and may not be taken off Sky Nurses' property. You may not tamper or remove any part of
your employee or contractor file; however, you may make copies of any information you have provided to Sky
Nurses that have your signature affixed, as permitted by state law.
Should you dispute any item in your file, you are permitted to make a signed and dated written
statement of your dispute that will become part of your file as well.
Sky Nurses will grant government agents and entities limited access to employee and contractor files when
required by law.

Recordkeeping

Sky Nurses guarantees that all information attained from the reference and background check process will only
be used as part of the employment or contractor process and kept strictly confidential.
Requests for Employee or Independent Contractor Information

Sky Nurses employees and contractors may request copies of any documents the employee or contractor has
provided to Sky Nurses. The request must be in writing with a signature.
Verifications of employment for financial, educational, or other reasons should be directed to human resources.

• At Sky Nurses' sole discretion, you may provide a signed release of information for Sky Nurses to
disclose information in your employee or contractor file to an outside entity requesting access.

Reference Responding

The Corporate Administrators will respond to reference check inquiries with dates of employment and
position(s) held. Some limited additional employment data may be released with a written authorization and a
release signed by the individual who is the subject of the inquiry. Exceptions to this policy may be made where
there exists a compelling “need to know” or when it is required by law. Sky Nurses will not respond to reference
check inquiries for Independent Contractors unless accompanied by a notarized letter from the Independent
Contractor requesting the release of information.
Human Resources has a five (5) business day standard lead time for completion of all requests which will be
processed in the order they are received.

pg. 10

Releasing of Information

Sky Nurses may provide confidential information to a client with whom an employee or contractor has been
assigned a medical escort. The following will be provided upon request by the client:

• Employee or Contractor Profile (Name, Telephone Number, Email Address, Professional License,
Professional Liability Insurance, and Travel Insurance)

• Professional License (copy)
• Professional Liability Insurance (copy)
• Travel Insurance (copy)

Unless otherwise required by law, Sky Nurses will not provide any information obtained from a Criminal
Background Screening to a client (private or business).

Social Security Number (US Citizens Only)

The Company is dedicated to protecting the personal security and privacy of all employees and contractors. In
the ordinary course of its business, and for a variety of legitimate business reasons, the Company may collect
and store personal information about its employees and contractors, including all or any part of an employee’s
or contractor’s social security number (“SSN”), in hard copy or digital storage. For purposes of this policy,
“SSN” means more than four sequential digits of an employee’s or contractor’s social security number.

The Company takes measures to prevent the unauthorized disclosure of an SSN, including without limitation:

• Ensuring the confidentiality of SSN;
• Prohibiting unlawful or unauthorized disclosure of SSN;
• Limiting the number of people with access to SSN, and the circumstances under which SSN may be

accessed;
• Ensuring the proper disposal of documents (hard copy or digital) that contain SSN; and
• Disciplining any employee or Independent Contractor who violates this policy.

The Company, and every one of its employees and contractors with access to SSN, will maintain the security
and confidentiality of every document containing the SSN. This means, at a minimum, that the Company will
securely maintain documents containing SSN and that any access to digital files containing all or any part of an
SSN will be password protected.

Furthermore, no employee or contractor shall display or disclose of an SSN without the express written
consent of the individual to whom the SSN is assigned. The Company will not mail any document containing
an SSN that is visible on, or from, the outside of the mailed article. Nor will the Company use the SSN as an
identifying number for its employees or Independent Contractor, or visibly print it on identification tags, badges,
passes, cards or licenses. The Company will not require you to use or transmit your SSN over the Internet, or
any Company intranet, computer system or network unless the connection is secure, or the transmission is
encrypted.

The Company restricts access to any document displaying an SSN to those with a legitimate business need to
access those documents. Access to these documents by anyone other than those individuals with a legitimate
business need to access those documents must be specifically authorized, in writing by HR and/or Accounting

pg. 11

or by the individual to whom the SSN is assigned. Documents containing an SSN will be disposed of in
accordance with the Company document retention policy and procedures.

Nothing in this policy is intended to modify an employee’s or Independent Contractor’s right to access their own
personal information, as permitted by applicable law. Nor does this policy prohibit the use of an SSN where the
use is authorized by state or federal statute, rule, regulation, court order, or pursuant to legal discovery or
process.

Violations of this policy will result in disciplinary action up to an including termination of employment or
Independent Contractor agreement. Violators may also be subject to civil and criminal penalties authorized by
applicable state or federal law.

Background Screening

In keeping with the Company's Ethics and Compliance program, background and reference checks are
required for all new employees and contractors at the time of initiating an employment or contractual
agreement. The information collected will become part of the employee or contractor's file and may include
verification of information provided during the hiring or contracting process. Any employment or contract offer
made by Sky Nurses is contingent on verification as to the accuracy of the information provided by the
potential or current employee or contractor.

Background checks will include the following:

• Social Security (U.S. citizens or U.S. visa holders with valid social security card) validates the
applicant’s social security number, date of birth and former addresses.

• Prior Employment Verification confirms applicant’s (employee and contractor) employment with
companies, including dates of employment, the position held, the reason for departure and eligibility for
rehire. This will be run on past two employers or five years, whichever comes first. Prior employment
verification also verifies an employee or contractors experience in the job in which he/or she is applying
or contracting for. This verification is completed through a third-party vendor.

• Multi-County Criminal will be run on countries that applicants have listed on the release form. This will
include counties of past residence for a period of up to five years.

• Federal Criminal History checks district courts for any crimes committed in violation of federal law in the
district of current residence.

• Two Professional References are required by the applicant and verified through Sky Nurses Human
Resources department.

• Educational Verification confirms the applicant’s claimed education institution, including the years
attended and the degree/diploma received. This is completed by Sky Nurses Human Resources
department.

• License(s) Verification confirms the applicant's good standing with all active and inactive licenses held
by the clinician. This is completed by Sky Nurses Human Resources department.

Employees and contractors must pass both the Company's background screening and Healthcare
Sanctions checks.

pg. 12

As background and reference checks are part of each employee or contractor's file, such information is kept
confidential and may only be reviewed by those involved with hiring and personnel decision processes or Sky
Nurses managers having a legitimate business need to know.
Should you be denied employment or contract based on information obtained from a background or reference
check, then Sky Nurses will provide you with a copy of such report(s) and allow you an opportunity to dispute
such information.
What is OFAC?

The Office of Foreign Assets Control (OFAC) of the US Department of the Treasury administers and enforces
economic and trade sanctions based on US foreign policy and national security goals against targeted foreign
countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the
proliferation of weapons of mass destruction, and other threats to the national security, foreign policy or
economy of the United States. OFAC acts under Presidential national emergency powers, as well as authority
granted by specific legislation, to impose controls on transactions and freeze assets under US jurisdiction.
Many of the sanctions are based on United Nations and other international mandates, are multilateral in scope,
and involve close cooperation with allied governments.

What is OIG?

Office of Inspector General's (OIG) mission is to protect the integrity of Department of Health and Human
Services (HHS) programs as well as the health and welfare of program beneficiaries. It is dedicated to
combating fraud, waste and abuse and to improving the efficiency of HHS programs.

What is NSOPW?

National Sex Offender Public Website (NSOPW) is provided as a public service by the U.S. Department of
Justice.

Background and reference checks may be conducted on current employees in order to assess them for
continued employment, promotion, or reassignment, as permitted by state and federal law. Background and
reference checks will be conducted on all contractors that are up for contract renewal.

Health Information

Sky Nurses maintain records of its employees' and contractor’s private healthcare information, and any such
information shared with Sky Nurses by an employee or contractor will be kept confidential.

pg. 13

Assessing Competency at Sky Nurses

When Hiring/Contracting & Selection Orientation Ongoing Development &
Performance Performance
Transfer Improvement

With What Job Description Sky Nurses Orientation: Individual Education and
• Mission, Vision, Performance Training
Job Description can be one Values, and Goals
inclusive document as long as • Organizational • Evaluation • Continuous
it includes the population Competencies • Client
served and contains the (Code of Ethics Learning
description of tasks, duties, and Business Surveys
and responsibilities. Conduct
• Patient and
Position Competencies Clinician Safety
• Medical Escort
• Technical Process
• Organizational
• Job Specific

Performance • In-Service
• Learning
• Resume • Mentoring Evaluation
• Interview Resources
• Reference Checks • Shadowing • Virtual
• Background
Methods • Training (1-1, • Mandatory Classroom
Screening: Training
• Health Screening Virtual Classroom) Testing • Focused
Training
• Testing (Medical
• Mentoring
• Observation Escort

• Precepting Course)

Timeframe Upon hire/contract, expiration Organization Annually for Ongoing
of certifications/license Competencies evaluation and
testing

• Within 2 weeks of Competency
hire/contract
Assessments

determined by case

pg. 14

Corporate

Non-Disclosure Agreement

In order to maintain a competitive advantage in its industry, Sky Nurses requires that all employees and
contractors sign a non-disclosure agreement as a condition of employment or contract and to keep information
related to Sky Nurses and those with which Sky Nurses conducts business with strictly confidential.

A nondisclosure agreement is a written legal contract between an employer and an employee or
contractor. The nondisclosure agreement lays out binding terms and conditions that prohibit the
employee or contractor from disclosing confidential and proprietary information.

Employees and contractors are prohibited from disclosing "Confidential Information", as defined above, to
any external parties without prior written authorization or to other Sky Nurses employees, independent
contractors, or consultants that do not have a legitimate business reason to know such information.

External parties are any person or entity besides Sky Nurses' employees, representatives, and
authorized agents. Employees and contractors must maintain confidentiality in all locations, all
modes of communication, and at all times, continuing indefinitely after termination of their
employment or contract relationship with Sky Nurses.

Employees and contractors are responsible for knowing what information should be treated as Confidential
Information and should consult their supervisor for clarification if in doubt. Confidential information includes
information that relates to Sky Nurses, its operations, or technology that is generally not known to the public
and includes, without limitation, the following:

• Trade secrets
• Business plans
• Business strategies
• Bids or quotes,
• Marketing plans
• Financial information
• Costs
• Pricing
• Employee or contractor compensation
• Client information and/or communications
• Employee or contractor personal information such as emails, telephone or address

Confidential information also includes information you receive from others that Sky Nurses has an obligation to
treat as confidential, including, without limitation, information from Sky Nurses' vendors, suppliers, and current
and prospective customers and clients.

You can help Sky Nurses safeguard its Confidential Information by adhering to the following guidelines:

• Do not discuss Confidential Information in public places.

pg. 15

• When discussing Confidential Information, or matters that are potentially Confidential, be aware of who
is around you and consider whether they have a specific need to know such information.

• Do not print hard copies of Confidential Information unless absolutely necessary. If you do, be sure to
keep such information in a safe and secure place.

• Keep electronically-stored Confidential Information password protected.
• Shred or tear up hard copies of Confidential Information before disposing of in the trash.
• Do not share or disclose information in any way that could be construed as a violation of the Non-

Disclosure Agreement (NDA).

Non-Compete

Sky Nurses does not require any clinician (employee or contractor) to sign a non-compete.

A non-compete clause is a term used in contract law under which one party, employee or
contractor, agrees not to enter into or start a similar profession or trade in competition against
another party.

Information Technology

The Sky-Med portal makes information readily accessible for employees and contractors from anywhere in the
world. You can access the Sky-Med portal through the Sky Nurses website at www.skynurses.com or
portal.skynurses.com.

Information Security

1. Keep Passwords Confidential
a. Never write down or post your password(s).
b. Do not share your password with others including IT. Passwords uniquely identify you within our
systems.
c. Never use someone else’s password.
d. If you suspect someone has learned your password, call Human Resources to learn how to
change your password right away.

2. Safeguard Portable Media (CD, Disk, PDA, Flash Drive)
a. Do not store patient information on media, unless necessary.
b. Lock up media when it is not being used.
c. Keep media in your possession when not locked up.
d. When you need to dispose of media, contact your IT department. Please do not throw media in
the trash.

3. Protect Electronic Patient Information
a. Before you walk away from an application or computer, ensure no patient data is on the screen.
b. Only access patient information necessary for your job responsibilities.
c. Do not share patient information with others unless you are certain they are authorized to have
the data.

4. Encrypt Sensitive Emails

pg. 16

a. We are required to encrypt email messages with sensitive information sent outside the
company.

b. To encrypt an email, simply type [encrypt] at the start of the email subject line. This will
automatically encrypt the message and the attachments.

5. Report Potential Violations and Suspicious Activity
a. It is important to report potential security violations and suspicious activity immediately.
b. Security incidents could include any of the following: Lost or stolen computer, unauthorized
access to a system, bypassing security controls, misdirected email, virus, the disclosure of
password, unusual email.

When you have security questions or need to report a security incident, please contact Sky Nurses.

Conflicts of Interest

Employees and contractors are required to avoid conflicts of interest. This means employees and contractors
must avoid activities, relationships, and situations that may cause them to put their personal interests ahead of
Sky Nurses. It is important that employees and contractors act in the best interests of Sky Nurses at all times,
and for this reason, employees and contractors must take measures to avoid even the appearance of having
conflicts of interest. You must disclose any actual or potential conflicts of interest to a human resources
manager, including actual or potential conflicts of interest held by another employee or contractor that such
employee or contractor fails to disclose. In general, you can avoid conflicts by not using or appear to use
Sky Nurses' Confidential Information, property, or business opportunities for your own personal gain.

The following are examples of situations which may create, or appear to create, a conflict of interest:

• Situations that you may have a personal financial interest in transactions or business activities of Sky
Nurses or Sky Nurses' competitors, clients, customers, or suppliers.

• Situations where, although you do not have a personal financial interest, you may nonetheless obtain
some other personal gain or advantage resulting from transactions or business activities of Sky Nurses
or Sky Nurses' competitors, clients, customers, or suppliers.

• Situations, where you consult for or otherwise, have a separate business relationship with a Sky
Nurses' competitor, client, customer, or supplier outside of your normal employment role for Sky
Nurses.

• Accepting any benefit, including gifts, services, entertainment, or favors, from a Sky Nurses competitor,
client, customer, supplier, government entity, or other organization in connection with your relationship
with Sky Nurses outside of your regular employment or contractor benefits from Sky Nurses.

• Situations where you are responsible for hiring, managing, or otherwise working with your own family
members or persons of close relation to you, whether such persons are other employees or contractors
or have a different business relationship with Sky Nurses, for instance as contractors, consultants,
clients, customers, or suppliers.

• You are required to consult human resources manager if you are unsure about whether you have a
conflict of interest or the appearance of a conflict of interest. When a conflict of interest is found to exist
or appears to exist, you must work with a human resources manager and/or the manager supervising
the relevant business activities to remove yourself from the situation as much as possible, including
creating an effective screening plan, if necessary.

pg. 17

Liability Insurance

Professional liability insurance protects for errors and omissions committed by employees in the course of their
professional duties where the employee or employer could become legally liable. It insures against claims of
medical negligence against the employee or contractor. Sky Nurses maintains General and Professional
Liability Insurance to protect Sky Nurses and staff during business. At this time, Sky Nurses General and
Professional Liability Insurance does not cover the independent contractor from personal claims.

Clinical Employees

Sky Nurses provides Professional Liability Insurance to all clinical employees employed by Sky Nurses.

• For each occurrence: $1,000,000.00
• Annual Aggregate: $3,000,000.00

Clinical Contractors

While on a medical escort assignment, you will be required to carry professional liability insurance. A minimum
must be met at all times to maintain a contract with Sky Nurses:

• For each occurrence: $1,000,000.00
• Annual Aggregate: $3,000,000.00

Failure to provide a Certificate of Professional Liability Insurance will be a cause for the withdrawal of a
contract.

Patient Care Incident

In the event of a patient care incident while on an assignment for Sky Nurses, you are required to report this
immediately by phone to the Vice President of Medical Management and provide a written, objective summary
of involvement in the event. To remain compliant with the HIPAA guidelines, the objective summary of
involvement in the event, should not contain PHI. The following are examples of reportable situations:

• Sudden or unexpected death;
• Patient fall, regardless of type of injury;
• Unanticipated neurological sensory and systemic benefits, for instance, permanent paralysis, brain

damage, loss of sight, loss of hearing or sepsis;
• Witness in situation deemed potentially problematic;
• Birth-related injuries, either maternal or fetal;
• Substantial disability, for example, amputation, disfigurements, or fractures;
• Severe IV infiltrations or situations where complications from IV solutions may require treatment; and
• Any other case, which you may deem reportable.

Mercer Consumer, a service of Mercer Health & Benefits Administration LLC

For registered nurses who have professional liability insurance through Mercer, you must notify the insurance
carrier in writing if you receive notice of a claim suit, incident or occurrence.

pg. 18

CLAIM REPORTING INSTRUCTIONS

A claim must be reported to Liberty International Underwriters Insurance for assignment to a Claims
Professional. Please follow the instructions below:

Please send written notice to:

[email protected]

OR

Liberty International Underwriters Insurance
Attn: Mercer Claims
55 Water Street, 23rd Floor
New York, NY 10041

If you would like to speak with someone regarding your Claim, Suit, Incident or Occurrence, please
contact: 1-855-511-8097

Terms in bold face are defined by your policy. Please refer to your policy for relevant definitions and
reporting obligations.

Nurses Services Organization (NSO)

Sky Nurses recommends that you check with NSO for verification of coverage under your policy. While it
clearly states that they offer Worldwide Coverage, it may or may not cover a nurse on a commercial airline.

Worldwide Coverage – Helps insure you anywhere in the world provided a claim is brought against
you in the United States, its territories and possessions, Puerto Rico, or Canada. In addition, a
professional liability insurance policy through NSO is portable, so you can take it with you
wherever you go. Whether you have a second job, volunteer, move, or change jobs, your policy is
there to help insure you.

Liability and Legal Protection for Good Samaritans

The fear of liability is noted to be the number one reason that prevents a trained medical personnel traveling as
passengers from assisting during a medical emergency.

United States Law

US law does not obligate a physician or nurse to render assistance. It is, however, widely considered an ethical
duty to provide help when possible.

pg. 19

The Aviation Medical Assistance Act of 1998 applies when medical professional volunteers to provide care
during a medical emergency. The Samaritan is protected against medical malpractice litigation if the following
conditions exist:

• The Samaritan is medically qualified to perform the service.
• The Samaritan acts voluntarily.
• The Samaritan acts in good faith.
• The Samaritan does not engage in gross negligence or willful misconduct.
• The Samaritan receives no monetary compensation.

International Law

Determining which country’s laws apply on international flights can be a challenge:

• The laws of the country from which the aircraft departed.
• Toward which it is traveling.
• The Country in which the airline is based out of.

Countries that operate under civil law can impose an obligation on physicians and nurses to render aid.

Repatriation Insurance

All employees and independent contractors must obtain travel insurance or membership in a travel assistance
program before a clinician will be allowed to travel as a medical escort for Sky Nurses. Verification of insurance
or membership must be provided to Human Resources.

If a clinician has accepted a medical escort and the airline tickets have been purchased, Sky Nurses will
purchase a 1-year membership with an approved company at the clinician’s expense, not to exceed $200.00, if
proof of insurance has not been received by administration. This fee will be deducted from the clinician’s fee
for the medical escort.

Do Sky Nurses provide Worker's Compensation?

Sky Nurses provides worker’s compensation insurance to all employees on the company’s payroll. This
comprehensive insurance is at no cost to the employee. This program covers any injury or illness sustained in
the course of employment that requires medical, surgical or hospital treatment within the United States. Sky
Nurses Worker's Compensation program does not cover independent contractors.

If you become exposed or injured while on the job, report the incident to the Vice President of Medical
Management and seek treatment. It is your responsibility to make sure that the incident report is completed.
The incident report can be found in the Sky Nurses Clinician Center within 24 hours of occurrence. Failure to
report injuries promptly may delay benefits.

Neither Sky Nurses nor the insurance carrier will be liable for the payment of worker’s compensation benefits
for injuries that occur during an employee’s voluntary participation in any off-duty recreational, social, or
athletic activity sponsored by Sky Nurses.

pg. 20

Corporate Responsibilities

Sky Nurses ‘Code of Conduct’ provides guidance to all employees and contractors in carrying out our daily
activities within appropriate ethical and legal standards. These obligations apply to our relationships with
patients, affiliated physicians, third-party assistance companies, insurance providers, contractors, vendors,
consultants, and one another. The Code of Conduct is a critical component of our overall Ethics and
Compliance Program. Sky Nurses has developed this program to ensure we meet our ethical standards and
comply with applicable laws and regulations.

The continued success of a business is contingent upon a commitment to an ethical work environment. It is the
healthcare clinician's obligation to uphold these standards.

• Obey the Law
o It is the duty of each employee or contractor to be aware of, and to comply with, all laws and
regulations relating to Company policies.

• Provide the Highest Standard of Care
o All employees and contractors must strive to provide the highest quality of health care service in
response to the needs of present and future patients.

• Promote a Positive Work Environment
o All employees and contractors deserve a workplace where they are treated fairly and where
they feel respected and appreciated. Harassment or discrimination on the basis of race, color,
religion, gender, age, national origin, disability, sexual orientation, veteran or marital status is
strictly prohibited.

• Keep Accurate and Complete Records
o Company documents must be accurately maintained. Under no circumstances may any
document be falsified or wrongfully destroyed.

• Protect Yourself
o All employees and contractors are responsible for compliance with environmental, health, safety
laws, and regulations. Do not perform any activity you believe is unsafe.

The Company’s Code of Conduct and Business Ethics policy, ADM102, requires each Sky Nurses employee
or contractor to receive the Code of Conduct and Business Ethics training. Orientation training regarding our
Code of Conduct and Business Ethics policy is required within fourteen (14) days of becoming a covered
employee or contractor. During the orientation training, individuals will review the Code of Conduct and
Business Ethics in detail and acknowledge their understanding that it represents mandatory policies and agree
to abide by it. In addition to training regarding the Company’s Code of Conduct and Business Ethics,
employees and contractors are required to receive “compliance training” relative to their job responsibilities.
Training is delivered through a number of methods including webcasts, online courses, and instructor-led
sessions and all training is tracked in the HR Management system.

The following represent some of the guidelines by which all Company employees and contractors should
operate:

• Information concerning patients, employees and other Company business of a confidential
nature must not be discussed with persons not concerned with such information, and certainly
never with people outside the Company.

pg. 21

• Discussing employee or contractor’s personal issues/problems with the patient or patient’s family
members is not appropriate.

• Employee or contractors must maintain a professional relationship with the patient and patient’s family
members. Associating, dating, or fraternizing with the patient or patient’s family member is
unprofessional and is strictly prohibited, as is any attempt, by words or conduct, to engage a patient or
former patient in a sexual or intimate relationship.

• Employees or contractors should ensure that they remain free of conflict of interest in the performance
of their responsibilities. Conflicts of interest may occur if the employees or contractors outside activities
or personal interests influence or appear to influence the ability to make objective decisions or if the
demands of outside activities hinder the performance of the job.

• Employees or contractors have a responsibility to preserve the company’s assets including time,
materials, supplies, equipment and information.

• Employees or contractors should avoid the appearance of impropriety by ensuring that they neither
receive nor extend business courtesy outside the Company guidelines.

Sky Nurses has certain work rules and levels of conduct that must be adhered to by all employees and
contractors.

The following will result in immediate employment or contractor termination:

• Non-compliance with any established Company policy or work rule(s).
• Verbal or physical abuse/threats, intimidating, swearing, or coercing behavior directed toward (or in the

presence of) a patient or patient’s family.
• Fighting or striking another person, except in self-defense against an unprovoked assault.
• Possessing, consuming, or being under the influence of alcohol, illegal or controlled substances, or

intoxicants while on a medical escort in the presence of a patient.
• Falsifying records, including false or misleading information on an employee or contractor job

application, resume, work reports, official documents, patient records, etc.
• Willful or deliberate destruction or damage to client property or supplies, or the property of a patient or

patient’s family.
• Possession of weapons, firearms or any other hazardous or dangerous devices while on a medical

escort.
• Unauthorized reading or disclosure of patient health information.
• Any other misconduct which affects the quality of patient care service.
• Insubordination, including refusal to do assigned work or refusal to perform work in the manner

described by a supervisor without proper justification.
• Inattention to duties or unsatisfactory job performance.
• Violation of any Company safety and health rules or standards.
• Negligence or inconsiderate treatment in the care of patients.
• Failure to notify Company in a timely manner of any sanctions or criminal convictions received by the

employee or contractor during their employment or contract period. The particular sanctions or criminal
convictions themselves may lead to discipline.
• No Call/No Show without just cause.
• Any other serious event that the Company deems as a major infraction of employee or contractor
conduct.

pg. 22

Ethics Line

Sky Nurses maintains an Ethics and Compliance Line for reporting possible misconduct or obtaining guidance
on an ethics or compliance issue. The Ethics and Compliance Line is 866.611.8134 Extension 501.

As part of our commitment to provide quality care to our patients, we strive to ensure an ethical and
compassionate approach to healthcare delivery and management. We must demonstrate consistently that we
act with absolute integrity in the way we do our work and the way we live our lives.

Standards of Conduct

All employees and contractors are responsible for knowing and abiding by Sky Nurses' rules and policies. Sky
Nurses prides itself on its ability to meet high standards of ethical and personal conduct throughout its
operations. Therefore, you are expected to maintain the highest ethical standards and perform your duties in
good faith and to the best of your abilities at all times when engaged in Sky Nurses business.

Where warranted under the circumstances, Sky Nurses will seek to use progressive discipline to correct,
improve upon, and prevent future recurrences of conduct falling below our standards.

Employees

At Sky Nurses' discretion, progressive discipline may proceed along the following line for employees:

1. Verbal warning
2. Written warning
3. Conduct evaluation period
4. Suspension with or without pay
5. Demotion
6. Reassignment
7. Termination.

A conduct evaluation period, if instituted for an employee, will be a set period not to exceed 90 days in which
the employee will receive counseling and monitoring by a supervisor with the aim of targeting possible causes
and correcting the poor performance. Depending upon the employee's performance during the conduct
evaluation period, further discipline or corrective action may occur at the end of the period, including
termination.

Contractors

At Sky Nurses' discretion, progressive discipline may proceed along the following line for contractors:

1. Verbal warning
2. Written warning
3. Conduct evaluation period
4. Termination of contract

In conclusion, Sky Nurses reserves the right to combine, skip, or reorder any steps in the process depending
upon the nature of the offenses and the circumstances. Note that this means that Sky Nurses has the right to

pg. 23

immediately terminate an employee or dismiss a contractor without warning or the use of progressive discipline
should the circumstances call for such action.

When determining the appropriate discipline for a given instance Sky Nurses may consider, at its discretion,
any of the following factors, without limitation: the number of repeated instances of the particular offense, the
amount of counseling and/or training received in order to prevent such offenses, the impact the offense has on
Sky Nurses' performance or perception in the marketplace, and the level of egregiousness and purposeful
intention to violate Sky Nurses' policy.

Termination of Employment or Contract

At Sky Nurses' discretion, Employees or Contractors may be disciplined or terminated for violating any Sky
Nurses policy or rule. Misconduct can take many forms, and it is impossible for us to provide you with a
comprehensive list of prohibited behaviors. Therefore, the list below is only illustrative and is intended to give
you notice of some of Sky Nurses' general expectations concerning standards of conduct; Sky Nurses may
always discipline or terminate employees or contractor for engaging in any conduct it deems inappropriate.
Employees and contractors are expected to use good judgment in all their actions and to consult their
supervisors or a human resources manager if there is any doubt as to whether their intended conduct falls
below Sky Nurses standards.

Examples of misconduct that may result in discipline or termination include, but are not limited to, the following:

• Unsatisfactory job performance, including poor quality or quantity of work.
• Engaging in insubordination or disobedience to the legitimate orders of a supervisor.
• Repeatedly arriving late at an airport or patient location.
• Dishonest behavior.
• Illegal discrimination or harassment.
• Disorderly conduct, such as violence or threats of violence.
• Violating Sky Nurses' procedures or instructions.
• Failure to abide by health or safety regulations.
• Intentionally falsifying Sky Nurses documents, including Sky Nurses' records and documents provided

by the employee or contractor during the hiring process.
• Excessive use of obscene, profane, or abusive language.
• Misusing Sky Nurses property, including using property without authorization; using Sky Nurses

property improperly; or damaging, destroying, or stealing property.
• Possession or use of weapons or other dangerous items or materials during a medical escort.
• Possession or use of illegal drugs, alcohol, or controlled substances without a valid prescription on Sky

Nurses property or while engaged in Sky Nurses business.
• Failure to disclose conflicts of interests.
• Unauthorized use or disclosure of Sky Nurses' confidential information.
• Conviction of a crime that indicates you are unfit to work for Sky Nurses or represent a potential threat

to Sky Nurses personnel or operations.
• Violating applicable laws or regulations in performing your duties.
• Violating any other Sky Nurses policy or rule.

pg. 24

Ethics Policy

The purpose of an Ethics Policy is to support a culture of openness, trust, and integrity in all employees and
contractors. A well-understood ethics policy requires the participation and support of every employee and
contractor. We believe that striving to be the best in our work, our relationships, our ideas and our services is
the greatest demonstration of our pledge to patient satisfaction. We are determined to do the best at what
matters most, and our success depends on our employees and contractor’s ability to deliver the consistent
level of excellence expected by all who rely on us.

Business Ethics

• Be honest and ethical in your conduct, including the ethical handling of actual or apparent conflicts of
interest between personal and professional relationships.

• Maintain the confidentiality of information entrusted to you except when authorized or otherwise legally
obligated to disclose.

• Provide constituents with information that is accurate, completely objective, relevant, timely, and
understandable.

• Proactively promote ethical behavior as a responsible partner among peers in the work environment.
• Protect and ensure the proper use of patient assets.

Attendance

As an essential element of all medical escorts, employees and contractors are required to arrive at the
designated airport at the time indicated on the clinician’s itinerary. If an employee or contractor has
circumstances beyond their control and must cancel a scheduled flight (medical escort), they must notify
management as soon as possible. Employees or contractors are expected to identify the reason for their
cancellation. An unexcused cancellation will not be tolerated and will result in termination or cancellation of
their contract.

Contracted Work Assignments

Because of the urgent nature of our business, it is important that scheduled travel assignments be completed
promptly. If an employee or contractor is going to be unable to report for an assigned travel agreement, that
employee or contractor must personally notify the on-call supervisor immediately unless an unforeseeable
emergency prohibits notification. Excessive cancellations (two or more excused or unexcused) after a travel
assignment has been arranged will result in termination of employment or contractor’s agreement. If an
employee or contractor fails to report for a scheduled travel assignment, the employee will be terminated, and
the contractor’s contract will become null and void unless the employee or contractor has a legitimate reason
for being a no-show.

From time to time, it may be necessary for the Company to change the starting and completion time of a
scheduled travel assignment to accommodate the needs of the patient.

pg. 25

Anti-Harassment

Sky Nurses aims to create a work environment free of harassment wherein employees and contractors treat
each other with respect and courtesy. Therefore, Sky Nurses prohibits its employees and contractors from
engaging in unlawful harassment against individuals on the basis of race, color, creed, national origin, religion,
gender, sexual orientation, pregnancy, genetic information, age, physical or mental disability, veteran status,
marital status, or any other protected classification under federal, state, or local law.

Conduct considered harassment is defined below. This policy applies in all work settings, whether or not
occurring on Sky Nurses' property.

Employees and contractors violating this policy are subject to discipline, including possible termination of
employment or contract. Instances of harassment are serious matters, and all employees and contractors must
make every effort to uphold and support Sky Nurses' anti-harassment policy. This includes reporting all
instances of harassment to a Sky Nurses manager. It is Sky Nurses' policy to promptly investigate any
reported instance in a thorough manner. Sky Nurses forbids any retaliation against those who report or
investigate harassment.

Sexual Harassment Defined

Sexual harassment constitutes discrimination and is illegal under federal, state, and local laws. For the
purposes of this policy, sexual harassment is defined as unwelcome sexual advances, requests for sexual
favors and other verbal or physical conduct of a sexual nature. Examples include:

1. Submission to such conduct is made either explicitly or implicitly a term or condition of an individual's
employment or contractor status.

2. Submission to or rejection of such conduct by an individual is used as the basis for employment or
contractor decisions affecting such individual.

3. Such conduct has the purpose or effect of unreasonably interfering with an individual's work
performance or creating an intimidating, hostile, or offensive working environment.

Sexual harassment may include a range of subtle and not-so-subtle behaviors and may involve individuals of
the same or different gender. Depending on the circumstances, these behaviors may include unwanted sexual
advances or requests for sexual favors; sexual jokes and innuendo; verbal abuse of a sexual nature;
commentary about an individual's body, sexual prowess, or sexual deficiencies; leering or whistling; repeated
uninvited physical contact or touching, such as patting, pinching, or grabbing another's body; insulting or
obscene comments or gestures; display in the workplace of sexually suggestive objects or pictures; and other
physical, verbal, written, or visual conduct of a sexual nature regardless of the rank, position, gender, or sexual
orientation of those involved. Sexual harassment may occur through transmission using the Sky Nurses'
electronic communications system or through other online conduct.

Harassment Defined

Harassment on the basis of any other protected characteristic is also strictly prohibited. Under this policy,
harassment is defined as verbal, written, or physical conduct that denigrates or shows hostility or aversion
toward an individual because of his/her race, color, religion, gender, sexual orientation, national origin, age,

pg. 26

disability, marital status, citizenship, genetic information, or any other characteristic protected by law or that of
his/her relatives, friends, or associates, and that a) has the purpose or effect of creating an intimidating, hostile,
or offensive work environment; b) has the purpose or effect of unreasonably interfering with an individual's
work performance; or c) otherwise adversely affects an individual's employment opportunities.

Harassment includes, but is not limited to, epithets, slurs, or negative stereotyping; threatening, intimidating, or
hostile acts; denigrating jokes; and written or graphic material that denigrates or shows hostility or aversion
toward an individual or group and that is circulated in a work setting, whether by being posted on Sky Nurses
premises or communicated via e-mail, phone, text messages, online forums, or other means.

Customer Service

Our primary concern at this Company is the welfare of our patients and our clients that we serve. It is the
responsibility of all employees and contractors to behave in a professional manner at all times and treat
everyone with dignity and respect. This kind of service enhances the image of the Company and increases
patient and family confidence in the care and services we provide.

The following are examples of the type of quality service that are expected of all employees and contractors:

• Address patients properly by their social titles, Mr., Mrs., Ms., or Miss, and their last name.
• The release of information without a patient’s consent is not only improper but also illegal. Do not

discuss the patient’s condition except on a need-to-know basis.
• Patient privacy must be protected at all times. Conversations with patients should be warm and cheerful

and must never involve gossip or personal issues.
• Potential safety hazards to any patient or contractor must be reported immediately.
• Personal items are important to patients. Handle them with care.

Social Media

At Sky Nurses, we understand that social media can be a fun and rewarding way to share your life and
opinions with family, friends, and co-workers around the world. However, the use of social media also presents
certain risks and carries with it certain responsibilities. To assist you in making responsible decisions about
your use of social media, we have established these guidelines for appropriate use of social media.

Per this Handbook, social media includes, but not limited to, Facebook, Twitter, Snapchat, LinkedIn, Google+,
Vimeo, Flickr, Pinterest.

This information applies to all employees and contractors who work at Sky Nurses.

Guidelines

In the rapidly expanding world of electronic communication, social media can mean many things. Social media
includes all means of communicating or posting information or content of any sort on the Internet. Ultimately,
you are responsible for what you post online. Before creating online content, consider some of the risks and
rewards that are involved.

pg. 27

Carefully read the Code of Conduct and Business Ethics Policy and ensure your postings are consistent with
this policy. Employees and contractors are prohibited from creating content on social media that could be
considered discriminating, harassing, or obscene, or that may damage Sky Nurses' reputation or public image.

Make sure you are always honest and accurate when posting information or news, and if you make a mistake,
correct it quickly. Be open about any previous posts you have altered. Remember that the Internet archives
almost everything; therefore, even deleted postings can be searched. Never post any information or rumors
that you know to be false about Sky Nurses, fellow associates, members, customers, suppliers, people working
on behalf of Sky Nurses or competitors.

Outside Sky Nurses

1. Express only your personal opinions. Never represent yourself as a spokesperson for Sky Nurses. If
Sky Nurses is a subject of the content you are creating, be clear and open about the fact that you are
an associate and make it clear that your views do not represent those of Sky Nurses, fellow associates,
members, customers, suppliers or people working on behalf of Sky Nurses. If you do publish a blog or
post online related to the work you do, or subjects associated with Sky Nurses, make it clear that you
are not speaking on behalf of Sky Nurses. It is best to include a disclaimer such as “The postings on
this site are my own and do not necessarily reflect the views of Sky Nurses.” The company should not
be held liable for any repercussions the employee's or contractor's content may generate.

2. Content pertaining to sensitive company information (trade secrets) should not be shared with the
outside online community. Divulging information concerning a patient, Sky Nurses' policies and
procedures, internal operations and legal matters are prohibited. Trade secrets may include information
regarding the development of systems, processes, know-how and technology. Do not post internal
reports, policies, procedures or other internal business-related confidential communications.

3. Do not use Sky Nurses email addresses to register on social networks, blogs or other online tools
utilized for personal use.

Sky Nurses Intranet (Sky Nurses Clinician Center)

1. The company reserves the right to edit or amend any misleading or inaccurate content depicted in blog
posts. The company also reserves the right to delete blog posts violating the Code of Conduct policy.

Always be fair and courteous to fellow employees and contractors when posting on Sky Nurses Intranet. Also,
keep in mind that you are more likely to resolve work-related complaints by utilizing our Open-Door Policy than
by posting complaints to Sky Nurses' social media outlet.

Retaliation is prohibited

Sky Nurses prohibits taking negative action against any associate for reporting a possible deviation from this
policy or for cooperating in an investigation. Any associate who retaliates against another associate for
reporting a possible deviation from this policy or for cooperating in an investigation will be subject to
disciplinary action, up to and including termination.

pg. 28

Media contacts
Associates should not speak to the media on Sky Nurses' behalf without contacting the Corporate Affairs
Department. All media inquiries should be directed to them.
For more information
If you have questions or need further guidance, please contact your HR representative.

Gift Acceptance

Accepting business gratuities from a patient during a medical escort is not encouraged nor discouraged by Sky
Nurses. However, there are things to consider when refusing:

1. How will it affect the patient, whether it will hurt their feelings?
2. Is it considered disrespectful if you refuse to accept their gift?
Gifts that patients offer to clinicians are often an expression of appreciation and gratitude or a reflection of
cultural tradition. There are no definitive rules to determine when a clinician should or should not accept a gift.
Prohibited
Accepting money based on a loan from a patient and/or family member is prohibited and cause for termination
of a contract.
• Employees or independent contractors may not solicit personal gifts or cash from any patient or family

member.

pg. 29

Payroll

Wage and Hour Policies

Employees

Under state and federal wage and hour laws, including the Fair Labor Standards Act ("FLSA"), all Sky Nurses
employees are either classified as exempt or nonexempt. All others are classified as independent contractors.

• Exempt Employees - Employees exempted from the minimum wage and overtime provisions of the
FLSA by holding positions that satisfy the criteria under the act. These employees are generally
executives, managers, professionals, administrators, and technical staff who receive salaries or sales
commissions.

• Nonexempt Employees - Employees who are NOT exempt under the criteria of the FLSA minimum
wage and overtime provisions.

• In addition, the following mutually exclusive classifications apply to both exempt and nonexempt
employees and help determine an employee's employment status and eligibility for employee benefits,
but in no way, guarantee continued employment for any amount of time:

• Regular Full-Time Employees - Employees are considered full-time employees if they are normally
scheduled to work at least 40 hours per week. These employees are generally eligible to receive Sky
Nurses' benefits, if any, subject to the terms and conditions of each benefit plan.

• Regular Part-Time Employees - Employees who are NOT normally scheduled to work at least 40
hours per week or who only irregularly work 40 or more hours per week. These employees are NOT
generally eligible to receive Sky Nurses' benefits.

• Temporary Employees - Full-time or part-time employees hired for a limited duration generally for
three months or less. These employees are typically interim replacements or hired for work on a
specific project. Temporary employee work duration may be extended upon written permission;
however, status as a temporary employee may only be changed by an express writing signed by
authorized Sky Nurses personnel. Temporary employees are employed on an at-will basis unless
expressly stated otherwise in a written employment agreement with Sky Nurses. As at-will employees,
temporary employees may be terminated prior to the end of the initially planned work duration for any
or no reason, with or without notice. Temporary employees are generally not eligible for Sky Nurses'
benefits unless expressly stated otherwise in a written employment agreement or Sky Nurses' policy.

Employees not notified of their particular classification upon hire should inquire to a human resources
manager.

Independent Contractors

Note that independent contractors and consultants are self-employed individuals working with Sky Nurses and
not Sky Nurses employees. As such, they are not entitled to receive Sky Nurses' benefits unless expressly
provided in a written agreement between such individuals and Sky Nurses. Furthermore, these individuals will
have control over the manner of completing assigned tasks, while Sky Nurses has control over assigning the
tasks that independent contractors and consultants complete and defining the specific outcomes sought.

pg. 30

Compensation

Employee Wages

Employees are paid every two weeks for their regular wages due. Payday will be every other Friday.
Employees will be paid on the last business day prior to any payday that happens to fall on a weekend or
holiday. Employees will be paid by direct deposit on their scheduled paydays, in accordance with payroll policy
and as permitted by state law. Employees will receive any direct deposit of wages in a savings or checking
account at the financial institution of their choosing.

You must submit a new Form W-4 to a human resources manager if your marital status or the number of
exemptions you claim changes.

Overtime Pay

Employees classified as nonexempt will be paid overtime according to the FLSA and state law. Your
supervisor must approve all overtime in advance. You are expected to comply with requests to work overtime
during especially busy times and according to Sky Nurses’ needs.

Florida state law sets the standard work week at 40 hours. You will earn overtime pay whenever you exceed
the standard work week, which will be paid at one and one-half your normal pay rate. The workweek is
calculated beginning at 12:00 a.m. on Sunday morning and ending at 11:59 p.m. on Saturday night but may be
changed according to Sky Nurses' discretion. Only actual hours worked will be counted for overtime pay. Meal
breaks and time off for holidays, vacation leave, personal leave, sick leave, and other leaves of absence will
not be used to calculate overtime.

Deductions for Employees

Deductions from your pay will be made according to federal and state law. This may include deductions for
Federal and State Income Tax Withholding, Social Security, Medicare, Disability, garnishments pursuant to
valid court orders, and other deductions pursuant to law. If you need to change your federal or state income tax
withholding, please consult a human resources manager.

Travel Expense for Employees

Nonexempt employees will be paid for travel while on Sky Nurses business according to federal and state law.
Exempt employees will be paid their normal salary while traveling for Sky Nurses.

Contractor Payments

All contractor payments are based on a daily rate and according to the daily rate listed in the Independent
Contractor Agreement.

All contractor payments are contingent upon the successful completion of a mission and the submission of
medical documentation unless noted otherwise. If the mission completion is unsuccessful due to:

pg. 31

• Patient's decline, Sky Nurses' will provide payment after the submission of medical documentation and
the completion of the travel expense report with supporting receipts.

• Contractor's negligence, Sky Nurses' reserves the right to withhold reimbursement.
Contractors payments will be disbursed no later than 7-10 business days after medical documentation
completion. Contractor payments will be paid by direct deposit, wire transfer or check. If wire transfer is
required, the contractor agrees to pay the cost of the wire transfer.
Deductions for Contractors
The earnings of a person who is working as an independent contractor are subject to Self-Employment Tax
(The United States only). As a self-employed individual, you may be required to pay estimated tax quarterly. All
independent contractors should consult with their accountant.
For more information, visit the Self-Employed Individuals Tax Center
Travel Expenses
Sky Nurses reimburses contractor's reasonable expenses incurred while traveling on Sky Nurses business.
Contractors may only travel on Sky Nurses business when authorized and should verify which travel expenses,
if not listed on the list of eligible expenses, are eligible for reimbursement prior to incurring such an expense.
While traveling, contractors should keep a detailed report of all expenses incurred, including any supporting
documentation such as receipts. Contractors must submit their expense reports within 3 business days of the
completion of a medical escort. Sky Nurses reserves the right to refuse reimbursement for all expenses
submitted without proper documentation.
Please use discretion while traveling to keep your expenses at a minimum and to avoid inappropriate
expenses. You may not be reimbursed for expenses that are excessive or improper under the
circumstances.

pg. 32

Clinical Requirements

Medical Escort staffing

Inadequate rest can result in disastrous medical errors. Although the words “fatigue” and “sleepiness” are often
used interchangeably, they are distinct phenomena. Sleepiness refers to a tendency to fall asleep, whereas
fatigue refers to an overwhelming sense of tiredness, lack of energy, and a feeling of exhaustion associated
with impaired physical and/or cognitive functioning. Sleepiness and fatigue often coexist as a consequence of
sleep deprivation. Sky Nurses has adopted the following:

• Before the start of the medical escort, all clinicians must have a minimum of 10 hours of rest after
arrival to his/her destination if the flight is greater than 6 hours.

• All clinicians must have a minimum of 24 hours between medical escorts (patients).

Working before a Medical Escort

A contractor may not work a shift before picking up a patient.

Example: Contractor works a 7PM-7AM shift in the ER, leaves the hospital at 7:30 AM and goes to another
hospital to retrieve a patient for a medical escort.

Performance Review

After each medical escort, a performance review will be conducted (completed or not completed). This
performance review will provide an opportunity to examine your strengths, weaknesses, and areas for
improvement, and identify specific goals going forward.

Any written performance reviews will become part of the employee or contractors file.

Dress Code

Creating a professional visual image is a key to our success. Your image could and will reflect upon our
company’s corporate culture, industry, and expectations. Professional attire for clinicians is required at all times
and employees are expected to wear clothes that are clean, pressed and properly fitted.

Direct patient care personnel must wear a Sky Nurses polo shirt and either khaki, gray or black pants that
project a positive image to our patients and to the public. Clothing must be neat and clean. Jeans/denim,
cropped pants, leggings, sweatshirts, tee shirts, and outside boots (cowboy) are not acceptable work attire.
Hats are not permitted unless they are part of a uniform or they are worn for religious reasons. Shoes must be
clean and in good repair. Hairstyles, jewelry, and personal hygiene should conform to the best business and
professional standards.

Sky Nurses provides one (1) polo shirt with the Sky Nurses logo. Additional shirts may be ordered at $12.00
each and may be ordered in sports gray or white.

pg. 33

All employees and contractors are required to comply with the dress code.

Florence Nightingale wrote: Always remember that soft colors bring out the warmth in a person
that is ill.

Appearance

Grooming plays a key role in dress code policies and first impressions are everlasting. While on a medical
escort assignment:

• Tattoos and body piercing must not be visible. Jewelry should be minimal.
• Pins, rings or studs may not be worn in the nose, eyebrows, tongue, or in or around the lips.
• Beards should be trimmed at all times.
• Cosmetics should be applied lightly.
• Artificial nails are discouraged by Sky Nurses. Nail length must not be longer than 1/4” beyond the

fingertips. Nail polish is permitted as long as it is not cracked or chipped. Exotic nail designs are
prohibited.
• Colognes, perfumes or fragrances of any type are not allowed during the medical escort as this can
cause respiratory compromise in patients aboard a commercial airliner.

Smoking Policy

Sky Nurses prohibits smoking during a medical escort. Clinicians that smoke must refrain from smoking in the
presence of his/her patient. We are taken this action to provide an environment for our patients that
encourages and supports good health. As a healthcare provider, it is our responsibility to set an example of
good health and this policy is a step in the right direction.

Travel

TSA PreCheck lets eligible, low-risk travelers enjoy expedited security settings. The program is available at
participating United States.airport locations and for most international itineraries.

The 5-year membership is $85.00.

• Legal Name must match exactly on all identification documents brought to enrollment.

Apply to the program. . . Click Here

pg. 34

Global Entry

U.S. citizens, U.S. lawful permanent residents, and citizens of a few other countries are eligible for Global
Entry membership. Global Entry is also available to the following:

• Citizens of the United Kingdom
• Citizens of Germany
• Citizens of Panama
• Citizens of South Korea
• Mexican nationals

How to Apply for Global Entry
Before you apply, make sure you are eligible for Global Entry. See Below.

1. Create a Global Online Enrollment System (GOES) account. Regardless of your age, you must have
your own GOES account.

2. Log into your GOES account and complete the application. A $100 non-refundable fee is required with
each completed application.

3. After accepting your completed application and fee, CBP will review your application. If your
application is conditionally approved, then your GOES account will instruct you to schedule an interview
at a Global Entry Enrollment Center. Each applicant must schedule a separate interview.

4. You will need to bring your valid passport(s) and one other form of identification, such as a driver's
license or ID card to the interview. If you are a lawful permanent resident, you must present your
permanent resident card.

Reasons for Ineligibility
You may not be eligible for participation in the Global Entry program if you:

1. Provide false or incomplete information on the application;
2. Have been convicted of any criminal offense or have pending criminal charges or outstanding warrants

(to include driving under the influence);
3. Have been found in violation of any customs, immigration or agriculture regulations or laws in any

country;
4. Are the subject of an ongoing investigation by any federal, state or local law enforcement agency;
5. Are inadmissible to the United States under immigration regulation, including applicants with approved

waivers of inadmissibility or parole documentation; or
6. Cannot satisfy CBP of your low-risk status.

pg. 35

Copyright 2017 by Sky Nurses
All rights reserved. No part of this electronic book may be used or reproduced in any manner
whatsoever without written permission except in the case of brief quotations embodied in critical

articles or reviews.

pg. 36


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