POLICY ON AIDS/HIV INFECTION

Epidemiological studies show that AIDS is transmitted primarily via sexual contact or blood-to-blood contact. Researchers state that casual transmission of the virus has not occurred in close family environments, and opportunistic infections associated with AIDS do not present an appreciable risk to healthy individuals. Since there is no evidence of casual transmission by sitting near, living in the household, or caring for an individual with AIDS, the following policy and procedures are intended to insure the privacy and protect the rights of all students and employees of Hillcrest Educational Centers.

A. Legal Effect of This Policy Statement
This instrument is an expression of policy. It is not intended to and does not want to modify contractual or other legal rights held by the Hillcrest Educational Centers’ students or employees. This statement is not intended to and does not create or modify Hillcrest Educational Centers’ legal duty of care to students or employees.

B. Definitions:
“HEC” means the Hillcrest Educational Centers, Inc.
“Student” means a student, who has been admitted to, enrolled in, and is residing at the agency, and who has not graduated, transferred, or discharged from HEC, or who has been otherwise removed from active status for any reason.
“Employee” means a person, including an administrator, who receives wages or a salary from HEC.
“HIV” means the Human Immunodeficiency Virus, sometimes referred to as the Human T-Lymphotropic Virus, Type III (HLTV-III) or the Human T-Lymphotropic Virus, Type III/Lymphaadenopathy Associated Virus (HLTV-III/LAV)
“HIV test” means a properly performed test licensed by the U.S. Food and Drug Administration to detect the presence of HIV antibodies or antigens in a person’s blood.
“AIDS” means Acquired Immune Deficiency Syndrome caused by HIV, as well as the condition sometimes referred to as AIDS-Related Complex (ARC).
“Person with HIV infection” means a person who is infected with HIV, whether the person has AIDS or some symptoms of AIDS or is asymptomatic.
“Person believed to have HIV infection” means a person believed to have HIV infection
“Person believed to be at risk of HIV infection” means a person believed to be at risk of contracting the HIV infection by a student of employee of HEC.

C. General Policy
1) HEC will not discriminate against students or employees with HIV infection, students or employees believed to have the HIV infection, or students or employees believed to be at risk of the HIV infection on the basis of their perceived risk.
2) HEC will conform its policies regarding persons with HIV infection to the law, the best available scientific and medical evidence and the imperatives of human dignity, including privacy.
3) HEC will treat students and employees with HIV with respect and will, where necessary, accommodate such students and employees accordingly.
4) Since HIV is not known to be transmitted by food or air, according to the latest available scientific and medical evidence, HEC’s students and employees will follow standard sanitary procedures related to preparing food and cleaning eating-ware, regardless of the presence at HEC of a person with HIV infection or believed to have HIV infection.
5) Since HIV is not transmitted through sharing bathroom facilities, and standard sanitary procedures will prevent the growth of fungi and bacteria that may potentially cause illness to immuno-compromised people, HEC’s students and employees will follow standard sanitary procedures in sharing and cleaning bathroom facilities, regardless of the presence at HEC of a person with HIV infection or believed to have HIV infection. Toothbrushes and razors should not be shared under any circumstances but in particular because of HIV status.
6) Since HIV is transmitted through blood, semen and vaginal secretions, as are other pathogens, and since according to the latest scientific and medical evidence HIV is not transmitted by sweat, feces, urine, vomit, tears, saliva, sputum or nasal mucous, unless these fluids contain blood, HEC’s students and employees will follow the Universal Precautions issued by the Center for Disease Control to clean up all bodily fluids, in handling materials, such as clothing and sanitary napkins, that have come in contact with bodily fluids, regardless of whether those bodily fluids are from a person with HIV infection or believed to have HIV infection and regardless of whether or not the body fluid is considered to contain blood.
7) HEC will educate students and employees about HIV infection/AIDS so that they will understand that they need not feel threatened by the simple presence at HEC of persons with HIV infection, persons believed to have HIV infection, or persons believed to be at risk of HIV infection.
8) HEC will not tolerate, and will strive to prevent and eliminate, any possible discrimination or harassment by students or employees directed at persons with HIV infection, persons believe to have HIV infection, or persons believed to be at risk of HIV infection.

D. Students
1) Students or prospective students, or their parents or guardians who know that the students or prospective students have HIV infection must disclose this information to the Coordinator of Nursing Services in order to facilitate appropriate medical treatment and counseling. Students with AIDS or with clinical evidence of HIV, who are too ill to receive treatment in a residential facility should have an alternative treatment in an appropriate medical or hospital setting.
2) It is assumed that HIV infected students can be served in residential facilities and that their diagnosis does not pose any special consideration in terms of physical facility requirements. In some unusual circumstances, however, a student may exhibit exceptional behavior that poses a theoretical risk to other students or employees. Such behavior would consist of engaging in sexual activity with other students, using parenteral drugs, frequent incontinence and public defecation. Those students whose behavior is determined to be unmanageable should be transferred to an appropriate setting.
3) HEC will not require prospective students to undergo HIV tests as a condition of admission. However, HIV testing may be done after admission in the following circumstances:
a. If the authorization for Diagnostic Testing has been signed by the legal guardian during the pre-placement process and that student has exposed peers or staff to his/her own body fluids.
b. If testing for HIV is requested by a student and the guardian consents and , an HEC physician orders testing. In this case, results would be available to HEC staff as outlined in section D, # 10 of this policy. If the student is 18 years old or older, and competent, guardian consent would not be needed.
c. Anonymous testing may be arranged, if requested by a student, for any student 13 years old or older, at the Neighborhood Health Clinic with no guardian consent, in this case results will not be made available to HEC or any HEC staff.
4) HEC will not deny admission to prospective students with HIV infection, believed to have HIV infection, or believed to be at risk of HIV infection, on the basis that they have HIV infection, are believed to have HIV infection, or are believed to be at risk of HIV infection. HIV infection is not considered a communicable infectious disease for the purpose of the provision elsewhere in this policy. HEC will not admit a student without verification that the student is free from communicable / infectious disease.
5) The person with HIV infection and /or AIDS has a somewhat greater risk of encountering infections in a residential program. In the event of an outbreak at HEC of a communicable disease, nursing will immediately notify the Medical Director of any students with HIV/AIDS infection and follow the directives given, including if necessary transfer and/ or quarantine within HEC, if possible, or at another facility.
6) HEC will not deny students with HIV infection, believed to have HIV infection, or believed to be at risk of HIV infection, any rights, privileges, benefits, or status as students on the basis that they have HIV infection, are believed to have HIV infection, or are believed to be at risk of HIV infection.
7) HEC will not require or request students undergo HIV testing as a condition for obtaining, or retaining rights, privileges, or benefits as a student,
8) If a Program Director has a reasonable belief that a student has HIV infection, the Program Director may request that the school physician refer the student to an appropriate medical setting for an HIV test and, if necessary, treatment. At an appropriate medical setting, the student will be administered an HIV test only after the student or the student’s parent or guardian voluntarily signs an informed consent form consistent with section D, #5 above.
9) A student’s HIV test results, whether positive or negative, will be placed in a sealed envelope labeled “Confidential Medical Information.” HEC will determine whether to maintain any such sealed envelopes in individual students’ medical records or in a separate file with restricted access. Release of test results shall be in accordance with Section D, # 10 below.
10) Testing for HIV antibody is not recommended for any purpose other than early intervention and treatment. HEC will restrict information regarding a student’s HIV status to as few employees as is possible, and will strive to maintain maximum feasible confidentiality. Only employees with an absolute need to know should have medical knowledge of a particular student. In individual situations this might include one or more of the following:
a) student
b) parent or guardian
c) administrators
d) direct care staff, if deemed appropriate by HEC’s community based healthcare provider for employees (e.g., Occupational Health) after an exposure.
e) nursing/medical staff
f) clinical staff
11) If the Medical Director determines that he/she should release a student’s HIV test results in circumstances not mandated by law to anyone other than an employee of HEC, the managing physician, or the student’s parent or guardian, HEC must first obtain the voluntary consent, in accordance with Section D, #3 above, of the student or the student’s parent or guardian.

Employees

1) HEC will not dismiss, refuse to hire, refuse to advance in employment, or otherwise discriminate against persons with HIV infection, believed to have HIV infection, or persons believed to be at risk of HIV infection.
2) HEC will not require that employee or prospective employees disclose their HIV status.
3) HEC will not require that employees or prospective employees undergo HIV testing as a condition of application or employment.
4) Information voluntarily provided by an HEC employee of their HIV status shall be kept confidential and contained in a separate medical file.
5) If requested to do so, HEC will make every effort to accommodate an employee diagnosed with HIV, AIDS , or any other infectious disease.

TUBERCULOSIS SCREENING

Purpose:

To screen all Students for Tuberculosis in order to ensure their safety and control cross infection of students and staff on campus, as recommended by the Centers for Disease Control.

Applies to:

ALL Hillcrest Educational Centers, Inc., Students and Employees.
Components:

1. Routine T.B. Screening
a. ALL new employees, except those known to be skin test positive, shall be given a skin test by Occupational Health using 5 t.u. (.1 ml) of

PPD.
b. ALL students are required to present documentation of PPD screening within 60 days of admission. For past positive reactors, a chest X-ray or TB Clinic Report, prior to acceptance, is required in lieu of testing. Such situations will be reviewed by the medical director on admission and follow up will be done as ordered.
d. ALL students in residence will be given a TB screening every year and a TB test planted if indicated. Positive reactors who have completed adequate preventative treatment do not need repeat chest films, unless they have pulmonary symptoms, which may be due to TB.

2. Testing After Potential Exposure:
a. Immediately following significant exposure to an employee, or student having suspected tuberculosis, all PPD negative persons at risk, will be skin tested. If the test is negative, it will be repeated 12-weeks after exposure, in accordance with CDC Guidelines.
b. Positive reactors do not require a skin test or chest film following exposure, unless they have symptoms suggestive to Tuberculosis.

3. Follow-Up:
a. Employees or Students with a positive skin test, will be required to have a chest X-ray. Those who convert from negative to positive, or have suspicious chest X-rays, will be referred to the Tuberculosis Clinic, or to a private Physician.

4. PPD Skin Test Interpretation
a positive skin test will be defined as follows:
a. 10 mm. induration is considered positive in:
1) Persons having recent close contact with an individual with active T.B.

2) Individuals with a chest X-ray and History consistent with, prior untreated T.B.
b. 15 mm. induration will be considered positive for ALL others.

5. Responsibilities of the Nursing Department
a. Administer TB screenings and TB skin tests if indicated, refer for follow-up, as indicated.
b. Keep appropriate records of each Student.
c. With post-exposure TB testing:

1. Notify exposed personnel, and arrange for skin tests. It is the responsibility of the exposed person to be tested within 5 days of notification.

2. ANY exposed person, who does not have documentation of negative results, cannot return to work, as recommended by the CDC.

3. Notify ALL exposed Personnel and arrange for skin tests to be repeated in 12 weeks.

4. Refer ALL appropriate personnel to a private physician or the Tuberculosis Clinic.

5. Inform the positive (PPD or chest X-ray) personnel to return to work with documented proof of follow-up care, prior to returning to work, as per CDC Guidelines.
d. Notify the Board of Health in accordance with MGL C71, S555A.
e. NO facilities for isolation are available at Hillcrest Educational Centers. If a student who is previously negative is found to have active TB, IMMEDIATE transfer to a health care facility where isolation is available must be arranged.

TUBERCULOSIS CONTROL PROGRAM

Policy:
It is the Policy of HEC to have an effective TB Control Program, which includes early detection, and treatment of persons with active TB.

Purpose:
To reduce the risk of TB transmission in the residential setting.

Program:

I. The ICC is responsible for the design, implementation, and maintenance of the TB Infection Control Program.
II. Policies are developed, implemented, and enforced to ensure early detection of Students and staff who may have infectious TB.
III. Prompt triage and appropriate management of Students and staff who may have TB infection, are done in the Outpatient Setting.
IV. Prompt diagnostic evaluation, and treatment for persons who may have infectious TB
V. Education and training of staff about TB and the effective methods for prevention of TB transmission
VI. Prompt evaluation of possible episodes of transmission of TB on the campus, including health care workers Purified Protein Derivative (PPD) skin test conversions, clusters of cases in health care workers or students, and contacts of TB patients who were not promptly detected and isolated.
VII. Coordination of activities with Local Public Health Department, emphasizing reporting, adequate discharge follow-up, ensuring continuation, and completion of therapy.

IMMUNIZATION PROGRAM

Students:

1. Prior to admission, every attempt is made to obtain an up-to-date Immunization Record on ALL students.
2. If records are not obtainable, or are not complete, a re-immunization schedule or completion schedule is started. Guidelines for immunizations are followed as recommended by the: Massachusetts Department of Public Health, in compliance with Chapter 76, Section 15 of the General Laws of Massachusetts. (See, Standing Orders in the Policy and Procedure Manual).
3. All required immunizations will be completed as necessary and ordered by the physician.

Staff:

1. ALL staff are encouraged to, and given the opportunity to have the Hepatitis B Vaccine series, if desired.
2. A form is provided by Hillcrest’s designated employee health care provider (e.g., Occupational Health), at the provider’s facility, requiring signed consent or refusal.
3. If refused, Staff may re-consider at any time during their employment, and receive the Vaccine.
4. At time of employment, all staff are encouraged to review their current immunization status with their own primary health care provider.

PANDEMIC MANAGEMENT SITE COORDINATOR

The PMSC role for the program site is filled by the site’s Head Nurse.

FUNCTIONAL DESCRIPTION:

In conjunction with the HEC Pandemic Management Coordinator, the Site Coordinator serves as program site’s coordinator for the primary aspects of pandemic management during the flu season, including but not limited to:
• medical and nursing activities,
• communication to staff and students regarding prevention and mitigation activities,
• consultation on and monitoring of the HEC Pandemic Management Plan,
• coordinating and communicating student illness data to the HEC Pandemic Management Coordinator,
• monitoring and communicating state and regional influenza data and reports provided by the HEC Pandemic Management Coordinator to the Program Director,
• other duties as assigned by the HEC Pandemic Management Coordinator.

AGENCY PANDEMIC MANAGEMENT COORDINATOR

The PMC role is filled by the HEC Director of Nursing Services.

FUNCTIONAL DESCRIPTION:

This person serves as HEC’s coordinator for the primary aspects of pandemic management during the flu season, including but not limited to:
• medical and nursing activities,
• communication to staff and students regarding prevention and mitigation activities,
• consultation on and monitoring of the HEC Pandemic Management Plan,
• coordinating and communicating student illness and staff absence data to the ExVP and SMT,
• monitoring and communicating state and regional influenza data and reports to the ExVP and SMT,
• communicating with local and regional medical and emergency resources as needed/indicated,
• other duties as assigned by the CEO or ExVP.

PMP – Goals, Assumptions, Thresholds, Activities/Functions, Threat Levels

A) Goals:
To ensure —
1. The continuity of essential functions and services.
2. The safety and well-being of students and staff.
3. The emergency delegation of authority, as necessary.
4. The adequate and accurate documentation of pandemic management activities and risk management activities vital to the agency.

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B) Assumptions:
1. Significant numbers of students and staff may be affected by seasonal flu and PANDEMIC ILLNESS.
2. Staff levels may be significantly reduced due to high levels of illness and hospitalization.
3. Remaining workers may be psychologically affected by disease, family concerns, concerns about economic loss, or fear, and require behavioral assistance.
4. Staff may be reduced by the need for some workers to attend to family illness or to children remaining at home due to school closures.
5. Staffing reductions may be temporary or long-term.
6. Local and regional support resources and infrastructure may be negatively affected. (e.g., schools, medical facilities, transportation systems, supply chains.)

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C) Staffing Thresholds Premises
1).. Each RTC staffs at 1 to 3 staff over ratio on each shift including the Supe and Asst. Supe.
2) HC has 1 Supe and 3 Asst. Supes on the Academic and Residential shifts, and 1 Supe and 1 Asst. Supe on the Overnight shifts. (= 10 supe staff per day).
HP has 1 Supe and 2 Asst. Supes on the Academic shift, and 1 Supe and 3 Asst. Supes on the Residential shifts, and 1 Supe and 2 Asst. Supe on the Overnight shifts. (= 10 supe staff per day)
BS/ITU has 1 Supe and 2 Asst. Supes on the Academic and Residential shifts, and 1 Supe and 1 Asst. Supe on the Overnight shifts. (= 5 supe staff per day)
3) If necessary to remain at required staff : student ratio, some number of supervisory staff can move “into the count”.
4) Absences for all employees, both DC and non-DC employees, throughout the year, including ‘flu season’, average 6.1/day, with a range from 4.2/day to 8.7/day.
5) It is neither necessary nor practical to develop thresholds for Non-Direct Care staff because any urgency associated with their absence depends directly on their location, role, function and the depth of backup available for their role / position. .

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D) Activities and functions covered by the PM Plan :
1. Prevention (PR)
2. Mitigation (MI)
3. Continuity of Essential Operations & Functions (CO)
4. General flu related activities (e.g., information, communications, reassurance, ensuring lines of leadership/authority) (GEN)

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E) Levels of threat/contagion, key indicators, operational status:
Essential activity: close monitoring and reporting of student illnesses and
staff absences.

Level 1 – “Routine” conditions –
a) relatively low and relatively stable frequencies
of flu cases among students and of staff absences .
b) No noticeable increase in cases or staff absences.
• Operations are essentially unaffected or only slightly affected. Few, if any, operational modifications are needed.

Level 2 – “Elevated” conditions –
a) higher than average incidence of flu cases among students and
of staff absences.
b) notably increasing numbers of cases
• Operations are affected and operational modifications are indicated or necessary.

Level 3 – “Emergency” conditions –
a) abnormally high numbers of cases and/or of staff absences
b) sharply climbing numbers of cases among students and staff absences.
c) unusually severe symptoms
• Operations are significantly affected; devolution of function and/or authority and major modifications of operations are required.
Primary goal is continuity of essential functions and operations.

ADDENDUM 4: PANDEMIC MANAGEMENT SITE COORDINATOR

The PMSC role for the program site is filled by the site’s Head Nurse.

FUNCTIONAL DESCRIPTION:

In conjunction with the HEC Pandemic Management Coordinator, the Site Coordinator serves as program site’s coordinator for the primary aspects of pandemic management during the flu season, including but not limited to:
• medical and nursing activities,
• communication to staff and students regarding prevention and mitigation activities,
• consultation on and monitoring of the HEC Pandemic Management Plan,
• coordinating and communicating student illness data to the HEC Pandemic Management Coordinator,
• monitoring and communicating state and regional influenza data and reports provided by the HEC Pandemic Management Coordinator to the Program Director,
• other duties as assigned by the HEC Pandemic Management
NM/DH/BG OCTOBER 2009

ADDENDUM 3: AGENCY PANDEMIC MANAGEMENT COORDINATOR

The PMC role is filled by the HEC Director of Nursing Services.

FUNCTIONAL DESCRIPTION:

This person serves as HEC’s coordinator for the primary aspects of pandemic management during the flu season, including but not limited to:
• medical and nursing activities,
• communication to staff and students regarding prevention and mitigation activities,
• consultation on and monitoring of the HEC Pandemic Management Plan,
• coordinating and communicating student illness and staff absence data to the ExVP and SMT,
• monitoring and communicating state and regional influenza data and reports to the ExVP and SMT,
• communicating with local and regional medical and emergency resources as needed/indicated,
• other duties as assigned by the CEO or ExVP.

NM/DH/BG OCTOBER 2009

ADDENDUM 2: PANDEMIC MANAGEMENT PLAN (PMP): FOOD SERVICE

In view of the recent information regarding the swine influenza (PANDEMIC ILLNESS) the following procedures will be available for all HEC campuses. These steps include:

• Level 1-“Routine” conditions:
a) Follow regular menu
b) Emergency supplies for routine levels of infection
1. Canned RTE soups
2. Carnation Instant Breakfast
3. Snack Bars
4. Bottled Water
5. One week supply of disposable plastic ware and utensils

• Level 2- “ Elevated “conditions:
a) Follow “Routine” condition procedures

• Level 3- “Emergency” conditions”
a) Cook out one side of week -on call Cook provides service
b) Cooks out on both sides of week- food prepared at satellite site and transported by Staff
c) All Kitchens can provide food for every Campus. We will schedule two Cooks on each side of the week for this emergency service, three cooks if one kitchen is to provide for all four sites.