COMPASS LABORATORY SERVICES COLLECTION PROCEDURES AND FAQS

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1 COMPASS LABORATORY SERVICES COLLECTION PROCEDURES AND FAQS

2 COMPANY CONTACTS For any questions regarding your account, specimen collection, IT troubleshooting, or to order more supplies, please contact Customer Service by , phone or fax. Phone: Fax: For all questions regarding specimen collection, time and attendance, training questions, or shift coverage, please contact your assigned IOP Manager.

3 BILLING POLICY Compass Laboratory Services believes that each patient is unique with individual risk factors including genetic composition, lifestyle, and comorbidities. Compass equips providers and patients with the information necessary to obtain the most detailed understanding of their risk. Compass also believes that these services must be affordable for patients, their health insurers, and Compass. As a general rule, three different types of insurers pay for Compass services on behalf of our patients: government programs; in-network commercial insurers; and out-of-network commercial insurers. In addition, our uninsured patients may also pay us directly. GOVERNMENT PROGRAMS (MEDICARE, MEDICARE ADVANTAGE, MANAGED MEDICAID): Compass testing is covered by traditional Medicare and other government health insurance programs. Compass does not bill Medicare fee-for-service patients, in accordance with governmental policy; other government plans may require patient payment of co-pays and deductibles which Compass must bill. IN-NETWORK COVERAGE (COMMERCIAL INSURANCE): Compass works with all major insurers to provide in-network coverage. As a result, Compass is in-network with many of the major insurance carriers. Compass will bill any patient covered by an insurance company with which Compass is an in-network laboratory the co-pay and/or the deductible amounts required by his or her individual plan. OUT-OF-NETWORK COVERAGE (COMMERCIAL INSURANCE): In the event Compass is out-of-network with a patient s commercial health insurer, Compass will bill the insurance company and, after receiving reimbursement or a denial from the insurer, will, as permitted by state law, send a bill to the patient for all of the tests that Compass performed. UNINSURED-PATIENTS: Compass will bill uninsured patients at the price indicated in the Uninsured Patient Pricing Guide. For additional information please visit us at compasslabservices.com.

4 PRESCRIPTION DRUG MANAGEMENT

5 PDM REQUISITION INSTRUCTIONS URINE REQUISITION PLEASE PRINT ALL INFORMATION LEGIBLY Section 1: Complete patient demographics and insurance. Consent/Insurance Release: I voluntarily consent to the collection and testing of my specimen and certify that the specimen identified on this form is my own; it is fresh and has not been adulterated in any manner. I certify that the information provided on this form and on the specimen bottle is accurate. I further authorize that laboratory to release the results of this testing to the ordering facility. I furthermore hereby authorize my insurance benefits to be paid directly to Compass Laboratory Services LLC for services I receive. I acknowledge that the Lab & Clinic may be an out-of-network facility within my insurance. I am also aware in some circumstances my insurance will send the payment directly to me for the services provided. Under law I agree to endorse the insurance check and forward it to the Lab & Clinic within 30 days of receipt. Failure to do so could result in my account being forwarded to collections. By checking Self-Pay I agree to be financially responsible for these tests. Section 2: Include ordering physician name, date and time collected, and processor name. Section 3: Please list all currently prescribed patient medications. Do not provide a separate medication list. For any medication not listed, please check Other and list. C-001 (01/16) Section 6: Please include all applicable ICD-10 diagnosis codes. Panel Changes And / Or Add Ons Place and Center Barcode Label Over Cap Panel 1 Panel 4 Panel 5 Panel 6 Panel 7 Do Not Perform Validity Testing Do Not Perform Standing Profile - Perform test / profile selected above Physician Signature (Required) Date: / / Date (Mo. Day Year) Donor s Initials Section 5: The Standing Order requested by the clinician will be performed unless the clinician clearly marks other testing and checks the Do Not Perform Standing Profile checkbox. If other testing is selected, the clinician must complete the physician signature in Section 7. Patient must initial barcode label. Two identifiers must be included B

6 PDM URINE REQUISITION FAQS What is the PDM Requisition? The PDM Requisition is a BLUE requisition for your immediate recognition. This requisition is used for typical drug screening. If you create a profile, it will be printed directly on the requisition. You will need to check this profile for testing or choose other tests if you do not want to perform your annual profile. What do I need to remember about this requisition? Compass must have two forms of identification for each requisition. Forms of identification include social security number, date of birth, or name. Compass must also have two forms of identification on the specimen. For your convenience, the barcode included on every requisition will suffice as one form of identification. We then request you use the patient s initials as the second identifier. The ordering physician MUST BE PROVIDED and match a physician listed on file for the account. Diagnosis codes must be provided. Please provide all appropriate diagnosis codes; these should align with the notations in the patient records. Mark medications from the list on the requisition. If the drug is not on the list, please provide the medication by writing in the appropriate section on the requisition. Please do not send a medication list separately. The White copy of the carbon requisition is sent to the Lab, the Yellow copy stays with the physician and the Pink copy is the patient s. What if the requisition is not completed correctly? If the requisition is filled out incorrectly, it will be sent to the specimen management team. Someone from this team will contact the office for needed information to complete the requsition. It is important to remember that specimens are held, and reports are not released until corrected information is received. Timeliness is extremely important. Additionally, below are examples of the most common issues: The patient initials on the bottle seal do not match the patient name on the requisition The barcode label on the specimen does not match the barcode on the requisition Insurance information is not provided and the patient is not selected as a self-pay patient Correction fluid is used to correct a requisition error. In the event of error please mark through the error, correct it, and initial next to the correction If there is mismatched demographic information between the requisition and any provided patient data sheets The specimen cup is not labeled or if the initials on the cup are inconsistent with the requisition

7 PDM URINE REQUISITION FAQS (CONTINUED) In the event a requisition is incomplete, will the specimen still be processed? In most instances the specimen will be processed but results held until the information is received. There are, however, some instances which preclude Compass from processing the specimen until the information is completed and returned: Account information absent on the requisition The requisition is not a Compass Laboratory requisition A photocopy of the requisition is received instead of the original requisition Tests are not clearly marked Will a specimen ever be rejected? There are some instances where Compass has no alternative but to reject specimens. These reasons include: 2 patient identifiers are not included on the specimen cup Specimen leakage during transit

8 ORAL FLUID SPECIMEN COLLECTION INSTRUCTIONS When do I use oral fluid collection? Oral Fluid collections are to be utilized only if the patient cannot provide a sufficient urine specimen. What supplies will I need for oral fluid collection? Requisition 1 Quantisal collection device 1 red top collection tube Resealable specimen collection bag NOTE: Oral Fluid collections should never be refrigerated. Ship specimens same day as collection. Specimens must be tested within 4 days of collection. What steps do I take to collect oral fluid specimens? 1. Verify donor identity. 2. Check the expiration date on the Quantisal collection device (found on the transport tube with the red cap). DO NOT USE IF EXPIRED. 3. Confirm that donor has not consumed food, beverage, chewing tobacco, or sublingual medications for at least 10 minutes prior to specimen collection. If any consumption has occurred, wait an additional 10 minutes before proceeding to the next step. 4. Remove Quantisal collection device from resealable bag. Open at the notch and remove collection device. Do not remove the red top tube at this time. DO NOT DISCARD the resealable bag, as the specimen will be returned for testing in this bag. 5. Position collection device under patient s tongue and mouth should be closed. Patient MUST NOT chew on pad, talk, or remove the collection device until the indicator turns BLUE. Patient should then tilt head down and circulate tongue to help produce saliva. In most cases, the volume adequacy indicator will turn blue within 2-5 minutes. If it does not turn blue discard the Quantisal device. Patient should then drink water, wait 10 minutes, and recollect. 6. When the indicator turns BLUE, hold red top transport tube in an upright position and uncap by pushing up with thumb. DO NOT SPILL OR EMPTY LIQUID FROM THE TUBE. 7. Insert collection device into the uncapped transport tube and replace cap. 8. Snap the cap firmly closed for transport. Ensure the SNAP is audible to complete closure. Have patient initial and date barcode sticker at the bottom of the requisition. Place label on the center of the transport tube as indicated on the label and press down on both sides to secure label to the tube and create a security seal over the red cap. 9. Confirm that the requisition is accurate and complete. 10. Fold requisition so that patient information is not visible and place in the back pouch of the resealable bag. 11. Place specimen transport tube in the main compartment of the resealable bag. Seal bag and ship according to proper guidelines as detailed in this document Nonconnah Blvd. Ste Memphis, TN compasslabservices.com

9 ORAL FLUID REQUISITION INSTRUCTIONS URINE REQUISITION PLEASE PRINT ALL INFORMATION LEGIBLY Section 1: Complete patient demographics and insurance. Gender Consent/Insurance Release: I voluntarily consent to the collection and testing of my specimen and certify that the specimen identified on this form is my own; it is fresh and has not been adulterated in any manner. I certify that the information provided on this form and on the specimen bottle is accurate. I further authorize that laboratory to release the results of this testing to the ordering facility. I furthermore hereby authorize my insurance benefits to be paid directly to Compass Laboratory Services LLC for services I receive. I acknowledge that the Lab & Clinic may be an out-of-network facility within my insurance. I am also aware in some circumstances my insurance will send the payment directly to me for the services provided. Under law I agree to endorse the insurance check and forward it to the Lab & Clinic within 30 days of receipt. Failure to do so could result in my account being forwarded to collections. By checking Self-Pay I agree to be financially responsible for these tests. Compass Laboratory Services for services I receive. I acknowledge that the Lab & Clinic may be an out-of-network facility within my insurance. I am also aware in some circumstances my insurances will send the payment directly to me for the services provided. Under law I agree to endorse the insurance check and forward it to the Lab & Clinic within 30 days of receipt. Failure to do so could result in my account being forwarded to collections. By checking Self-Pay I agree Section 3: Please select all currently prescribed patient medications. Do not provide a separate medication list. For any medication not listed, please check Other and list. C-001 (01/16) Section 5: Please include all ICD-10 codes relevant to this visit. Panel Changes And / Or Add Ons Panel 1 Panel 42 Panel 53 Panel 64 Panel 75 Do Not Perform Validity Testing Physician Signature (Required) Physician Signature (Required) Place and Center Barcode Label Over Cap / / Date (Mo. Day Year) Donor s Initials SLIT HERE Section 2: Ordering physician name, date and time collected, and processor name are required. Section 5: The Standing Order requested by the clinician will be performed unless the clinician clearly marks other testing and checks the Do Not Perform Standing Profile checkbox. If other testing is selected, the clinician must Date: complete the physician signature in Section C Rev Patient must initial B C barcode label.

10 SPECIMEN PACKING AND SHIPPING FAQS Can I ship urine and oral specimens in the same box? Yes! The preferred method is to ship both Urine and Oral in the same package. How are the specimens supposed to look before I ship them? URINE ORAL How long are PDM specimens valid? Specimen validity requires urine specimens to be tested within 7 days of collection. Any urine specimen received outside the 7 day collection window will be released with a stability comment on the final report. Specimen validity requires that all Oral Fluid specimens should be tested within 4 days of collection. If they are received outside of this 4 day range, the report will list Specimen exceeds 4 day collection limit. Discarded. Also note that due to weekend delivery, any specimens collected on Fridays, must be shipped that same day. Tuesday will be the last valid day for testing. Can I use FedEx or UPS? Yes! If using FedEx, place the secure specimens directly in the brown clinical box. Attach the return shipping label. The return shipping label is located in the bag stating, Only use these labels when returning PDM (Prescription Drug Management) or Oral Fluid specimens to Compass Laboratory. If your clinic utilizes UPS for shipping, place the secure specimens in a UPS branded LaboratoryPak and seal the bag. Place the sealed LaboratoryPak in a standard UPS box. Close and seal the box, and attach the Return Shipping Label stating, Only use these labels when returning PDM (Prescription Drug Management) or Oral Fluid specimens to Compass Laboratory.

11 PDM SUPPLIES FAQS What supplies will I need for PDM Urine? Requisitions Toxicology Kits (sealable specimen cups and a specimen bag for return) Specimen bags (only for accounts utilizing Point of Care testing) Materials for return shipping What supplies will I need for PDM Oral Fluid? Requisitions Oral Fluid Collection Kits (Including 1 Quantisal collection device) *Please store kits at room temperature before patient use, as well as after specimen is collected. DO NOT REFRIGERATE. Materials for return shipping How do I place a reorder? Sales representatives will order the initial supply shipment, and a reorder form is included with every supply shipment. A reorder form is also included in this binder. Where do I submit the reorder form? Submit the reorder form to Compass Customer Service at customerservice@compasslabservices.com or by phone at or fax How long will it take to receive supplies? Please order supplies 10 days in advance to ensure no disruption in service.

12 PDM SUPPLY ORDER FORM PRESCRIPTION DRUG MANAGEMENT SUPPLY ORDER FORM Clinic Name Shipping Address Requested By Date Ordered COLLECTION SUPPLIES PDM Requisitions (each) Specimen Cups w/ Bags (each) Specimen Bags, Non-Biohazard (each)* Small Disposable Gloves (Box of 200) Medium Disposable Gloves (Box of 200) Large Disposable Gloves (Box of 200) SHIPPING SUPPLIES Shipping Labels Clinical Boxes, Medium (20 pack) Clinical Boxes, Large (20 pack) *Available for POC clients only. Available for Compass employees only. order to or fax to Supply orders are shipped Ground. Please order supplies 10 days in advance to ensure no disruption in service. LAB USE ONLY Order Received: Confirmation Number: This form is to be used as an example only. Please use order form that will come with all of your shipments

13 ORAL FLUID SUPPLY ORDER FORM ORAL FLUID SUPPLY ORDER FORM Clinic Name Shipping Address Requested By Date Ordered COLLECTION SUPPLIES Oral Fluid Requisitions (each) Oral Fluid Collection Kits (each) Small Disposable Gloves (Box of 200)* Medium Disposable Gloves (Box of 200)* Large Disposable Gloves (Box of 200)* SHIPPING SUPPLIES Shipping Labels Clinical Boxes, Medium (20 pack) Clinical Boxes, Large (20 pack) *Available for Compass employees only. order to or fax to Supply orders are shipped Ground. Please order supplies 10 days in advance to ensure no disruption in service. LAB USE ONLY Order Received: Confirmation Number: This form is to be used as an example only. Please use order form that will come with all of your shipments.

14 ADDITIONAL RESOURCES

15 WEB PORTAL REPORTING USER GUIDE 1 To access the web portal, enter the following URL: The web portal can also be reached from the top right-hand corner of our main site, 2 Enter your User ID, Password, and Location ID as provided by the Laboratory. Click Login. Upon login, you will be redirected to the main screen (below). 3 From the menu on the left, choose Inquiry. You will then see the below screen. Please note, the Inquiry view will show all completed reports.

16 WEB PORTAL REPORTING USER GUIDE (CONT.) 4 Search by entering any or all of the following criteria: Starting Collection Date (MM/DD/YYY) Patient s Name (Last Name OR Last Name, First Name; use % symbol for less specific searches). Ending Collection Date (MM/DD/YYY) Requisition Number SPECIMEN KEY: S: Oral Fluid # Only: PDM To search ALL specimen reports, you can leave this screen blank. This view will show ALL specimen types for ALL clients tied to your portal. 5 Your search results will be displayed in a table. The specimens displayed are sorted first by Account, then Collection Date (with the most recent at the top), and then by Alphabetical Last Name Listing. 6 The Web Portal will show up to 20 results at one time. To view more results, click More. Click the Report link on the right side of the screen for the patient s results you would like to view. A new window showing the report will pop up. The report can be printed or saved.

17 WEB PORTAL REPORTING USER GUIDE (CONT.) 7 From the main menu, choose Reporting on the left. Please note, this view does not list any partial reports. From the column of checkboxes that appears on the left-hand side of the screen, choose the report(s) you want to print or choose All Selected. Once you ve made your selection, click Print Selected at the bottom right-hand side of the screen. 8 A new window will be launched with a combined PDF of the reports. Click Print to send the reports to your printer. 9 After launching your reports into a separate window, you will see the following box: Please note, this question controls your Inbox. If you are pleased with the reports that were printed or saved, click OK. If you want to leave reports in your Inbox, click Cancel.* *You can retrieve a completed report from the Inquiry screen at a later date if you remove it from your Inbox.

18 WEB PORTAL REPORTING USER GUIDE (CONT.) 10 From the main menu, choose Pending on the left. 11 Click the folder next to the account you d like to view. 12 A listing of all specimens that have been reviewed by the lab and are still in progress (Pending) will be displayed. To view the test(s) in progress, click the folder beside the specimen number.

19 WEB PORTAL TROUBLESHOOTING 1. Internet Explorer or Microsoft Edge (Windows 10) web browsers work best. 2. Verify that Java is up to date. Look for an icon in the bottom right corner of the Windows desktop. 3. Verify that all Windows updates have been performed. This can be verified in the Control Panel for Windows 7 or 8, or in Settings for Windows Call Compass customer service to ensure that the web portal is working properly. If so, you may be transferred to IT to better help you solve the problem

20 PDM SAMPLE REPORT PRESCRIPTION DRUG MANAGEMENT SAMPLE REPORT Patient Name: Patient, Example Gender: DOB: 06/20/1953 This section shows Specimen all ID of #: the drugs Z000000that are currently Collected prescribed Date: to the 05/13/2016 patient. Received Date: 05/16/2016 Reported Date/Time: 10/05/ :14 Specimen Type: Urine Dr. Thomas H. Jones 1234 Compass Street City, ST Compass Laboratory Services 1910 Nonconnah Blvd. Suite 108 Memphis, TN Phone: Fax: Laboratory Director: Dr. Charles Handorf CLIA #: 44D Prescribed Medication(s): Xanax, Hydrocodone, Ativan Test Name Confirmation Value (ng/ml) DRUG TESTING RESULTS Cutoffs Result (ng/ml) Detection Window Creat. Adj. Comments Drugs Consistent with Medications Alprazolam (LCMS) Positive 1-3 days. 362 Parent drug found. Consistent with prescription. Hydroxyalprazolam (LCMS) (Alprazolam Metabolite) Positive 1-3 days. 904 Metabolite found. Consistent with prescription. These sections outline the Drugs Inconsistent with Medications results of drugs detected, Amphetamine (LCMS) Positive 1-3 days. 362 Inconsistent and if prescribed without drugs are not prescription. detected. Methamphetamine (LCMS) Positive 1-3 days. 724 Inconsistent without prescription. Drugs Prescribed but not Detected Lorazepam (LCMS) 0 50 Negative 1-6 days 0 Parent drug and metabolite not found. Inconsistent with prescription. Hydrocodone (LCMS) 0 50 Negative 1-2 days. 0 Parent drug and metabolite not found. Inconsistent with prescription. Test Name Confirmation Value Cutoffs (ng/ml) Result Amphetamine (LCMS) Positive Methamphetamine (LCMS) Positive MDMA (LCMS) Negative MDA (LCMS) Negative MDEA (LCMS) Negative Clonazepam (LCMS) 0 50 Negative 7-Aminoclonazepam (LCMS) 0 50 Negative Laboratory Specimen #: Z This section shows all of the drugs that were tested on the patient and their results. Printed It Date/Time: continues Oct 5 to 2016 the 2:14PM back page. Page 1 of 2 Patient Name: Patient, Example 1910 Nonconnah Blvd, Suite 120 Memphis, TN

21 PDM ADD/REMOVE FORM PRESCRIPTION DRUG MANAGEMENT ADD TEST FORM Clinic/Practice Name: Requisition # (required): Patient Name: Physician Signature (required): Additional Diagnosis Codes: To add tests from previous requisition, please write the drug in the appropriate line. NOTE: Compass will only hold specimens for 30 days. Complete and fax this form to ADD 1910 Nonconnah Blvd, Suite 120 Memphis, TN This form is available if you need to make changes to your test selection. Please contact Customer Service if you would like to utilize this form.

22 EMPLOYEE INFORMATION

23 PAYLOCITY Paylocity is the name of our Employee Management system. This system is where you will clock in and out, access your pay history and details, along with request PTO and access benefits information if you are a benefit-eligible employee. You should be familiar with the system from your Onboarding process, but below are some helpful reminders. 1. The Company ID is Security answers are case sensitive. If you cannot access your account because you have forgotten your login information or security answers, please contact the Lab and ask for the HR department.. 3. If you forget your password, you can select the Forgot Password option from the main App screen, and Paylocity will send you an with a temporary password to your Compass address. 4. Time Keeping is accessed through the Paylocity Mobile App. You can also request PTO through the mobile app. 5. If you need to leave a note for your supervisor, make sure you type in the Add Note field before you hit Submit. 6. As long as Location acquired is showing in the Location box, your punch will register. 7. You can select your clocking activity - Clocking In, Starting Lunch, Ending Lunch or Clocking Out - by selecting the Drop Down box under the time. If you have questions about Paylocity or how you might utilize the system, speak with your IOP Manager.

24 COMPANY Every Compass employee is issued a company address through Microsoft 365 Online. The access and temporary username is ed to your personal address that you submitted on your new hire paperwork. Please access and set up your Compass address within 48 hours of receiving your access. You will receive important training information as well as regular communication from your Manager and the Lab via . Please check you on a daily basis. To access your daily, visit Login.microsoftonline.com If you have questions about access or having your password reset, please contact the Lab at and ask for Support.

25 COMPANY CONTACT LIST IT & Support DEDRICK RUSSELL Customer Service & Supply Orders EMR Support JONATHON MORGAN Insurance, Payroll & General HR MEGAN KELLY/RACHEL HOLOBAUGH Specimen Management Logistics & Field Operations PAULA SEWARD General Lab Info 1910 NONCONNAH BLVD, SUITE 108 MEMPHIS, TN P: F: IOP Managers ANNAH JONES: CATHY BROWNING: IOP Support Specialist MARQUITA JAMES:

26 TRAINING & ENCRYPTION TRAINING All new Compass employees must complete online courses for HIPAA (Health Insurance Portability and Accountability Act) Certification and compliance training. The links to complete training will be sent to your Compass address within 48 hours of your start date. This certification course must be completed within 30 days of your start date. If not completed within the 30 day time period, you cannot return to work until completed. There may be additional trainings throughout your employment. Your assigned IOP Manager or the Compass HR department will communicate with you directly when these trainings are required. ENCRYPTION Part of your HIPPA compliance is directly related to understanding how to protect PHI (Personal Health Information) if you need to send this information via . PHI includes any information specific to a patient including Name, Date of Birth, Insurance Identification, Social Security Number or Requisition number. Below are the instructions to send and open Encrypted s using your Compass address. 1. If you ever need to send an that includes PHI, type the word Encrypt in the Subject line of the followed by the subject. For example, Encrypt - Missing Information for Dr. Smith. 2. If you receive any information related to Patient Health Information (PHI), the will come encrypted. The word Encrypt will be in the subject line, and look like the below. The recipient will receive a message similar to below. Right click on the message.html attachment and save in your location of choice.

27 TRAINING & ENCRYPTION (CONT) 3. Opening the attachment will bring up the following screen. There are two options: A. Click on the SIGN IN AND VIEW YOUR ENCRYPTED MESSAGE if you have a Microsoft Live ID or an existing Office365 login. B. Click on the Don t want to sign in? Get a one-time passcode to view the message if you do not have or do not want to log in with credentials. 4. If you are logged in to your Compass work , choosing option A. from step 4 above will open the with no additional steps. 5. If you are not logged into your work , they will be prompted to select from the following options. Choose Organizational account if you have an Office365 account. Compass is an Organizational account. Select Organizational account and enter your username and password.

28 TRAINING & ENCRYPTION (CONT) ADDITIONAL NOTES FOR ENCRYPTED 1. When replying to encrypted s internally, messages will maintain encryption. 2. If the recipient is external and replies to an encrypted , it will not maintain encryption on the reply. 3. Encrypted messages can be forwarded internally through the Compass system and maintain encryption. 4. Encrypted messages cannot be forwarded from one external party to the other because the pass code and sign in is only tied to the original recipient. YOU CANNOT TEXT ANY PATIENT INFORMATION AT ANY TIME. THIS IS A VIOLATION OF HIPAA PRIVACY. THIS INCLUDES SPECIFIC PATIENT INFORMATION, IMAGES OF COMPLETED REQUISITIONS, ETC.

29 EMPLOYEE HANDBOOK HIGHLIGHTS The full Compass Employee Handbook can be accessed at any time from the Paylocity employee portal. Below are some specific sections pertinent to your position. Please reference the full version for any questions and contact your IOP Manager or the Compass HR department. COMPANY PROPERTY If you are issued company property such as computers, laptops, cell phones, printers, etcetera, such property is considered owned solely by Compass and would fall under any scope and management as outlined in the workplace privacy policy. As the recipient, any employee in possession of Compass property must be responsible for protecting and keeping track of all property. Any and all repair issues should be directed to the Compass IT department. Should the employee separate from Compass, it is the employee s responsibility to return all property in working condition to their supervisor during their separation process. Final paychecks will be held until all equipment is returned and found to be in working condition. WORKING A COMPANY HOLIDAY If an employee is asked by a Compass Manager to work on a holiday, they will be paid time and a half for any hours worked, and their standard rate of pay for the remainder of their designated holiday schedule. HOLIDAY THAT FALLS ON A WEEKEND If a Compass recognized holiday falls on a weekend day, management will make a decision based on expected volume as to which day will be recognized as the Holiday (Friday before or Monday after) and alert employees in a timely manner. EXTENUATING CLOSURE Should a clinic close for additional holidays beyond Company holidays or for any additional days that would traditionally be open, Compass employees at those locations must contact the IOP Manager to discuss their options. Options would include taking PTO, taking unpaid time off as approved by the IOP Manager, or working with the IOP Manager to find a facility to temporarily fill in as needed. Unless there are extenuating circumstances around the distance travelled, any mileage incurred driving to a temporary location would not be eligible for reimbursement.

30 Below is the Employee Agreement that you signed during your new hire onboarding process. If at any time you have questions about what you are permitted or prohibited from doing, please contact your IOP Manager. COMPASS LABORATORY SERVICES SPECIMEN PROCESSOR POLICY (Specimen Processors) To comply with the federal Physician Self-Referral Law, 42, U.S.C. 1395nn, and the regulations promulgated thereunder ( the Stark Law ) or the Medicare and Medicaid Patient Protection Act of 1987, as amended, 42 U.S.C. 1320a-7b (the Anti-kickback Statute ), individuals who process urine or other specimens ( Specimens ) (including any staff, employees or agents of Compass Laboratory Services, LLC ( Compass ) ( Specimen Processors )) may not provide any services to, or on behalf of, the physician practice. The Compliance Memorandum of Understanding with each physician practice shall state this understanding clearly. Protocol for Specimen Processors: Only those processing and clerical duties for Compass that are directly related to the handling and processing of laboratory specimens may be performed. PERMITTED SERVICES: 1. Specimen preparation for transport. 2. Packaging of Specimen for transport. 3. Collection of Advance Beneficiary Notice (ABN) form. 4. Clerical duties for Compass directly related to the specimen being collected, i.e. filing of requisitions, routing of ABN, and handling of Compass test-specific forms. 5. On-line entry of orders into Compass software from a written requisition/order provided by the physician s office. 6. Pull or access actual or electronic health records for the sole purpose of processing the Specimen. 7. Generate a list of patients for the day and have it signed or checked off by the physician if the list is solely for the use of Compass. 8. Access records (electronic or hard copies) so long as it is for the sole purpose of processing the Specimen and has no benefit to and does not supplement the physician s office operations. 9. Obtain the height and weight from a patient if it is for the sole purpose of processing a Specimen. PROHIBITED SERVICES: Specimen Processors SHALL NOT do any of the following (whether urine or any other specimen): 1. Take vital signs or perform other nursing functions. 2. Test, collect, or process for any other laboratory, unless a charge is billed for such service pursuant to Compass policies and procedures. 3. Register patient s demographics into the physician s computer system. 4. Prepare laboratory test orders on behalf of the physician s office. 5. Fill out and/or complete any test-specific forms for the Clinic. 6. Collate or file results for the physician s office. 7. Answer the office phone for results or other matters. Call patients for appointments. 8. Perform venipuncture or other specimen collection services for testing to be performed by the physician s office laboratory. 9. Perform venipuncture or other specimen collection services for patients having exclusive insurance requiring the specimen to be directed to a laboratory other than Compass. The only exception to this is a written agreement between the parties. 10. Suggest to any physician or staff of the physician that a Specimen be taken. 11. Place a report in or along-side of the patient s medical record. 12. Perform any patient filing or other administrative duties for the physician s office, related to the Specimen or otherwise.

31 13. Assist with a point of care test ( POCT ) in any way. 14. Read or interpret POCT results. 15. Record POCT results in a patient s medical record. 16. Provide any other services that supplement a clinic s practice, or that otherwise would be performed by clinic staff in the physician practice setting, except as permitted expressly by this Specimen Processor Policy. 17. In the processing of urine specimen, specifically, Specimen Processors also SHALL NOT do any of the following tasks: a. Be involved in the handing of, or receiving of, a cup to or from a patient. (In the typical physician office, the physician s staff must hand and receive the cup to or from the patient with instructions to provide a urine specimen.) b. Obtain the Specimen directly from the patient. In addition, employees or relatives of employees from the clinic may not become or work as Specimen Processors. If a Specimen Processor (or any Compass employee) realizes (a) some action(s) being performed violate this Specimen Processor Policy, or (b) if he/she believes that the clinic personnel or anyone else has given instructions to undertake actions inconsistent with the Specimen Processor Policy, the Specimen Processor (or other Compass employee or agent) should the Compass contact person, Annette Sharpe, at asharpe@compasslabservices.com, and follow the with a phone call at (704) Compass will provide written notice to the Specimen Processor if the contact person changes. My signature below indicates I have read, understand and agree to comply with the Specimen Processor Policy. I understand that any violation of this policy may result in disciplinary action up to and including termination.

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