BDG Employee Handbook

Employee Handbook, effective 3/5/2010

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Employee Handbook


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Welcome! Please familiarize yourself with the policy. In this employee handbook you will find our personnel policies, procedures, work rules and benefits. This handbook will give you insight into what is expected of you and what you can expect from us now that you are a member of our team. This handbook cannot anticipate every situation nor answer every question about your employment. If, during the course of your employment, you have any questions that this handbook does not address, please make sure to ask your office manager or a member of the management team. In order to retain the flexibility necessary to administer this policy, we reserve the right to revise, supplement, or eliminate any benefits, policies, rules, regulations or practices as deemed necessary. You will be notified of any such changes. This handbook and any future revisions provide you with general information only. Nothing in this handbook guarantees the duration of your employment. This policy is not, and should not be construed as a contract of employment. You retain the right, as do we, to terminate the employment relationship at any time, for any reason, with or without cause. Our employees are not hired for any specified term. As a consequence, all employment is viewed as “terminable-at-will” at the option of either the company or the employee.

Foreword For interpretation of this handbook, any reference to the “Management Team” should be defined as the Owner Doctor, Office Manager, Practice Administrator, and/or Business Manager. In addition any reference to the Company should be defined as Aliante Dental, Boston Dental, Brighton Dental, Fenway Dental, Happy Dental and Hola Dental, Happy Dental, Affordable Dental, and Discount Dental.

Equal Employment Opportunity In order to provide equal employment and advancement opportunities to all individuals, employment decisions will be based on merit, qualifications and abilities. The company does not discriminate in employment opportunities or practices on the basis of race, color, religion, sex, national origin, age, ancestry, marital status, sexual orientation, veteran’s status, physical/mental disability unrelated to an individual’s ability to perform the essential functions of a job with or without accommodation, or any other characteristic protected by law except where a bona fide occupational requirement demands such factors be taken into consideration. The company will make reasonable accommodations for qualified individuals with known disabilities unless doing so would result in an undue hardship. This policy governs all aspects of employment, including selection, job assignment, compensation, discipline, termination and access to benefits and training.


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Disability Accommodation

The company is committed to complying fully with the Americans with Disabilities Act (ADA) and ensuring equal opportunity in employment for qualified persons with disabilities. All employment practices and activities are conducted on a non-discriminatory basis. Hiring procedures have been reviewed and provide persons with disabilities meaningful employment opportunities. Pre-employment inquiries are made only regarding an applicant's ability to perform the duties of the position. Post-offer medical examinations are required only for those positions in which there is a bona fide job-related physical requirement. They are given to all persons entering the position only after conditional job offers. Medical records will be kept confidential. Reasonable accommodation is available to all disabled employees, if their disability affects the performance of job functions. All employment decisions are based on the merits of the situation in accordance with defined criteria, not the disability of the individual. This policy is neither exhaustive nor exclusive. The company is committed to taking all other actions necessary to ensure equal employment opportunity for persons with disabilities in accordance with the ADA and all other applicable federal, state, and local laws.

Employee Health Issues Working in a dental office raises special health issues because of the possibility that employees may be exposed to contagious diseases. Stringent infection control policies are in place within the office to protect the workers. This practice urges our personnel to obtain vaccination against Hepatitis B. The office pays for the vaccination of clinical personnel. As required by OSHA, all accidents and injuries occurring during the workday are to be reported as soon as possible to the Management Team. Proper OSHA documentation is to be completed by the Management Team. Medical assistance and subsequent treatment will be provided if necessary. All employees are required to read the OSHA manual provided to each office. Each employee is required to supply written documentation that this has been completed within thirty days from date of hire. This documentation will become a part of the employee’s personnel file.


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Employment Relationship Your employment here should be considered “at will” which means just as you may terminate your employment at will with or without cause or notice, the company has the same opportunity in regards to maintaining your employment. We believe the working conditions, wages, and benefits offered are competitive with those offered by other offices. If you have concerns about the working conditions in your office, you are strongly encouraged to voice these concerns openly and directly with any one of the management team. Our experience has shown when employees deal openly and directly with one another, the office environment becomes team oriented. We feel the individual consideration and team relationships provide the best climate for maximum development of individual and organizational goals. Most of us have had the unfortunate opportunity to work in an office full of gossip and tension. This type of behavior is not tolerated. Make the most of this new career by becoming a valuable member of your new team.

Our Philosophy of Care

We want our patients to keep their teeth for a lifetime in comfort and health. We are committed to a philosophy of dentistry which we call "Lifetime Care". Our philosophy is patient centered and we believe we can positively influence a person's quality of life through "Lifetime Care". We must know our patients so well and care for them so much as people that we can determine from this knowledge what the best lifetime treatment is for their particular needs. We will take every opportunity to motivate and educate patients to the point where he/she desires "Lifetime Care". We need to know if each patient values a healthy mouth and if he/she can handle the investment for the kind of care selected. We fully understand that not all of our patients are candidates for the Lifetime Care approach and that is O.K. These patients will only respond to "patch and repair" (drill-fill-bill) dentistry. We have no problem with this because anything we do is a service to them and for them. We are committed to the "Lifetime Care" philosophy for 3 reasons: 1. We believe lifetime care is in our patient's long-term best interest.

2. We believe the Lifetime Care approach offers our patients the highest quality of life for the investment made and;

3. We believe the Lifetime Care approach to dental care offers a lower lifetime cost over the patch & repair approach.


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The Lifetime Oral Healthcare Program Nature of the Program: It’s a program that assesses people’s oral healthcare needs from a lifetime point of view. It’s a program designed to provide people with maximum oral health for a lifetime. It removes patients from a patch, repair and maintain approach to care to a “Do it right the first time,” the quality way, approach to comprehensive lifetime care provided by a single organization. Its objective is to establish an office environment that is so comfortable and attractive that patients will want to come to your office for their oral healthcare all their lives and will encourage all their friends and relatives to do the same. It’s a program designed to help people keep their teeth for a lifetime. The earlier in life a person enters the program the lower their cost for maximum oral health care during their lifetime. Advantages to the Patient:

Lower lifetime cost. Greater lifetime convenience. Greater lifetime comfort.

Receives maximum quality care. Acquires greater quality of life due to the benefits of the program.

What Offering The Program Means To Our Organization: It means that you will have a superior oral health care program to offer the communities you serve. If you successfully market and deliver this program it may ensure that you will remain the market leader in your area. Becoming and remaining the market leader provides your patients with a better care and service package and ensures you that your organization will be able to meet its goal of being one of the community’s most reputable and respected employers. The end product is happier patients, Doctors and team members who have a fuller, more prosperous life.


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Open Door Policy During your employment, questions or issues may arise that affect your work. By maintaining open communication, we hope to be able to resolve these issues in a timely manner. Please feel free to go to the office manager directly if you have a problem or issue that you need to discuss. We will listen to your concerns with respect and will do our best to help you resolve them.

Unlawful Harassment The company is committed to providing a work environment free of discrimination and unlawful harassment. Actions, words, jokes, or comments based on an individual's sex, race, ethnicity, age, religion, or any other legally protected characteristic will not be tolerated. Any harassing conduct including unwelcome sexual advances, verbal or written sexual or racial abuse, sexually degrading words, unwelcome physical contact, the display of sexually suggestive pictures or objects and any retaliation for reporting harassment is prohibited, whether committed by Dentists, Managers, or other team members. As an example, sexual harassment (both overt and subtle) is a form of employee misconduct that is demeaning to another person, undermines the integrity of the employment relationship, and is strictly prohibited. Should you want to report an incident of sexual or other unlawful harassment, you should promptly report the matter to your office manager. If this person is either unavailable or you believe it would be inappropriate or you do not feel comfortable discussing it with them, you should immediately contact your Practice Administrator. You may raise concerns and make reports without fear of reprisal. Any Doctor or office manager who becomes aware of possible sexual or other unlawful harassment should promptly advise the Practice Administrator who will handle the matter in a timely and confidential manner. The persons involved will be informed of the results immediately. Anyone engaging in sexual or other unlawful harassment will be subject to disciplinary action, up to and including termination of employment.


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Introductory Period At the beginning of your employment you will undergo an introductory period of ninety (90) days. This period is intended to give both of us the opportunity to take a careful look at one another to make certain there is a good “fit.” You’ll have the chance to evaluate your job and the practice, and we’ll have the opportunity to see how well you perform your duties and how well suited you are to the position and your new surroundings. The designation of this introductory period does not constitute an obligation on the part of the company to retain you until the end of the period specified. Employment during the introductory period and beyond remains at will. All employees, regardless of length of service, are expected to maintain our standards for the job performance and conduct.

Employment Categories It is the intent of the company to clarify the definitions of employment classifications so you can understand your employment status and benefit eligibility. These classifications do not guarantee employment. You are designated as either NONEXEMPT or EXEMPT from federal and state wage and hour laws. NONEXEMPT includes most HOURLY employees. These groups are entitled to overtime pay under the specific provisions of federal and state laws. EXEMPT employees are excluded from specific provisions of federal and state wage and hour laws such as overtime pay. Most managers fall into the EXEMPT category. Your EXEMPT or NONEXEMPT classification may be changed only upon written notification by the management team. In addition to the above categories, you will belong to one of the following employment categories: REGULAR FULL-TIME employees are not in a temporary status and are regularly scheduled to work a full-time schedule of at least 32 hours a week. PART-TIME employees are not assigned to a temporary status and are regularly scheduled to work less than 32 hours week. While they do receive all legally mandated benefits, they are ineligible for most of the company’s benefit programs. ON CALL employees are hired as interim replacements, to supplement the work force. Employment assignments in this category are of a limited and/or varied duration. Employment beyond any initially stated period does not in any way imply a change in employment status. On call employees retain that status until otherwise notified. While on call employees receive all legally mandated benefits, they are ineligible for all of the company’s other benefit programs.


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Layoffs If the company determines that reductions in workforce are necessary, consideration will be given to the company’s need for ability and flexibility, in making such determinations. However, final determination is at the discretion of the company and will be based on performance and economic demands.

Outside Employment You may hold a job with another organization or attend school as long as you satisfactorily perform your job responsibilities. We will try to work with your schedule and be flexible but if a conflict arises, your obligation to this company must be met first. You will be judged by the same performance standards and will be subject to the company’s scheduling demands, regardless of any existing outside requirements. If the company determines your outside work interferes with your performance or ability to meet our requirements, you may be asked to terminate the outside employment if you wish to remain employed with us. Outside employment will present a conflict of interest if it has an adverse impact on this company.

License Verification

All licensed employees, upon being hired, are required to present proof of licensure of certification to HR. It is the responsibility of all employees to keep their licenses or certificates current. The company is not responsible for keeping any employee’s license or certification current or in good standing. The company will pay for the renewal of CPR certification for dental assistants and business assistants following 180 calendar days of employment. The CPR training will be held semi-annually at one of our offices.

Job Performance Employees are responsible for performing the duties in their job description adequately and properly. The company’s policies and procedures must be followed. Employees are expected to establish rapport with fellow team members and should not behave in a manner that obstructs or hinders another employee from completing assigned duties. Employees are expected to operate in a manner that is safe to themselves, their co-workers, and the patients and to follow office safety and OSHA protocol at all times. It is the responsibility of employees hired for licensed positions to keep their licenses current and supply the company with proof of valid licenses. The company will not be held responsible for an employee losing a required license because of failure to comply with continuing education requirements.


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Employees should not bring personal problems to work. Employees should not conduct personal business during working hours. Employees may not use or be under the influence of alcohol or illegal drugs during work time. No medication should be used which impairs job performance. The company reserves the right to test an employee under reasonable suspicion or following an on-the-job accident for alcohol or drugs. You and the office manager are strongly encouraged to discuss job performance and goals on an informal, day-to-day basis. Additional formal performance evaluations are conducted to provide both office management and yourself the opportunity to discuss job tasks, identify weaknesses, recognize strengths, and to provide positive approaches for meeting goals. Formal performance evaluations are normally scheduled annually for all regular full-time and part-time employees, coinciding generally with the anniversary of the employee's original date of hire. New employees may receive a formal evaluation after 90 calendar days from their start date. Please keep in mind that a scheduled evaluation does not guarantee an increase in compensation

Your Personal Work Record

The company maintains your personnel file during your employment. The personnel file includes such information as your job application, resume, records of training, documentation of performance appraisals, salary increases, and other employment records. Personnel files are the property of the company, and access to the information they contain is restricted. Generally, only supervisors and management personnel who have a legitimate reason to review information in a file are allowed to do so. The company will follow all state and federal laws governing accessibility to personnel files. If you wish to review your own file or have copies of information, you should contact your office manager in writing. With reasonable advance notice, you may review your own personnel files in the presence of an individual appointed by the management team to maintain the files. Copies of information are restricted to documents signed by you or authorized by the Business Manager.

Payroll Processing/Timekeeping Payroll is processed every two weeks with payday being every other Thursday for a total of 26 payrolls per calendar year. You will be paid on the 9th business day following the payroll cutoff date. For example, for the pay period of February 7th, 2010 to February 20th, 2010, you will be paid on March 4th, 2010 the 9th business day following February 20th, 2010. Business day is Monday through Friday while the workweek runs Sunday through Saturday. All required deductions, such as federal and social security taxes will be held automatically from your paychecks.


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The company takes all reasonable steps to insure you receive the correct amount of pay in each paycheck, and you are paid promptly on the scheduled payday. Please review your paycheck for errors. In the unlikely event there is an error, please bring the discrepancy to the attention of the office manager immediately. It is the policy of the company to comply with all applicable laws that require records to be maintained of the hours worked by our employees. In order to ensure you are paid correctly and in a timely manner, all hourly employees will be required to record their time worked. Hourly employees are responsible for tracking their time by logging into the electronic time clock at the start and finish of each workday. Hourly employees must also log in and out for their lunch break. Please ensure you are following the timekeeping policy correctly and in a timely manner. Failure to comply may lead to disciplinary action. Mistakes made by the employee in reporting their hours worked will be corrected on the next payroll. Errors made by the company will be corrected as soon as possible. Altering, falsifying, tampering with time records, recording time on another employee’s time card or not following this policy may result in disciplinary action, up to and including termination.

Compensation Program To attract and retain employees, the company endeavors to pay salaries competitive with those paid by other practices in the market. Your salary will normally be reviewed annually on your anniversary date. Your total compensation consists not only of your salary but also of the bonus opportunities and various benefits you are offered such as health insurance and dental benefits. The company reserves the right to evaluate your compensation at any time. An evaluation does not guarantee an increase however your compensation is directly influenced by your performance. Questions regarding your compensation should be directed to your Management Team. Please keep in mind that everyone’s compensation is held in the strictest of confidence. Discussing your salary with other team members may result in progressive disciplinary action up to and including termination.

Overtime Overtime compensation is paid to all nonexempt employees in accordance with federal and state wage and hour restrictions. Sometimes overtime is necessary to meet our patients’ care. Every effort will be made to keep your schedule consistent; however, if circumstances indicate overtime is necessary, the employee must be able to work the


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overtime. You will be paid one and one-half your regular rate of pay for all hours worked in excess of 40 hours in a given workweek. Paid vacation and holidays will not count as working hours in relation to your eligibility for overtime pay.

Employee Evaluations & Wage Increases We have a competitive wage and salary program that offers you financial incentives to meet and exceed the performance standards established for your position. It is the policy of the company to provide employees with regular evaluations. The evaluation is a formal opportunity for the supervisor and the employee to discuss job performance and career objectives. Performance reviews are based on the responsibilities detailed in the job descriptions, as well as adherence to the policies and procedures of this practice. Employee evaluations are the basis for such important personnel decisions as merit raises, promotions/demotions and termination of employment. Every new employee receives a formal performance review after ninety (90) days of employment. Every employee receives a formal performance review at least once a year. All evaluations will be in writing. Every employee will have the opportunity to evaluate his/her own performance review and to share their perceptions with the dentist/supervisor. Wage increases are based upon merit. We determine raises by the performance level of the employee as documented through the performance evaluation process. An employee whose performance is rated as meeting or exceeding job standards will be eligible to receive a merit increase. The amount of money available for merit raises varies from year to year due to business conditions. Never discuss salary or wage issues with another employee. If caught doing so, it may be grounds for termination. Salary information must always be handled with the utmost discretion and confidentiality.

Personal Telephone Calls/Cell Phones The telephone lines should be used for business use only. The front office staff is very busy seeing to the needs of our patients and should not have to take the time to take a message for you or see if you’re available to come to the phone. Not including emergency situations, please inform your family and friends that you are not to receive phone calls at work. In the event you need to make a phone call you may do so on your break or during lunch. Cell phones are to be turned off (not silenced or on vibrate) during working hours and are not to be carried on your person.


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Rest Periods/Break Room Every effort is made to have lunch breaks at regular times. However, due to the uncertainty of patient care, the scheduling for lunch breaks may vary at the discretion of your Management Team. Lunch breaks will also require flexibility of the employee (i.e. rotating, etc.). For each 8 (eight) hour day worked each employee receives a 30-minute unpaid lunch break. In addition to your lunch break you are entitled to take 2 (two) paid 10-minute breaks. In order to provide excellent patient care and keep our practices in smooth working order, rest or lunch breaks will not be scheduled. Your office manager or lead will allow these types of breaks when deemed necessary. Keep in mind that each office has its own schedule and will be handled individually. Remember you must clock out for your lunch break and anytime you leave the office for personal issues. You should also check with your management team before leaving the office during work time. The consequences for not clocking out for breaks may include disciplinary action. The break room is for you to relax in and enjoy. However, it is each of our responsibilities to keep it clean. You are to clean your own dishes and wipe down the counter after using. In those offices where available, employees may utilize a secure locker. A $5.00 key deposit is required and will be refunded upon return of the key. The company is not responsible for lost/missing items or belongings. Important information regarding company policies, federal employment laws, employee meetings, and other matters of interest will be posted in the break room. Please take the time periodically to look and review any information as it is posted.

Request for Time Off Employees who wish to request time off (with or without pay) should complete a Time-Off Request Form. The request should be made with as much notice before the absence (30 days would be ideal.) The form should be filled out for all absences including vacation, sick days, doctor appointments, medical leave, personal leave, jury duty, or military duty. In the event of an unforeseen absence a member of the management team may complete the request for an employee. And in some cases, the exact return-to-work date may be unknown. In that event, the form should be submitted with an estimated return-to-work date and updated when the information is available. Time-Off Request Forms must be approved by the management team


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(including your Office Manager and your Regional Manager) before the absence is deemed “Approved”. Request for Time off forms are available at each office. Please check with that office’s manager or key individual to obtain a copy.

Attendance and Punctuality Since each of you is a vital part of the success of this practice, it is very important for you to be at work and on time for work when you are scheduled. Frequent or unexplained absences or tardiness can be an inconvenience to your fellow workers and to our patients. Any non-emergency appointments should be made before/after hours or made on your day(s) off. Any request for time off must be requested in writing. Any deviation from your scheduled hours must be approved by the office manager. This includes calling in sick, leaving early, request for days off, etc. You must call every day you are absent stating the nature of your absence and your anticipated return. If you need to call in sick or will be late for your shift you must call the office and speak to the office manager or your regional manager, leaving a message or speaking to another team member is not acceptable. Asking your spouse or anyone else to call for you is also unacceptable. If you do not call within the first four hours of any scheduled shift, you will be considered a no call/no show and will be deemed to have voluntary resigned. If you are absent for two or more consecutive days due to an illness, the company reserves the right to request a Doctor’s release for you to return to work. The company may also verify any note provided. It is important to remember that any absence longer than three days not classified as a vacation is considered a leave of absence. Your coworkers suffer, the patients suffer and your paycheck suffers when you are not at work. Excessive absenteeism/tardiness especially within your first 90 days of employment will be cause for disciplinary action up to and including separation from the company. Also, our evaluation of your performance will always take into account your attendance record. Tardiness is defined as not arriving to work at the scheduled arrival time and/or not being ready to work at the scheduled starting time. All team members and Doctors should be at the office 15 minutes and no earlier than 20 minutes prior to the office starting time to be ready for the Morning Huddle unless otherwise designated by the management team to come earlier. For example, if your office starts seeing patients at 9 am, you are expected to be ready for morning huddle at 8:45 am.


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Jury Duty It is our policy to enable you to fulfill your civic obligation to serve jury duty. Immediately upon receipt of an official jury notice, it is your responsibility to notify the office manager so that schedule adjustments if necessary can be made. Proof of a jury summons must be provided. Time away from work to serve jury duty is unpaid.

Bereavement Time If you wish to take time off due to the death of a family member, you should notify your management team immediately. There is no compensation for this type of leave of absence unless you elect to utilize your paid vacation. You will be excused from work for up to 5 days for an immediate family member that includes your spouse, mother, father, children or stepchildren. In the event of the death of your siblings, in-laws or grandparents you will be excused for up to 2 days. If you feel you need to have additional time off beyond what is outlined above, please discuss this with your management team. We understand this is a very difficult time so please keep your management team informed as to when you will return to work.

Military Duty Leaves of absence without pay for military are granted to employees. If you are called to active military duty or to Reserve or National Guard training, or if you volunteer for the same, you should notify your Management Team and submit copies of your military orders immediately. You will be granted military leave of absence without pay for the period of military service, in accordance with applicable federal and state laws. Every reasonable effort will be made to return eligible employees to their previous position or a comparable one. All benefits that operate on an accrual basis (vacation, holidays, etc.) will cease to accrue during any period of military leave that exceeds 30 days. During your leave, if you wish to continue your health insurance, you must continue payment of your employee premium.

Personal Leave of Absence If an employee needs to be away from work for compelling personal reasons, he/she may apply for a personal leave of absence. However, personal leave will be granted only under extremely unusual circumstances to attend to urgent matters that cannot be reasonably taken care of without absence from work. Such leaves are given without pay and must be approved in advance by the HR department. Other benefits such as vacation must be used prior to requesting a leave.


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An employee may request a personal leave after he/she has completed 90 calendar days of service. A completed “Leave Request Form” must be presented to HR with as much notice as possible. Each request for a personal leave will be treated on its own merit, but in no case will it be less than 3 days or in excess of 90 calendar days. Requests for personal leave will be evaluated based on a number of factors, including anticipated staffing considerations during the proposed period of absence. Benefits accruals will be suspended during the leave and will resume upon return to active employment. When a personal leave ends, every reasonable effort will be made to return the employee to the same position, if it is available, or to a similar available position for which the employee is qualified. However, the company cannot guarantee reinstatement in all cases. If an employee fails to report to work promptly at the expiration of the approved leave period, the company will assume the employee has resigned without notice. No personal Leave of Absence can last longer than 90 calendar days.

Family & Medical Leave Act Team members may apply for FMLA by completing a Leave Request Form. This form may be obtained from your Management Team or the HR department. The employee is required to provide 30 days notice for foreseeable events that require FMLA or with as much notice as possible for unforeseeable events so that the HR department can determine your eligibility as soon as possible. FMLA generally requires covered employers to provide eligible employees with up to 12 weeks of unpaid leave of any 12-month period:

For the birth of a son or daughter, and to care for the newborn child. For placement of a son or daughter for adoption or foster care. To care for eh employee’s spouse, child, or parent with a serious health

condition; or

To take medical leave when the employee is unable to work because of a serious health condition.

An employee must have completed at least one full year of service and have worked a minimum of 1,250 hours in the 12-month period preceding the leave to be eligible. In addition, to be eligible for leave an employee must work at a facility that employs at least 50 employees at that facility or within 75 miles of that facility. During this period of time the employee’s job and accrued benefits must be protected, and health benefits must be continued under the same terms as prior to the leave. This means the employee is responsible for keeping up with their dependent premium for health benefits. Team members must also utilize all paid vacation they are eligible for


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during this leave of absence. Benefits accruals will be suspended during the leave and will resume upon return to active employment.

Meetings/Training Each employee shall report to work 15 minutes prior to the scheduled start of the day for a “morning huddle”. During this time we will discuss the day’s schedule and any other pertinent information. All employees are required to attend the morning huddle. In addition, one day per week each office will conduct a team meeting. The day and time of this meeting will vary by location. The team meeting will be no longer than one hour. Attendance to the team meetings are required by all full time employees. Periodically the company shall provide opportunities of training and staff development. These trainings may occur during regular business hours in which the offices will close and/or they may be offered on a Saturday. All training is mandatory for all full time employees. Unless prearranged failure to attend a training session is considered a self termination and is subject to disciplinary action up to and including termination. All meetings/trainings will be scheduled and announced with sufficient notice to ensure attendance by all.

Insurance The company provides health insurance to full time employees after six (6) months of service. Coverage begins on the 1st of the following month and consists of medical and prescription coverage. The company pays 100% of the premium. Dependents may be covered at the employee’s expense. The federal Consolidated Omnibus Budget Reconciliation Act (COBRA) gives employees and their qualified beneficiaries the opportunity to continue health insurance coverage under the company’s health plan when a “qualifying event” would normally result in the loss of eligibility. Some common qualifying events are resignation, termination of employment, death of employee, reduction in an employee’s hours or a leave of absence, an employee’s divorce or legal separation, and a dependent child no longer meeting eligibility requirements. Under COBRA, the employee or beneficiary pays the full cost of coverage at the company’s group rates plus an administration fee. The company provides each eligible employee with a written notice describing rights granted under COBRA when the employee becomes eligible for coverage under the


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company’s health insurance plan. The notice contains important information about the employee’s rights and obligations.

Dental Benefits All full and part-time employees are eligible for dental benefits following 6 (six) months of employment. When services are rendered by an owner doctor the benefit covers 100% of general services excluding any lab fees. When general services are rendered by an associate doctor the employee is responsible for same lab fees and doctors salary. When an employee has dental coverage the company reserves the right to bill insurance for any and all services rendered. Any payment received from insurance will be applied towards employee’s responsibility when applicable. No treatment should be rendered without the written approval of the regional manager. If an employee voluntarily leaves employment voluntarily or is terminated due to his/her own fault within one year of having services rendered then the employee becomes responsible for the total cost of their treatment or their co-insurance/deductible (if they have insurance). Some dental benefits such as specialty (ortho) or cosmetic services (whitening) will be available at a discounted price. This will be handled on a case by case basis and must be pre-approved by the management team. For orthodontic services employees must remain employed throughout the length of the treatment to receive the discounted rate. If an employee voluntarily leaves employment during active orthodontic treatment then the employee would be responsible for the original cost estimate. Financial arrangements can be made. When services are performed on an hourly employee the employee will clock out. Salaried employees will receive services during their off days.

The above benefits apply to the employee and his/her immediate family members to include spouse and minor children. There is a 20% discount off of the UCR fee for extended family members (i.e., parents, brother, sister, grandparents, etc).

Holidays We observe the following paid holidays: New Year’s Day, Memorial Day, Fourth of July, Labor Day, Thanksgiving Day and Christmas Day. All full time employees are eligible to receive holiday pay after one year of continuous employment by the date of the holiday. Employees must also work their scheduled


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shift before and after the holiday to receive holiday pay. Only pre-approved absences such as vacation will be exemptions of this guideline. Full-time employees are eligible for all of these paid holidays at eight hours each when the holiday falls on Monday through Saturday.

Profitability Bonus When determining eligibility a committee consisting of the Owner Doctor(s), Business Manager and Regional Manager will determine an employee’s eligibility. BASIC GUIDELINE

All full and part time employees are eligible for quarterly bonuses once they have been employed for six months. A full time employee is someone who works more than 32 hours per week.

Part time employees will receive ½ of the full time employee’s amount. A part time employee is someone who worked 8 – 31 hours per week for every week during the quarter.

An employee must be eligible the entire quarter to be eligible for the quarterly bonus.

An employee’s six month anniversary date from date of hire has to fall before the 15th of the 1st month of the quarter to be considered eligible for the quarter. Example 1

So if you were hired on 4/17/10, your 6 month anniversary would be 10/17/10, but because this is after the 15th of the month, you’re not eligible for the entire 4th quarter due to the all or nothing rule. Example 2 If you were hired on 4/14/10 you would be eligible in the 4th quarter of 2010. Example 3 If you were hired on 2/17/10, your 6 month anniversary would be 8/17/10, and because it falls on the 2nd month of the quarter, you’re not eligible for the entire 3rd quarter 2010.

EXTENDED LEAVES OF ABSENCES If you have an extended leave of absence for more than 6 days cumulatively within the quarter, your hire date will be adjusted by the number of days absent for the purpose of calculating your eligible date for profit sharing. Any previously eligible employees will NOT be eligible for the quarter if total leaves of absence exceed 6 days cumulatively during the quarter. Approved vacation requests will not disqualify the employee’s eligibility for profit sharing. TRAINING An employee must have attended all Heartland sponsored and our internal training classes and team meetings held within the quarter in order to be eligible for that quarter. In addition they must pass any tests that are taken. DISCIPLINARY ACTION


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Any disciplinary actions at any office, not including verbal warnings, will disqualify an employee for the NEXT bonus for all offices regardless if it’s from the previous quarter or the current quarter. TERMINATION/RESIGNATION Any terminated/resigned employee regardless of reason will NOT be eligible to receive any prior unpaid bonus. If an employee resigns and provides a minimum of a two week notice he/she will still be eligible for any bonus for any previous full quarter worked and in which they are otherwise eligible. However if an employee resigns in mid-quarter, they would not be eligible for that quarter. [example: If Joe resigns on 4/30/10 with a 2 week notice, he will be eligible to receive the 1st quarter bonus but not for the 2nd quarter bonus because he’s not worked the full 2nd quarter.] BONUS PAY DAY Pay date of bonuses will be the second pay period of the second month following the end of the quarter. [example: the first quarter bonus would be paid the second pay check in May.] BONUS CALCULATION Bonuses are determined by the net profit (collection minus expenses) of an office. The net profit is calculated by the three month cumulative average (profit/loss) after loan payments or other threshold figures. The threshold is the minimum profit that must be obtained before the team shares in any profits. The team will then split 10% of all net profits. The total amount of eligible employees is based on the number of full/part-time staff more than half of the time. The management reserves the right to make exceptions to accommodate special circumstances. PERCENTAGE SHARE AMONG TEAM The team breakdown is as follows: Regional Manager 2% Office Manager 3% Back Office Manager 1% DA’s/BA’s 4% (Paid out to eligible to team members only)

Net Income from Operations for the quarter is calculated

Minus Quarterly Threshold

Equals Amount Over the Threshold


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Times 10%

Equals Amount to be shared among all team members in the following manner: Regional Manager 2%

Office Manager 3% Back Office Manager 1%

DA’s/BA’s 4% (Paid out to eligible team members only)

Example for an office with 8 team members (3 BA’s, 3 DA’s, 1 Manager, and 1 Lead Asst):

Net Profit for the quarter

$100,000

Minus Quarterly Threshold $24,500

Equals Amount Over the Threshold

$75,500

Times 10%

Equals $7550 (Amount distributed to team) Divided in the following manner:

Amount for Regional Manager: $1510 Amount for Office Manager: $2265

Amount for Lead Assistant: $755

Amount for the rest of the 6 team members: $503/each

Termination When foreseen, it is requested that all employees give a two-week (10 working days) notice before terminating their employment and should continue service through that date. Any and all benefits will be forfeited upon termination.

Wage Attachments The attachment of an employee’s wage by a creditor/court is a serious matter. Management MUST honor wage attachments ordered by courts of law, the IRS and the State of Nevada. The administrative cost to handle and process wage attachments (also known as garnishments) is very high. You should make every effort possible to eliminate such wage claims against your salary.

Uniforms We want to present a professional atmosphere not a trendy look. Therefore the following guidelines shall be adhered to regarding what’s acceptable attire. Female Business Assistants/Female Managers


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Professional style business attire (dress slacks, skirts, dresses, blouses or sweaters) that are black and/or white in color. Dress shoes or business appropriate sandals are acceptable foot wear. Friday is a “free” day. Although business attire is still required they need not be black and/or white in color. Male Business Assistants/Male Managers Professional style business attire (dress slacks and shirt and dress shoes) black and white in color. Friday is a “free” day. Although business attire is still required they need not be black and/or white in color. Dental Assistants and Hygienists Black bottoms, black or white shirt, white or black closed toe shoes and a company provided lab coat. Doctors Professional style business attire. Some doctors may prefer to wear scrubs; while this is permitted, it is not encouraged. Shorts, Jeans, T-shirts, sweatshirts, sweatsuits, sweatpants and casual shorts/pants, are not business attire and therefore are not acceptable for any employee to wear When wearing light clothing, please remember to wear light colored undergarments. The appropriateness of all clothing remains at the discretion of the company and employees may be sent home without pay to change. Lab coats should be worn at all times by the clinical department. The company will provide the coats and cover the cost of maintaining and cleaning them. Lab coats are only to be worn in the office per OSHA regulations. The company will also provide gloves, masks, eye protection, and utility gloves to be worn as personal protective equipment as required by OSHA. All employees will be issued a headset. Headsets are to be worn, plugged in and turned on during working hours. If you travel from office to office you are to bring your headset with you. Not wearing your headset could be grounds for disciplinary action. If your headset is not functioning properly please notify the office manager immediately for a replacement headset.

“If you want to be part of the team, you have to wear the uniform!”


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Standards of Dress/Appearance As an employee you represent this company. Your appearance, behavior and attitude are reflections of this organization. For that reason we have adopted a standard of dress and grooming that will create a favorable image of the company. Our appearance guidelines were designed to maintain a consistent image. They rely on common sense and personal commitment. Management will resolve differences of opinion concerning acceptable appearance. The grooming and appearance standards are:

1. Your hair must be neat, clean, simply arranged and in a natural style and color. Extreme or unusual hairstyles are not permitted. For women, hair accessories should be kept to a minimum and should be suitable for our business environment. For men, beards, mustaches, and sideburns must be well groomed and neatly trimmed. When chair side your hair must be pulled back and out of the way.

2. Fingernails should be neatly trimmed and clean at all times. For the clinical team members, the acceptable nail length starting from your true cuticle to the tip of the nail should be no more than .6 inches. For the business team members, the acceptable nail length starting from your true cuticle to the tip of the nail should be no more than .75 inches. Avoid extreme and unusual colors of nail polish.

3. Cosmetics should correspond with and compliment your individual skin color. Extreme colors should be avoided.

4. Jewelry may be worn in moderation so long as it is not extreme and does not interfere or affect your job duties.

5. Uniforms including lab coats are to be worn by all personnel. 6. All clothing must be neat, clean and well pressed at all times. 7. Uniforms must fit properly. Pants/shirts are not to be oversized as to give

a sloppy appearance. 8. Facial jewelry (with the exception of earrings and clear plastic retainers)

must not be visible on any exposed part of the body during business/training hours and/or while on company property. Earrings must be worn in moderation.

9. Team members must not have permanent marks or figures (tattoos) visible on any exposed part of the body during business/training hours and/or while on company property.

General Rules of Conduct Our success is largely based upon our ability to work together as a team with respect for the rights and interests of others. There are types of personal conduct that undermine our success in this regard. It is impossible to list all such behaviors;


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however, the following list is a representative sample of behavior that may result in disciplinary action up to and including termination.

1. Any form of insubordination. 2. Unauthorized use or removal of, or failure to report unauthorized removal

of company, employee, or patient property. 3. Drinking, having the odor of liquor on your breath, possessing or being

under the influence of alcohol while on duty. 4. Unauthorized possession or use of a controlled substance, or being under

the influence of these substances while on duty. Selling or transferring of any illegal drugs, prescribed drugs, or non-prescribed controlled substances during working hours or on company premises.

5. Willful destruction or misuse of property belonging to the company, another employee or patient.

6. Knowingly making false statements or omissions of pertinent facts on personnel or other company records verbally or written or giving false testimony in accident/incident reports.

7. Unauthorized discussion or dissemination of confidential information (i.e., patient information.)

8. Deliberately altering your own or another employee’s time records. 9. Failure to communicate with patients in a helpful and courteous manner. 10. Failure to observe established safety rules or to report an accident. 11. Unauthorized use of company equipment/supplies or facilities. 12. Theft or dishonesty. 13. Failure to use company issued safety equipment. 14. Making any type of negative comment about another employee to another

employee, except for discussing a problem with a member of the management team.

15. Smoking in the office. 16. Refusal or failure to carry out reasonable orders and instructions or

assigned work. 17. Horseplay, wrestling, or dangerous practical joking. 18. Creating or contributing to unsanitary, hazardous, or poor working

conditions 19. Wasting time, loafing, loitering, or sleeping on the job. 20. Failure to report a mistake or accidental damage. 21. Engaging in any activity prohibited by law. 22. Failure to have or maintain an attitude conductive to a productive work

environment. 23. Installing, using, or failure to report the installation or use, of any

unauthorized computer software. 24. Willful neglect, disregard, or violation of any company policy, procedure,

or regulation established by the company including OSHA and HIPAA regulations.


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25. The use of profanity. 26. Possession of a firearm on company property. 27. Leaving the office during working hours without authorization. 28. Participating in office gossip.

Computer Usage & Email Computers, computer files, e-mail, internet access and software furnished to employees are property of the company, whether accessing resources from home or at our work site, and are intended for business use only. You should not use a password, access a file or retrieve any stored communication without authorization. The company strives to maintain a workplace free of harassment and sensitive to the diversity of its employees. Therefore, the use of computers, access to the Internet and the e-mail system in ways that are disruptive, offensive, or harmful to morale is strictly prohibited. For example, the display or transmission of sexually explicit images, jokes, or anything that may be construed as harassment or showing disrespect for others is not allowed. E-mail may not be used to solicit others for commercial ventures, religious or political causes, outside organizations or other non-business matters. Incidental and occasional personal use of electronic communications and Internet access records will be treated like any other company record. All electronic communications and Internet access records will be treated like any other company record. The company e-mail system and Internet access records are not private and you should have no expectation that they are. The company purchases the license for the use of various computer software programs for business purposes and does not own the copyright to this software or its related documentation. Unless authorized by the software developer, the company does not have the right to reproduce such software for use on more than one computer. You may only use software on local area networks or on multiple machines according to the software license agreement. The company prohibits the illegal duplication of software and its related documentation. All software other than what was initially provided by the company must be approved by the company prior to installation. You should notify a member of the management team immediately upon learning of violations of this policy. Should you violate this policy, you will be subject to corrective action, up to and including dismissal.


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Confidentiality As dental care professionals, we often have access to personal information about our patients. For example, when reviewing a patient’s medical history we may discover HIV status, pregnancy or a recent bout with cancer. We must respect our patient’s right to privacy. Information about patients, their treatment or their personal lives must be kept completely confidential. The guidelines for confidentiality are as follows: 1. Speak softly or privately with patients, so other patients can not overhear. 2. Computer terminals displaying patient information (i.e., appointment book, family file) should not be left open/up in areas where patients might view them. Make sure all computer screens have a screen saver setting. 3. Do not reveal information about a patient to anyone but the patient unless you are speaking to the parents of a patient under the age of 18. 4. The office restricts release of any information about a patient (name, address, age, sex, treatment, etc) to members of the public or press, family members or friends, etc without the patient’s written authorization. 5. Do not discuss the dental treatment or personal information of patients outside of the practice. 6. Never use a patient’s protected health information for personal use or gain. 7. Any subpoena received should be given immediately to the office manager. 8. Original charts and/or x-rays are never to be released.

There are two areas involving telephone calls where discretion must be exercised as well. When calling a patient on the telephone, it is important not to leave messages containing medical or dental information as well as account balances owed on answering machines or with other parties. It is appropriate to leave a message requesting that the patient return your call at the office. The second area involves incoming telephone calls where the caller asks, “Is Mrs. Smith there?” or “Does Mrs. Smith have an appointment today?” In both these instances, the fact that Mrs. Smith is a patient is confidential, and information regarding her should not be given to anyone regardless of whether or not she has an appointment. The company adheres to all other regulations prescribed by HIPAA (Health Insurance Portability & Accountability Act), and all employees are expected to abide by these rules as well. Any violation of HIPAA regulations could be grounds for immediate dismissal.

Office Cleaning It is the responsibility of all employees to remedy and correct any condition that detracts from the professional appearance of their workstations or the office as a whole. Team members should tidy all workstations at the end of the morning and at the end of the day. Special attention should be paid to the reception room and the bathrooms. Employees are responsible at all times for their own personal belongings.


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For those offices with kitchens, please make sure these areas are cleaned and monitored on a regular basis including the refrigerator.

Employee Accidents All injuries, however slight, should be reported to your supervisor or the office manager. As an employee, you are covered for worker’s compensation effective the day you begin working. It is your responsibility to report any on-the-job injury immediately whether you are the injured party or not. Any employee who has had an exposure incident, such as a needle stick, MUST report to the office compliance manager. The practice will arrange for a post exposure evaluation and follow up services at no cost to the employee. It is fraud to file an industrial insurance claim if you are not injured on the job. Filing a false claim will result not only in a loss of benefits, but could mean costly fines and/or jail time.

Health & Safety It is your responsibility to practice every safety rule and habit in order to protect yourself and your fellow coworkers. Your failure to do so will subject you to disciplinary action. BE SAFETY CONSCIOUS; THINK SAFETY FIRST. Proper clothing, shoes, and protective gear are to be worn at all times. Proper procedures should be followed at all times when handling equipment, bottles, and substances as well as when lifting or carrying materials. Carelessness or lack of attention to safety practices could make you dangerous to your fellow coworkers as well as to our patients. You should report all unsafe conditions, which come to your attention to the doctor immediately. Safety is everybody’s responsibility and we all must make every effort to insure an accident-free working environment for all employees and our patients. A Hepatitis B vaccine is available at no cost to all employees with risk of occupational exposure. If you decline to be vaccinated, you must sign a declination form. If you were previously vaccinated, you will be asked to provide proof or sign a document to that fact. This information will be kept in your confidential medical record.

Thank you! Thank you for taking the time to familiarize yourself with this policy. We hope that you have found this information useful. Please remember if you ever have a question, ask!

Welcome and Good Luck in your new career!


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EMERGENCY ACTION PLAN Under OSHA standards, every dental practice must have an Emergency Action Plan and a Fire Protection Plan. Below is a summary of the procedures we use to protect our employees and patients in the event of such an emergency. BUILDING SAFETY

Building exits should remain unobstructed, easily unlocked and clearly marked. The practice has fire/smoke alarms and fire extinguishers mounted throughout the building. Please familiarize yourself with their locations. EVACUATION

If a fire should break out in the building, if small, employees should immediately locate the nearest fire extinguisher and attempt to extinguish. If not, call 911 and evacuate the building. DO NOT try to fight a large fire or stop to retrieve personal belongings. Once employees have evacuated the building, you should gather at the main entrance to the parking lot. The office manager will be responsible for making sure that all employees are accounted for as well as reporting anyone missing to the fire officials. You will be allowed to return to the building as soon as the fire department has given permission to do so. Emergency evacuation for any other reason should follow the same procedure. MEDICAL EMERGENCY

In the event of a serious medical emergency, employees should contact a dentist immediately and someone should call 911. Until trained medical personnel arrive, staff members should do what is necessary to make the person comfortable. Administer CPR or first aid if you are certified. First aid supplies and oxygen are located in the sterilization room. BUILDING SECURITY

Keys are distributed on an as needed basis. They should not be duplicated. Keys must be returned upon termination. Keep purses, wallets and other valuables in the break room or out of sight. The practice is not responsible for lost or stolen property. If you should lose something of value you must report it to the office manager. He/she will determine if the police should be called. Be alert to the unusual. The presence of strangers who appear lost or out of place may be treated with an offer to help. If you prefer not to confront a stranger notify a dentist or office manager immediately so they may investigate and take appropriate actions if necessary.


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PRIVACY POLICIES

The following privacy policies have been adopted and shall be utilized as a basis for our

office/facility in handling, protecting and disclosing Protected Health Information (PHI). Any reference to Boston Dental Group or to the dental practice or office should be defined as

Aliante Dental, Boston Dental, Brighton Dental, Fenway Dental, Happy Dental, Hola Dental, Friendly Dental, Discount Dental and / or Affordable Dental.

1.0 PRIVACY STATEMENT The privacy of patient information is very important to our patients and our office. It is important that

we reasonably protect the patient's health information in a way that helps keep the information within our facility yet allows our business to operate reasonably and efficiently so we may provide high-quality

service to our clients. To that end, we adopt the following policies and will follow the policies to help

ensure that our office does not improperly use and/or disclose protected information.

Protected Health Information means and refers to any individually identifiable health information related to the patient. A patient is a current patient or former patient. Protected Health Information has a broad

meaning and includes the name, as well as other demographic information, about the patient as well as health history and physical information, financial information and any other information related to the

patient when this information can be used to identify the patient.

2.0 STORAGE OF PROTECTED INFORMATION

Our office has implemented a system that stores protected information in a manner that reasonably keeps it away from unauthorized personnel. We will use passwords on our computers and we will use

screen savers that will blank the screen or remove from view protected information when we are not

present at the computer or within a specific period of time. We will keep paper records closed so that protected information is not easily viewable by others in our office. Reports, papers with protected

information and other documents are to be reasonably kept in a fashion that does not easily allow viewing by others.

3.0 SIGN-IN SHEET For the privacy of our patients we either use a privacy protected sign in sheet or no sign in sheet.

4.0 TRAINING OF EMPLOYEES

Each of our employees that have access to Protected Health Information will be trained using our internal training procedures. The employees shall abide by the privacy rules. All new employees shall go through

privacy training. Each employee that will have access to Protected Health Information, as described in 45

CFR 164, shall sign a document indicating completion of training. Each employee shall review these policies. We will train each employee within a reasonable time after the employee starts working in our

office.

DISCIPLINE: We will maintain a policy that, when and if an employee violates these policies or applicable

rules we promulgate in our office to supplement these policies, the employee will be disciplined by receiving notice of the infraction and/or violation. We will then take the action necessary to correct the

problem with the employee, which may include termination of employment. We believe that compliance with Federal Privacy Regulations is important to our office and to our patients and we will take

appropriate disciplinary action when an employee fails to abide by the regulations and these policies.

5.0 COMPLIANCE OFFICER

We shall appoint a privacy officer. The officer will ensure that these policies are followed. We will be using a software based Privacy Manager system and the privacy officer will work to ensure that the

software is used to manage the privacy process. The officer shall also ensure that each employee is


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properly trained, as specified in paragraph 4. This officer, or a separate person, shall act as a complaint

manager as well. Complaints received regarding any privacy violations shall be tracked and handled by the officer.

Our privacy and complaint officer is Connie Trofibio.

6.0 PATIENT EDUCATION

All patients shall review and receive upon request a notice of their rights under HIPAA, except for minor patients. For minor patients that have not been emancipated, a copy of the privacy rights shall be

provided to the parent or legal guardian. The patient shall be notified of their rights under the law as

well as a statement about our privacy practices. The patient shall acknowledge receipt of the notice or we shall record, electronically or otherwise, that such acknowledgement was requested, but the patient

would not sign it. A record shall be kept noting the patient has received the notice of rights and the acknowledgement form.

7.0 DISCLOSURE OF PROTECTED HEALTH INFORMATION

Unless provided for in these policies or by applicable Federal law, we will not disclose Protected Health Information without the authorization of or specific consent of the patient.

We will notify each patient of their Privacy Rights pursuant to our Notice of Privacy Practices and Rights

and attempt to receive acknowledgement of these rights from the patient before we use or disclose his or

her Protected Health Information for Treatment, Payment or Operation purposes as described below. Our policy is to disclose only the minimum necessary information for payment and operation reasons

when such use or disclosure is required. We may rely on the representations of our Business Associates, as described below, when determining what information is required when disclosing for purposes of

payment or operations.

If there are additional state requirements governing how we must protect, use, disclose or notify patients

in regard to their rights, we will provide such information in additional to the information provided for in these policies.

We need not obtain consent from the patient to use or disclose for Treatment, Payment or Operations

(TPO) reasons, as described below. However, we will ensure that the patient has received a Notice of

Privacy Practices and Rights as well the opportunity to acknowledge receipt of the Notice.

In the event we need to receive consent from a patient for use or disclosure not provided for pursuant to these policies, we will do so by providing the patient with our consent form. We will not disclose

information that is not allowed to be disclosed under these policies or applicable state or federal law

without the patient's consent.

We may also seek authorization from a patient that provides us with the ability to use and disclose information without specific consent for each disclosure. An authorization must be in writing and must

set forth-specific circumstances for which we may use or disclose Protected Health Information.

A patient may revoke their consent in writing. When we have received notice of the revocation, we will

no longer disclose following receipt of the revocation. The patient properly authorized anything disclosed prior to the revocation.

ORAL AGREEMENT: In certain circumstances, we may not be able to obtain consent or authorization

from the patient as described above. In these rare circumstances, we may rely on the patient's oral

agreement for disclosure of Protected Health Information. Sometimes, in emergency circumstances, a


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patient may not be able to give consent or is unavailable to provide consent. In these circumstances, we

will use our best professional judgment before acting on behalf of the patient. If the patient requests to see their PHI, we may provide that information to them. We may disclose, to a patient's personal

representative, PHI that is relevant to the representative in their capacity as representative.

We may need to determine the identity of a patient to verify the patient may give consent or

authorization. In these rare circumstances, we may obtain appropriate identification before allowing consent or authorization for disclosure.

IN OUR OFFICE WHEN OTHERS ARE PRESENT: If others are present in our office, such as when services

are being performed and others may be able to hear information about treatment, we will obtain oral consent from the patient and offer the patient a private area for discussion prior to discussing Protected

Health Information related to treatment options, condition or diagnosis. We will notify the patient that

we may be discussing these areas of information and specifically ask if the patient would like a private area to discuss the information, when practical.

MARKETING AND FUNDRAISING: We will not disclose information for fundraising purposes with the

patient's authorization or consent. We will only provide marketing communications when we believe the

communication is provided for purposes of the patient's treatment.

TREATMENT, PAYMENT and OPERATION DISCLOSURES: We may, without consent of the patient, disclose Protected Health Information for activities related to treatment, payment or healthcare

operations. Treatment disclosures shall mean and refer to disclosures for treatment purposes, including coordinating and managing care of the patient, to another healthcare provider. Payment disclosures shall

mean and refer to disclosures for payment purposes such as billing service organizations, health plans

and other organizations that may provide services or products that relate to payment for services and products provided by our office. Operation disclosures shall mean and refer to disclosures that relate to

the management and direct operations of our business so it may provide care to patients. These services may include, but are not limited to, training programs, computer services, attorneys and accountants.

For TREATMENT disclosures to another entity covered by the Federal privacy regulations (45 CFR 160 and 164), our office may make disclosures without an agreement with the other covered entity treatment

provider. This is because the other provider is already covered by these regulations. With respect to treatment disclosures, our office is not subject to the minimum necessary rule. In some circumstances,

we may obtain a Business Associate agreement with other treatment providers ensuring that the provider

will comply with these policies and the Federal privacy regulations.

For PAYMENT disclosures, our office will disclose only the minimum necessary information for the payment associate entity to do its job for us. We will ensure that a Business Associate agreement, as

defined below, is obtained prior to making any PAYMENT disclosure, when such an agreement is required under the law or pursuant to these policies.

For OPERATIONS disclosures, our office will disclose only the minimum necessary information to the other entity in order for the entity to do its job. We will ensure that a Business Associate agreement, as

defined below, is obtained prior to making any OPERATION disclosure.

OTHER DISCLOSURES WE MAY MAKE: We may make disclosures, without consent or authorization, in

certain circumstances. These circumstances include those defined above as well as: 1) for public health purposes; 2) to avoid a potential serious public health crisis; 3) to employers regarding work-related

illness or injury; 4) to federal officials for lawful intelligence or counterintelligence activities; 5) to correctional institutions regarding inmates; 6) in response to subpoenas or other valid legal process; 7) to

law enforcement officials, subject to the privacy rules governing such disclosures; 8) to report abuse, neglect or domestic violence; 9) for worker's compensation purposes; 10) as part of authorized research


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projects; or 11) as otherwise required by law. In making any of the aforementioned disclosures, all

requirements set forth in the Federal privacy laws will be met prior to disclosure.

REGULATORY AND AUDIT DISCLOSURES: We may be required to provide information to authorized enforcement and regulatory agencies from time to time. Such information will be provided subject to the

law and pursuant to the requests of the authorized agency. We may disclose information for audit

purposes and for complaint management, upon request, to the United States Department of Health and Human Services.

MINIMUM NECESSARY INFORMATION ONLY: We will make reasonable efforts to disclose only the

minimum necessary information to the receiving party pursuant to applicable state and federal requirements. We are not required to apply the minimum necessary rule to disclosures made for

Treatment, as described above, for disclosures to the patient, disclosures to the Department of Health

and Human Services for compliance reviews or complaint investigations, disclosures required by law or use or disclosures required to comply with the federal Health Insurance Portability and Accountability Act

provisions. Within our office, we will also follow the minimum necessary rule in our use of a patient's Protected Health Information.

BUSINESS ASSOCIATES: In the event our office utilizes the services of Business Associates that will use

or that we will disclose Protected Health Information too, we will obtain satisfactory assurances, in the form of written contracts, from those Associates with respect to their use and/or disclosure of Protected

Health Information. We will prepare Business Associate agreements and track the agreements. Prior to releasing Protected Health Information to a Business Associate, other than to another Healthcare Provider

that is a covered-entity under the HIPAA Privacy Regulations, we will obtain the appropriate assurances through the Business Associate agreement. We may not be able to obtain Business Associate

agreements in very rare circumstances, such as emergency situations, prior to disclosing Protected Health

Information. However, we will obtain the assurances as soon as reasonably possible in such situations.

If our office learns that a Business Associate is not following its obligations pursuant to our agreement with them, we will take prompt, reasonable action to ensure the breach is stopped. We may even

terminate our agreement in certain circumstances and take appropriate action by reporting the Business

Associate's actions to the United States Department of Health and Human Services.

8.0 NOTICE OF PRIVACY PRACTICES AND RIGHTS Our office will provide a Notice of Privacy Practices and Rights to each patient we provide services to

prior to providing the service to the patient. If we are disclosing information about a patient after April

14, 2003 and we have not yet provided a notice to that patient, we will do so prior to the disclosure of Protected Health Information. We will provide the notice in writing to the patient. We will allow the

patient to request copies of the notice as well. We will provide each patient with an Acknowledgement of Receipt of the Notice that they will be asked to sign. If they refuse or cannot sign the acknowledgement,

we will note such status in the Privacy Management system we utilize or keep a copy of the refusal or notes regarding inability to acknowledge in our files.

9.0 PATIENT ACCESS TO INFORMATION ACCESS: Pursuant to the Privacy Regulations, our office will provide patients access to their Protected

Health Information for review and copying. We will charge reasonable fees for time and photocopying of records. We may also provide the information in other forms, as long as reasonable and practical, upon

the patient's request. Reasonable fees for preparation of the information will be charged to the patient.

We may also be asked to provide access to Protected Health Information held by our Business Associates. In such case, we will, in a reasonable period, obtain this information and make it available to the patient

for review in our office or we will provide copies of the information. In all cases, reasonable fees for preparation and photocopying may be charged to the patient. In some cases, we may not allow access

to information. We will only restrict or withhold access when required or allowed by Federal law.


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AMENDMENT: Pursuant to the Privacy Regulations, patients may request that we amend their records.

We will make a decision regarding the amendment based on the documentation provided by the patient. Amendment does not require us to delete information from the record. We may allow the patient to add

information to the record or, if we believe it is appropriate, we may change the record based on the request of the patient. If we did not create the information (unless the entity that did is not available to

allow the amendment), we believe the information is accurate and complete or if we do not have the

information, we may deny the patient's request to amend.

We will follow the Federal Privacy regulations when determining if it is appropriate to allow or deny a patient's amendment request. As noted above, we will not physically delete or alter information already

contained in the patient's record. We will, however, allow information to be added, when appropriate under the rules and within our professional judgment, as noted above. In the event we agree to make

an amendment, we will notify our Business Associates that may have the patient's PHI, of the

amendment, so they may adjust their records as well. If we sent out information that was erroneous or incorrect in regard to the PHI, we will reasonably notify any entity that may have received the erroneous

information. In the event we deny a patient's request for amendment, in any future disclosure of PHI, we will note in the record that we denied a request for amendment.

DISCLOSURE ACCOUNTING: We will provide accountings of disclosures as required by law. Under the law, we are required to keep track of certain disclosures we make of a patient's PHI. The rules do not

require us to track disclosures for purposes of Treatment, Payment or Operations, as described above. We do not need to track disclosures related to national security, to correctional institutions regarding

inmates or when provided for in an Authorization by the patient or his/her personal representative. We may suspend accounting if required to do so or allowed for under the Privacy Rules or authorized

regulatory agency. We will use the software based tracking system to account for the disclosures that

we make. We may charge for an accounting that is more frequent than every twelve (12) months. The patient will be notified of the fees for such an accounting. We are also required to provide an accounting

of disclosures made by our Business Associates. Upon request by the Patient, we will notify our Business Associates of the requirement that they provide an accounting of any permissible disclosures they have

made.

REQUEST TO RESTRICT DISCLOSURE: Patients may request that we restrict disclosures that we make of

their Protected Health Information. We have no obligation to comply with these requests, but if we do, we will comply with the restriction. Any request must be made in writing. If we do agree to the request,

we may still disclose the information if it is required in an emergency situation. If we agree to a

restriction, we will promptly notify any affected Business Associate. We may terminate the restriction by giving written notice to the patient of our decision to do so. We will use the software based management

system to track any restrictions.

ALTERNATIVE COMMUNICATIONS: Patients have the right to ask us to use alternative ways or locations when communicating PHI to them. Our office will accommodate such requests when made in writing and

when such request is reasonable. Our office will notify the patient of our decision to accommodate any

of this type of request. We will notify the patient of what will be required in order for us to meet their request. In some cases, there may be a fee associated with meeting a patient in an alternate location.

The fee will be reasonable and we will only accommodate when such request and location are reasonable.

10.0 DOCUMENTATION OF PRIVACY ACTIVITIES We will utilize our software based Privacy Manager to document our privacy practices and actions. Our

internal policy to use the Privacy Manager to track information and to assist in our management of privacy related activities. It shall be the duty of the designated Privacy Officer to ensure employees are

following these policies and using the Privacy Management software to track our privacy related activities.


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11.0 INITIAL PRIVACY ASSESSMENT

We will do an initial privacy assessment using our Privacy Management Software and will take steps to ensure that our office meets the Federal regulations, including those that may not be included in the

Privacy Manager, in becoming Privacy compliant. We will conduct this assessment in a reasonable period of time to ensure we are compliant in accordance with the Privacy regulations.

In the event our state has laws that are more stringent than the Federal regulations, we will incorporate policies that supplement these policies to ensure we meet state requirements as well.

12.0 COMPLAINT MANAGER

We will manage complaints made by patients with respect to Privacy. Complaints will be directed to the privacy officer who shall attempt to resolve the complaint after determining the type, validity and

circumstances contained in the complaint. In the event the complaint is made to DHHS, the designated

complaint manager (privacy officer) shall work with the Department to resolve the issues. Should the resolution require modification of these policies or changes in operation and/or personnel, appropriate

action will be taken. A patient that requests the address of DHHS shall be immediately provided with that information. This office shall not retaliate against any patient or person making a complaint pursuant to

the Privacy or any other governing regulations.


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Handbook Acknowledgement Form

(File Copy) Date: _________________________

Issued To: __________________________________________ (Please print your name here)

This Employee Handbook describes important information about Boston Dental Group. I hereby acknowledge receipt of the Employee Handbook, and I understand I should consult the management team or Human Resources regarding any question I may have. Furthermore, I understand it is my responsibility to read and comply with the policies set forth within seventy-two (72) hours of the receipt and any revisions made to it.

Employee Signature

Documents

BDG Employee Handbook