NJ Medicinal Marijuana ProgramNJ Department of Health and Senior ServicesPO Box 360Trenton, NJ 08625-0360

Re: Notice of Request for Applications to Establish and Operate a MedicinalMarijuana Alternative Treatment Center

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NJ HEALTHY CHOICE, INC. APPLICATION MATERIALS

Criterion 1: Submission of Required Information Regarding Applicant & Facility

Measure 1: The applicant shall provide the proposed legal name and the following documents applicable to the applicant’s legal status. Supporting documents should be included as Appendix A.

Certificate and Articles of Incorporation - ATTACHED By-Laws for corporations - ATTACHED Organizing documents for associations – N/A Evidence of nonprofit status – ATTACHED Certificate of good standing issued by the New Jersey Secretary of State - ATTACHED

Measure 2: The applicant shall provide the proposed physical address(es) of the ATC, if a precise address has been determined. Supporting documents should be included as Appendix B.

For each proposed physical address, the applicant shall provide legally binding evidence of site control (e.g., deed, lease, option, etc.) sufficient to enable the applicant to have use and possession of the subject property including, but not limited to, length of term of use and possession.

Proposed Physical Address and Mailing Address : 29 E. 29th Street, Bayonne, NJ 07002

Evidence of Site Control : Should NJ Healthy Choice, Inc. be chosen as an alternative treatment center, Bayonne Medical Center, which is the sister company of NJ Healthy Choice, Inc., will provide an appropriate lease agreement at current fair market value in order for NJ Healthy Choice, Inc. to confidently satisfy all of its property and space requirements under the alternative treatment center arrangement.

If the applicant intends to cultivate medicinal marijuana at one physical address and dispense it at another, both facilities shall be located within the same region as defined in N.J.A.C. 8:64-1.2. – N/A

If a precise address has not been determined, the applicant shall identify the general location(s) where the facilities would be sited, and when. - N/A

Measure 3: The applicant shall provide evidence of compliance with the local zoning laws for each address or proposed location for an ATC. If the current zoning is not appropriate for a given address or location, identify any required zoning variance(s) and the applicant’s actions taken to date to obtain such approval(s) and/or variance(s). Supporting documents should be included as Appendix C.

See attached Appendix C, which is a letter from the City of Bayonne, Division of Planning/Zoning/Building dated February 10, 2011, which states that the proposed ATC location would be consistent with Bayonne Medical Center’s current zoning.

Measure 4: The applicant shall provide evidence that all of the physical addresses and proposed locations provided in response to Measure 2 are not located within a drug-free school zone. The applicant shall provide the distance to the closest school from the ATC. Supporting documents should be included as Appendix D.

The proposed location of NJ Healthy Choice, Inc.’s alternative treatment center is 29 E. 29th Street in Bayonne, New Jersey, which is otherwise known as Bayonne Medical Center, the sister company of NJ Healthy Choice, Inc. While the site is within 1000 feet of a school, it is within Bayonne Medical Center which currently dispenses controlled substances. NJ Healthy Choice will maintain protocols similar to those of the hospital which would provide a more than substantially secure environment under the alternative treatment center arrangement.

Measure 5: The applicant shall provide a legible map or maps of the ATC service areas by Zip Code to be served by the ATC. Supporting documents should be included as Appendix E.

The ATC’s primary service area would be located within Hudson County, New Jersey. Hudson County includes the following cities: Bayonne, Harrison, Hoboken, Jersey City, Kearny, North Bergen, Seacaucus, Union City, Weehawken, and West New York. Corresponding zipcodes are as follows: 07002, 07010, 07020, 07022, 07029, 07030, 07031, 07032, 07047, 07072, 07086, 07087, 07109, 07093, 07094, 07096, 07097, 07099, 07102, 07104, 07105, 07206, 07302, 07303, 07304, 07305, 07306, 07307, 07308, 07309, 07310, 07311, 07395, 07399, and 07657.

See attached Appendix E for service area maps.

Measure 6: The applicant shall provide the role, qualifications, name, address and date of birth of each staff member and the role, name, percentage interest, address and date of birth of each principal, officer, board member or partner of the ATC. In the event that an individual has not yet been identified, a statement of required qualifications and position description shall be included as Appendix F.

Staff Members

Should NJ Healthy Choice, Inc. be chosen as an alternative treatment center, appropriate and qualified staff members will be selected and hired in order to carry out responsibilities under the alternative treatment center arrangement. All such staff members shall meet or exceed the industry standard qualifications and/or any specific qualifications set forth under the alternative treatment center arrangement.

Controlling Member

IJKG Opco LLC d/b/a Bayonne Medical Center – 0% interest – 29 E. 29th Street, Bayonne, NJ 07002

Principals/Officers/Board Members/Partners

Director , Vivek Garipalli – 0% interest- Director , Jeffrey Mandler – 0% interest Director , James P. Lawler -- 0% interest President , Daniel A. Kane - 0% interest Treasurer , David Paulosky - 0% interest

Measure 7: Disqualifying Drug Offenses: In considering any application for an ATC permit, an applicant must disclose and the Department shall consider, at a minimum, the following factors in reviewing the qualifications of those persons applying:

Whether the applicant or any staff member, principal, officer, board member or partner has been convicted under any Federal, state or local laws, relating to drug samples, wholesale or retail distribution, or distribution of a controlled substance; - NONE HAVE BEEN CONVICTED.

Whether the applicant or any staff member, principal, officer, board member or partner has been convicted of a felony under any Federal, state or local laws; - NONE HAVE BEEN CONVICTED.

The past experience in the manufacturing or distribution of drugs or controlled substances by the applicant or any staff member, principal, officer, board member or partner;

Because the alternative treatment center is proposed to be located within Bayonne Medical Center, an acute care hospital, the hospital’s current policies and procedures regarding distribution of medications evidence vast experience in the distribution category with respect to staff members.

Whether the applicant or any staff member, principal, officer, board member or partner has ever furnished false or fraudulent material in any application concerning drug manufacturing or distribution; - NONE HAVE FURNISHED FRAUDULENT MATERIAL.

Whether the applicant is in compliance with any previously granted professional health license or registration, if any; and - N/A

Any other factors the Department might consider relevant. - N/A

Measure 8: The applicant shall provide the identities of all its creditors, if any.

Bayonne Medical Center is a sister company of NJ Healthy Choice, Inc., which will provide all initial funding and contributions for NJ Healthy Choice, Inc.’s alternative treatment center.

Measure 9: The applicant shall provide a list of all persons or business entities having direct or indirect authority over the management or policies of the ATC.

IJKG Opco LLC d/b/a Bayonne Medical Center Vivek Garipalli, Director Jeffrey Mandler, Director James P. Lawler, Director Daniel A. Kane, President

Measure 10: The applicant shall provide a list of all persons or business entities having an indirect interest in the ATC. An indirect interest includes an interest in the land or building where the ATC will be sited.

IJKG Opco LLC d/b/a Bayonne Medical Center

Measure 11: The applicant shall include the required application cover sheet and attestation statement signed by its chief executive officer or other individual authorized to make legally binding commitments on its behalf. - ATTACHED

Criterion 2: Submission of Required ATC Operational Information

Measure 1: The applicant shall provide a draft operations manual and training plan which demonstrates compliance with Subchapter 9 of N.J.A.C. 8:64, the Rules Related to the Medicinal Marijuana Program and which addresses ATC General Administration Requirements for Organization and Recordkeeping. Supporting documents should be included as Appendix G.

See attached Draft Operations Manual, Appendix G.

Measure 2: The applicant shall provide a description of how the ATC will operate on a long-term basis as a not-for-profit entity and a business plan that includes, at a minimum, the following:

I. The applicant shall provide a detailed description about the amount and source of the equity and debt commitment for the proposed ATC.

a. The immediate and long-term financial feasibility of the proposed financing plan;

b. The relative availability of funds for capital and operating needs; and

c. The applicant’s financial capability.

NJ HEALTHY CHOICE, INC.BUDGET NARRATIVE

FINANCING

REVENUE

SUPPLIES/PRODUCT COSTS

PAYROLL

EMPLOYEE BENEFITS

RENT

CONTRACT SERVICES

II. The applicant shall provide a copy of its proposed policy regarding charity care/servicing indigent patients.

See attached two (2) policies labeled specifically for Criterion 2, Measure 2, II.

III. The applicant shall provide a copy of its proposed policy related to disposal of returned or unusable marijuana.

See policy within Draft Operations Manual, Appendix G.

IV The applicant shall complete the following projected income statements for the first three (3) years of operation. Round all amounts to the nearest dollar.

NJ Healthy Choice, Inc.

Medical Marijuana ProgramThree Year Projection

Year 1 Year 2 Year 3Revenues Registered PatientsOther Supplies Register Patients

ExpensesSalaries and wagesBenefitsRentUtilitiesSupplies/product costsPurchase ServiceInsuranceOffice suppliesTotal Operating Expenses

Income/(loss)

Operating Margin

PatientsUnits10 visits per patient

Measure 3: The applicant shall document its experience running a not-for- profit organization or other business(es).

See attached resumes for Director, Vivek Garipalli, Director, Jeffrey Mandler, Director, James P. Lawler, and President, Daniel A. Kane.

Criterion 3: Community Input - Describe the ATC planning process and involvement of community stakeholders in detail. Describe remaining steps if any to receive necessary approval

for site location or operations.

Measure 1: Input from the city(s) or town(s) where the applicant’s ATC would be located.

See attached letter from the Honorary Terrance P. Ruane, President of the Bayonne Municipal Council dated February 11, 2011.

Measure 2: Input from the general public regarding the suitability of the applicant and the general standards for location(s) such as, distance from a school, daycare center or other child-oriented location; distance from a commercial shopping district, pharmacy; etc.

See attached letters of support from the community, specifically from the Bayonne Community Mental Health Center dated February 10, 2011, and the NJ Center for Empowerment and Community Development (CECD) dated February 10, 2011.

NJ Healthy Choice, Inc. will lease space from and be housed in within the physical premises of Bayonne Medical Center. Such location will provide for greater security and integrity of the alternative treatment center.

Criterion 4: Dispensary specific considerations

Measure 1: The applicant shall provide a plan for inventory, record keeping and security which shows an understanding of the types of records that shall be considered confidential health care information under New Jersey law and are intended to be deemed protected health care information for purposes of the Federal Health Insurance Portability and Accountability Act of 1996, as amended [HIPAA].

PLAN

As a user of information at NJ Healthy Choice, Inc., you may develop, use, or maintain patient records (for health care, quality improvement, peer review, education, billing, reimbursement, administration, and research) or personnel records (for employment, payroll, or other business purposes). Patient and personnel information from any source and in any form, including paper records, oral communications, audio recordings, and electronic displays, is strictly confidential. Access to confidential patient and personnel information is permitted only on a need-to-know basis.

It is the policy of NJ Healthy Choice, Inc. that users, (employees, medical staff, students, volunteers, and outside affiliates) shall respect and preserve the privacy and confidentiality of patient and personnel information.

Violations of this policy include, but are not limited to:

1. Accessing information that is not within the scope of your job2. Misusing, disclosing without proper authorization, or altering patient and personnel

information disclosing to another person your sign-on code and password for accessing electronic or computerized records

3. Using another person's sign-on code and password for accessing electronic or computerized records leaving a secured application unattended while signed on

4. Attempting to access a secured application without proper authorization

Violation of this policy by employees, staff, or volunteers of NJ Healthy Choice, Inc. may constitute grounds for corrective action up to and including termination of employment. Violation of this policy by outside affiliates will constitute grounds for termination of the contractual relationship or other terms of affiliation between the outside affiliate and NJ Healthy Choice, Inc. Unauthorized release of confidential information may also have personal, civil, and/or criminal liabilities and legal penalties attached.

Examples of Breaches of Confidential

Accessing information that is not within the scope of your job: Unauthorized reading of patient account information Unauthorized reading of patient's chart Unauthorized access of personnel file information '. -": Accessing information that you do not need to know for the proper execution of your job functions

Disclosing to another person your sign-on code and password for accessing electronic or computerized records: Telling a coworker your password so that he or she can log in to your work Telling an unauthorized person the access codes for personnel files or patient accounts

Leaving a secured application unattended while signed on: Being away from your desk while you are logged in to an application Allowing a coworker to use your secured application for which he or she does not have access afte

Misusing, disclosing without proper authorization, or altering patient or personnel information: Making unauthorized marks on a patient's chart Making unauthorized changes to a personnel file Sharing or reproducing information in a patient chart or personnel file with unauthorized personnel Discussing confidential information in a public area, such as a waiting room or elevator

Using another person's sign-on code and password for accessing electronic or computerized records: Using a coworker's password to log into NJ Healthy Choice, Inc. computer system Making unauthorized use of a log-in code for access to personnel files or patient accounts

Attempting to access a secured application without proper authorization: Trying passwords and log-in codes to gain access to an unauthorized area of the computer system Using a coworker's application for which you do not have access after he or she is logged ill

Measure 2: The applicant shall submit a description of its proposed program for providing counseling and educational materials regarding methods of administration and research studies on health effects of medicinal marijuana to registered qualifying patients and their registered primary caregivers. The applicant shall submit a description of its historical relationship with clinical or research activities, if present.

See attached Appendix G, Draft Operations Manual.

Measure 3: The applicant shall provide an acceptable safety and security plan, including staffing and site, and a detailed description of proposed security and safety measures which demonstrate compliance with the Rules Related to the Medicinal Marijuana Program.

See attached Appendix G, Draft Operations Manual.

Measure 4: If the applicant proposes to cultivate and dispense at two separate physical locations, the applicant shall provide an acceptable delivery receipt plan, including measures to ensure sanitary medicinal standards, security and inventory control, for the receipt of medicinal marijuana from the cultivation site by ATC staff at the dispensing site. The delivery receipt plan shall demonstrate compliance with the Rules Related to the Medicinal Marijuana Program. – N/A

Measure 5: The applicant shall submit a description of its Medical Advisory Board including expertise of members and describe the plan to address community issues, including but not limited to, labeling issues and an overall review of community relations.

NJ Healthy Choice, Inc.’s Medical Advisory Board will consist of three physicians who have expertise in treating patients with disorders believed to be amenable to treatment with medical marijuana. The three physicians shall be board certified in their specialty. The specialties represented will include Neurology and Pain Management. Each physician will be registered pursuant to N.J.A.C. 8:64-2.4. The following physicians are the proposed Board members:

o Dr. Hoosang Sadeghio Dr. Phillip Lutzo Dr. Mark Spektor

NJ Healthy Choice, Inc. representatives, including the physicians listed above, will be present at the Medical Advisory Board meetings.

Measure 6: The applicant shall submit a plan to track and analyze data including but not limited to patient outcome, utilization and trends.

NJ Healthy Choice, Inc., will utilize an Electronic Medical Record in order to track and analyze data. The data included for analysis and reporting will include but not be limited to:a. Patient outcomes, including symptom improvements and quality of life score

improvementsb. Utilizationc. Trendsd. Patient satisfaction

The Quality Improvement Data will be presented monthly at Center’s staff meetings as well as presented at BMC organizational Medical Management Improvement Committee on a quarterly basis.

Pursuant to 8:64-4.3, NJ Healthy Choice, Inc. will collect and submit to the Department for each calendar year the following statistical data:

a. The number of registered qualified patients and registered primary caregivers

b. The debilitating medical conditions of qualified patientsc. Patient demographic data

d. Program costse. A summary of patient surveys and evaluation of servicesf. Such information as the Department may require

Criterion 5 Cultivation specific considerations – THIS PORTION OF APPLICATION IS N/A. NJ HEALTHY CHOICE, INC. WILL NOT BE APPLYING TO BE A CULTIVATOR.

Measure 1: The applicant shall provide an acceptable safety and security plan, including staffing and a detailed description of proposed security and safety measures which demonstrate compliance with Rules Related to the Medicinal Marijuana Program. Supporting documents should be included as Appendix F.

I The description shall include a detailed floor plan for the ATC cultivation site, which indicates location and design standards and performance specifications of security devices to be utilized.

II The applicant shall provide a plan to involve and coordinate with local law enforcement authorities on security and safety issues, and identify the law enforcement officials contacted during the development of this plan.

III If the applicant proposes to cultivate and dispense at two separate physical locations, the applicant shall provide an acceptable delivery plan, including measures to ensure sanitary medicinal standards, security and inventory control, for the delivery of medicinal marijuana from the cultivation site to the dispensing site. The delivery plan shall demonstrate compliance with the Rules Related to the Medicinal Marijuana Program.

IV All responses shall be utilized for internal Department review only and shall not be available for public comment or review.

NOTE: OFFICIAL USE ONLY – SECURITY-RELATEDINFORMATION – WITHHELD PURSUANT TO THE NEW JERSEYOPEN PUBLIC RECORDS ACT (OPRA)

Measure 2: The applicant shall provide a description of the enclosed, locked facility that would be used in the cultivation of medicinal marijuana, including steps to ensure that the medicinal marijuana production shall not be visible from the street or other public areas.

If the enclosed site is a greenhouse, identify materials used in construction of panels. Glass, fiberglass, metal, or polycarbonate panels shall be used in construction of the facility; polyethylene film is not permissible. Describe window and vent covers.

Measure 3: The applicant shall demonstrate an ability to provide a steady supply of medicinal marijuana to registered qualifying patients.

I The applicant shall provide a start-up timetable which provides an estimated time from issuance of an authorization for operation to limited operations to full operation, as well as the basis for these estimates.

II The applicant shall describe its knowledge of (and experience with) organic growing practices or agricultural growing practices to be used in their cultivation of medicinal marijuana.

III The applicant shall describe its quality control program and steps that will be taken to ensure the quality of the medicinal marijuana, including purity, potency and consistency of dose.

IV The applicant shall describe:

Methods to ensure that seed production and/or hybridization is prevented during cultivation of medicinal marijuana;

Methods of testing for the presence of mold, bacteria or other contaminants;

Procedures for routine scouting of insect and plant disease conditions;

Methods to control insect pests that do not include the application of pesticides during cultivation of medicinal marijuana, in accordance with the Rules Related to theMedicinal Marijuana Program;

Procedures for proper sanitation practices to minimize plant disease, and to promptly dispose of diseased plant material in a secured disposal area;

Methods for utilization of fans and cooling systems to maintain airflow patterns sufficient to prevent or minimize plant disease and insect infestation;

Methods to keep environment free from flowering male plants to ensure that female plants are not pollinated and seed production and/or hybridization is prevented;

Recordkeeping of any cultural measures used for plant pest or disease control, including disposal of culled plants;

The various strains of marijuana to be dispensed, and the form(s) in which it will be dispensed;

Record keeping for each package by lot, label and bar code;

Area security;

Packaging and labeling requirements; and

Methods of processing in a safe and sanitary manner.

Appendix G

Draft Operations Manual

1. Oversight of the Healthy Choice Alternative Treatment Center.

MISSION

NJ Healthy Choice, Inc. is a not for profit corporation incorporated to operate as an Alternative Treatment Center as defined by State of New Jersey. NJ Healthy Choice, Inc. utilizes a medical model to achieve its mission. It is dedicated to the following objectives for the benefit of its patients:

A. Help improve the quality of life of its members through improved symptom management, improved functional capacity, and reduced emotional distress.

B. Provide products related to the use of medical marijuana.

C. Provide registered qualifying patients, family members, and health care providers with up to date, scientifically accurate information about medical marijuana.

D. Provide registered qualifying patients, family members, and health care providers with up to date, reliable resources regarding State and Federal statutes and potential legal ramifications related to the use of medical marijuana.

E. Provide adjunctive clinical services that may be beneficial to the debilitating medical condition for which the registered qualifying patient is using medical marijuana.

F. Conduct clinical research to advance the field of medical marijuana.

G. Outreach to the patient and medical community regarding the services available at Healthy Choice Alternative Treatment Center.

H. Outreach to other organizations interested in medical marijuana treatment.

I. Disseminate research findings to registered qualifying patients, health care providers, family members, advocacy groups, policy makers, and other interested parties.

Organization Chart

 

The Board of Directors of NJ Healthy Choice Inc. will have final and full authority over the operation of the corporation and will ensure that NJ Healthy Choice Inc. shall not acquire, possess, cultivate, manufacture, deliver, transfer, transport, supply or dispense marijuana for any purpose except to assist registered qualifying patients with the medical use of marijuana directly or through the qualifying patient's other primary caregiver. They will ensure that NJ Healthy Choice Inc. operates in a not for profit capacity for the benefits of its registered qualifying patients. The Board of Directors will consist of not fewer than six (6) Board Members.

The Center Director is responsible for the oversight of all of NJ Healthy Choice Inc. activities and staff. He or she will perform all administrative functions and ensure that policies and procedures are followed. The Center Director will be responsible for training all employees and volunteers in Professional Conduct and Ethics and for maintaining updated information on all State and Federal Statutes relating to medical marijuana and new developments (medically, socially, and politically) in the field of medical marijuana.

The Dispensary Manager is responsible for the storage, transportation and dispensing of medical marijuana in any and all forms. The Dispensary Manager will also be responsible for the inventory management system and point of purchase system

Vendors will work with NJ Healthy Choice, Inc. to provide high quality, reasonably priced supplies and products related to the dispensing, and using of medical marijuana to registered qualifying patients.

Contractors will provide educational, clinical, research, and security services. These

NJ Healthy Choice, Inc.Board of Directors

Medical Advisory Council

Center Director

Dispensary Manager Vendors and Contractors

contractors will provide clinical expertise to NJ Healthy Choice, Inc., including but not necessarily limited to:

• Supervision of support groups• Provision of educational workshops and materials• Psychosocial assessment with referral to other adjunctive clinical services as well

as outside resources• Provision of adjunctive clinical services such as acupuncture, massage therapy,

pain self-management counseling, yoga, relaxation techniques, and stress management

Contractors will also research new developments in medical marijuana and develop materials to dispense this information to registered qualifying patients, their family members and interested parties such as healthcare providers, policy makers, and other organizations interested in medical marijuana. They will develop questionnaires and data collection systems to provide statistics on the utilization of and outcomes achieved by NJ Healthy Choice, Inc. They will conduct qualitative and quantitative research relevant to medical marijuana, including but not necessarily limited to quality of life, patient satisfaction, efficacy, and adverse effects. Contractors will also provide on-site security during dispensing hours for the added protection of the registered qualifying patients, the employees, and the product.

The Medical Advisory Council will be made up of at least three members of the medical community and will meet at least semiannually. The members will include practicing physicians. They will review the results of patient satisfaction surveys, research findings, and provider experiences to provide input on the evolution of the Institute's products and offerings.

2. Procedures for safely dispensing medical marijuana.

NJ Healthy Choice, Inc. will dispense medical marijuana in their secure dispensary. All product will be packaged in compliance with Department of Health regulations and will include a label containing the patient name, name of the strain, batch and quantity. Every package will be labeled FOR MEDICAL USE ONLY NOT FOR RESALE. Only registered qualifying patients or their primary caregivers who have identified NJ Healthy Choice, Inc. as a primary caregiver can enter the dispensary and only during hours established by the center.

3. Procedures to ensure accurate recordkeeping, including inventory protocols

NJ Healthy Choice, Inc. will implement appropriate security and safety measures to:

A. ensure the safety of registered qualifying patients, employees, and volunteers.

B. deter and prevent the unauthorized entrance into areas containing medical marijuana.

C. deter and prevent the theft of marijuana.

D. protect the confidential health information of registered qualifying patients. E. protect the integrity of computer systems, including product tracking systems.

PERSONNEL RECORDS

NJ Healthy Choice, Inc will maintain personnel records for each of the employee, principle officer, director, board member, agent and/or volunteer.

a. The record will include: an application; a copy of the NJ Healthy Choice, Inc issued ID badges, drivers’ license or other state issued ID; a certification that each employee, principle officer, director, board member, agent and/or volunteer agrees to comply with NJ 8:64; documentation of references; appropriate background check verification; the corresponding job description that includes duties, authorities, responsibilities, qualifications and supervision details; documentation of all required training including privacy and confidentiality; a signed statement that includes the date, time, place the training was provided and who provided the training. Additionally, the files will include signed copies of periodic performance evaluations, any disciplinary actions taken and documentation of drug testing.

b. The record will be maintained for a period of at least twelve (12) months after individual termination.

The Human Resources Department will conduct background checks on all employees as part of the selection and hiring process. Once the background investigation is completed, it will be placed in the employee's file. The following inquiries will be made and documented prior to applicant acquiring a position

1. Criminal record check will be conducted.

2. Verification that the individual’s name does not appear on either the GSA List of Parties Excluded from Federal Programs and the OIG List of Excluded Individuals/Entities prior to hire and annually on the anniversary of existing employees’ date of hire.

3. In accordance with the New Jersey “Health Care Professional Responsibility and Reporting Enhancement Act”:

A. An inquiry will be made to the Division of Consumer Affairs as to:

i. The current licensure and status of any health care professional under consideration for employment.

ii. Any Board Action or Notice of Impairment under the Act has been reported by any other health care entity.

B. Former employment – Inquiries will be made of all employers who employed the applicant for the seven (7) year period preceding the application – including inquiry from any health care entity regarding the employee’s job performance and the reason for the employee’s separation.

Evidence of a criminal record is not necessarily grounds to disqualify a candidate for employment or to terminate an employee. However, if the individual in any way falsified his/her application for hire or transfer, the may sever the employment relationship.

Subsequent to hire, employees are required to disclose any criminal convictions to their department head and human resources.

The Department will be notified immediately of any employee found on the OIG Exclusion list (see Federal Sanction Screening Policy #1.25.3 for appropriate action).

Requests for References or Confirmation of EmploymentMedical Center employees should not respond to requests for information regarding other employees. Rather, all requests for references, confirmations of employment or other information should be directed to Human Resources. Human Resources will only accept written requests for information with a release signed by the employee.

All information and records concerning your employment at are maintained in your personnel files, located in the Human Resources Office. The confidentiality of these files is strictly maintained. The personnel file is available to you for inspection while NJ Healthy Choice, Inc.. Copies of information will be provided upon request within three (3) days.

In order to keep your personnel file up-to-date, you must notify Human Resources and your department of any changes. This includes name, marital status, dependents, insurance, telephone number, address, continuing education relative to your employment here and any other information that the NJ Healthy Choice, Inc. should be aware of (i.e., awards, memberships, honors, etc.).

The Human Resources Department will provide specific materials from these files to the administrative staff and the individual employee’s Department Head for NJ Healthy Choice, Inc. business only. In addition, persons acting in an official capacity as required by federal, state, or local regulations will be allowed access. In all cases, personnel files may only be reviewed within the Human Resources Department.

Release of copies of personnel records to outside agencies will be made only under subpoena following administrative review.

It is the policy NJ Healthy Choice, Inc. to maintain a record of verification of the status of all employees who are required to have a license, registration, or certification, and to assure that such status is current and complies with all regulatory or licensing authorities governing hospitals.

Procedure:

1. Verification at Time of Employment:

i. Verification by visual examination of all original licenses, registrations or certifications will be made by the Human Resources Department at the time of employment of all nursing, professional and clinical new hires, with a copy of the documentation, stamped “COPY”, maintained in the employee’s personnel file. The Human Resources Department will then conduct Primary Source verification with the appropriate licensing or certifying authority. This documentation will also be included in the employee’s personnel file.

All R.N.’s and L.P.N.’s must also present to the Patient Care Services Division their original license for verification by visual examination.

The Human Resources Department will conduct a background check which consists of, but is not limited to, verification of licensure, if applicable.

ii. Verification of house physicians licenses, board certifications and any other pertinent documentation of physicians and certified nurses employed by shall be made prior to employment. Copies of said documentation shall be stamped “COPY” and shall be maintained in their file in the Human Resources office.

iii. All departments utilizing agency personnel will notify Human Resources of the name and address of the agency, so Human Resources can verify that the agency in question is licensed or registered in N.J. as a State recognized employment agency before the agency is engaged. All agency personnel must produce their license and/or certification, as appropriate, to the Manager for verification before they begin their assignment and a copy will be made and stamped “COPY” and held by the department for the length of the agency assignment. Primary Source Verification will be performed by the appropriate designee of the department and the documentation retained for the length of the agency assignment. On off hours, weekends, and holiday shifts, verification will be made by the Patient Care Services Administrative Supervisor.

2. Annual Verification:

i. Primary Source Verification will be made on a regular annual basis by the Human Resources Department. Copies will be placed in the employees personnel file.

ii. Primary Source Verification will be made on a regular basis for each physician employed to ensure that no physician is allowed to work without current status.

It is the responsibility of each employee to maintain and update any license or registration that is required for the performance of his/her duties. Anyone without a valid license or certification will be suspended immediately. Disciplinary action up to and including termination may be taken for repeated failure to comply with this policy and procedure.

ALTERNATIVE TREATMENT CENTER EMPLOYEE TRAINING

NJ Healthy Choice, Inc. employee traininga. The training will be completed on campus by management. The training will include: Professional conduct; ethics; State and Federal Laws regarding patient confidentiality; industry news and developments in the field of medical use marijuana; all adopted security measures and controls; and specific procedural instructions for responding to emergencies including robbery and workplace violence

Introduction

NJ Healthy Choice, Inc. utilizes a decentralized approach to education. The Department of Human Resources is responsible for overseeing the educational functions within the NJ Healthy Choice, Inc. All educational activities reflect the philosophy and support the goals of the NJ Healthy Choice, Inc. The intent of educational programming is to promote performance changes in staff performance and encourage professional development, thereby improving the quality of care. Commitment to and participation in educational programming by all levels of personnel is required to ensure a vital and dynamic educational process. It is recognized that adults learn best when principles of adult education are applied to the teaching learning process.

Definitions

General Employee Orientation

This one-day program is scheduled and coordinated monthly, by the Human Resources Department for all new employees. The purpose of the orientation is to welcome new employees to the organization and help them become familiar with policies, procedures and benefits of the NJ Healthy Choice, Inc. as well as the organization’s expectations for all employees. The agenda and documentation for the day is included as attachment A. Content is taught by subject matter experts and evaluated annually to ensure compliance with all regulatory agencies. All organization-wide competency training is administered at this time.

Probation Period

All employees are subject to a three-month probationary period upon hire. During his period, the NJ Healthy Choice, Inc. will make an initial determination about whether the employee’s performance meets requirements of the job and the employee can decide whether he/she wants to continue to work at NJ Healthy Choice, Inc.

Annual Competency Fair

The purpose of the fair is to reinforce many of the organization-wide competencies that were presented at General Orientation and to provide updates on any new or revised information in order to maintain competency of all healthcare workers.

Staff Development

A program whose purpose is to teach new knowledge or skills to existing staff as a result of a role change or function requirement. Terminal behavioral objectives must be met, as this program is job related.

Example: Pain ManagementPreceptor CourseACLS

Continuing Education

A program whose purpose is to promote the use of new and current theory and/or skills. Information / skills acquired are not a requirement to practice in a particular position.

Example: Legal Issues for HealthcareStress Management

Educational Process

Assessment

1. Conduct, on a continuous basis, assessments of learning needs of employees, utilizing performance improvement data, incident reports, mandatory regulations, and administrative input.

2. Conduct periodic formal written learning needs surveys of all personnel.3. Determine the career development needs / interest of each employee as part of the

performance appraisal process.

Planning

1. Employ a systematic approach to planning educational activities. Refer to procedure.2. Involve administrative personnel and employees at the staff level in the planning process.3. Collaborate with managers and directors in scheduling educational activities.4. Document program planning on the Monthly educational Calendar.

Implementation

1. Notify all personnel of forthcoming educational programs by e-mail to Directors and posted on all units.

2. Coordinate educational activities with other service activities.3. Utilize the appropriate resources for the educational activity.4. Utilize educational strategies and methodologies consistent with the program objectives

in achieving the desired outcome.

Evaluation

1. Systematically evaluate individual educational activities through the use of learner evaluations.

2. Orientation of all new employees, assessing the educational needs of employees, planning educational events through the educational advisory committee (EAC), developing methods to document education and monitoring compliance of employees with

Policy

1. All new hires at NJ Healthy Choice, Inc. will be required to attend a general orientation to the NJ Healthy Choice, Inc. on their first day of employment. In special situations, employees may begin working prior to attending orientation if the following conditions are met:

Their presence in the department is essential to patient care Their Administrator gives prior approval They complete the orientation self-study module within the first day of work They attend the next General Orientation Session

2. During the orientation period, the orientee should not be counted in the daily staffing numbers. Specific departmental and job specific information is to be covered during the orientation and an initial assessment of the employee’s performance and competency is performed. Human Resources will verify that this has occurred this via the employee's three-month evaluation form.

3. All employees, must annually update their competencies by attending the Competency Fair. Ongoing measurement of all appropriate competencies is conducted through attendance at the Annual Organizational Competency Fair. Managers will need to follow-up with employees who do not attend. Compliance will be reported to the respective Vice President and to the Board.

4. All NJ Healthy Choice, Inc employees, are required to attend and complete all in-service education, training, and/or licensing and regulatory agencies and state and federal law including the Health Insurance Portability and Accountability Act of 1996 (HIPAA).

5. Retraining for all NJ Healthy Choice, Inc employees whose functions are affected by a material change in the privacy and confidentiality policies or procedures will take place within ninety days after the material change becomes effective.

6. Any employee who is on leave of absence and returns or resigns and is rehired after 6 months must attend department specific orientation and update their annual competencies within 30 days of their return.

7. All Educational activities will be documented on the individual “Employee Competency Summary” which is kept in the departments.

PHYSICAL PLANT AND SECURITY ALARM SYSTEM

4. Employee Security Policy

BACKGROUND CHECK

All employees and Board members associated with NJ Healthy Choice, Inc. will submit to a full background check. Any offer of employment will be contingent upon receiving a report demonstrating compliance with the eligibility requirements.

Any vendor or contractor who will have access to the Center’s physical plant, safety or security procedures, or registered qualified patient information, must provide evidence of a full background check prior to being engaged by NJ Healthy choice, Inc.

ATC IDENTIFICATION CARDS

Any employee, or Board Member, director or officer of NJ Healthy Choice, Inc., when on physical premises of the center, must at all times display an ATC identification card. No such individual may begin working at NJ Healthy Choice, Inc. prior to having possession of the identification card. Such cards will be surrendered to the permitting authority when owner, director, board member or employee is no longer eligible to validly possess the card for any reason.

5. Safety and security procedures including disaster plan with procedures to be followed in case of fire or other emergencies

6. Personal safety and crime prevention techniques

7. Smoke and drug-free policies

NJ Healthy Choice, Inc. is committed to programs that promote safety in the workplace, employee health and well being and which promote a positive image of the institution in the community. Employee involvement with drugs and alcohol can adversely affect job performance and employee morale, jeopardize employee and patient safety and undermine the public’s confidence in the Center. Therefore, it is the goal of the Center to maintain a drug and alcohol free workplace. The Center’s rules pertaining to drugs and alcohol are as follows:

1. The use, sale, purchase, possession, or distribution of intoxicating beverages on Center premises or reporting to work under the influence of the same or with the odor of an alcoholic beverage on your breath is strictly prohibited.

2. The use, sale, purchase, possession, distribution, or manufacture of any unprescribed controlled dangerous substance by employees, on or off Center premises, or reporting to work under the influence of such a substance, is strictly prohibited. This prohibition includes but is not limited to marijuana, hashish, heroin, cocaine, morphine, phencyclidine (PCP), amphetamines, barbiturates, and hallucinogens.

3. The abuse of legally prescribed medications or possession of these medications without prescription, on or off Center premises, or reporting to work under the influence of the same, is strictly prohibited.

Any employee found by the Medical Center to have engaged in such conduct described above, at any time, will be subject to disciplinary action, up to and including discharge.

Employees must inform management if they were arrested or convicted of an offense involving drugs within five days of the arrest or conviction. Any employee who is convicted of a drug-related offense may be terminated from employment.

Implementation of Policy in the Workplace

An employee who is suspected of violating this policy may be required by the Center to submit to a medical examination that includes blood, urine, or other diagnostic testing to determine the presence of alcohol or drugs. Any employee, who refuses to cooperate in any way in connection with the taking of such a test, or in the enforcement of this policy, is subject to disciplinary action up to and including discharge.

If, in the opinion of the Center, an employee appears to be in violation of this policy, that employee will be immediately suspended from his/her position, without pay, pending further action. The decision to suspend may be taken before or after the results of any test for alcohol or drugs are known, and such action may be taken without testing the employee. A final disciplinary decision will be made on a case by case basis, taking into consideration the employee’s position, length of service with the Center, overall job performance, and any other

factors deemed relevant by the Medical Center, including and the results of any test for the presence of alcohol or drugs.

See Attached Policies: Emergency Management Plan (plan), Emergency Management Plan (policy), Security Procedures, Weapons, Hazard Vulnerability Analysis

REPORTABLE EVENTS

If NJ Healthy Choice, Inc. becomes aware of a reportable loss, discrepancies identified during inventory, diversion or theft, whether or not the medicinal marijuana, funds or other lost of stolen property is subsequently recovered and/or the responsible parties are identified and action is taken against them, NJ Healthy Choice, Inc: notify law enforcement by telephone, notify the permitting authority immediately (not within more than 3 hours of the incident) by telephone and within 10 days in writing. Reportable events include: an alarm activation or other event that requires public safety response; a breach in security; the failure of the security alarm system due to a loss of electrical power or mechanical malfunction that is expected to last longer than eight (8) hours; and any and all corrective actions taken. Documentation of such breaches, in an auditable format, with any corrective action must be documented and maintained for a period of at least two years after the reporting of an occurrence.

See Attached Policies: Controlled Substance Medication, Medication Variance Report

INVENTORY AND DESTRUCTION OF MARIJUANA – RECORDKEEPING

NJ Healthy Choice, Inc will conduct an initial comprehensive inventory of all medicinal marijuana (usable and unusable marijuana) available for dispensing on the date that NJ Healthy Choice, Inc first engages in the dispensing of the drug. An inventory of no medicinal marijuana will also be recorded during the first inventory. The inventory will include damaged, defective, expired or adulterated marijuana awaiting disposal, including the name, quantity and the reasons for which NJ Healthy Choice, Inc is maintaining the marijuana.

NJ Healthy Choice, Inc will conduct monthly inventory or stored, usable and unusable marijuana and will conduct a comprehensive annual inventory, maintain the inventory documentation in some form or hard copy (written, typed or printed), provide documentation of disposed marijuana that includes date, the quantity disposed of, manner of disposal and the person(s) present during the disposal with signatures to verify information. There must be at least 2 people present for all inventories and disposal of medicinal marijuana.

Records will be maintained for at least two (2) years.

If a permit to operate expires without being renewed, NJ Healthy Choice, Inc will destroy or dispose of all unused marijuana by providing it to the NJ State Police for destruction. A written record will be maintained that will include the disposal of the identified marijuana including the weight and inventory prior to destruction. Within ten (10) business days after the destruction of the drug by the NJ State Police, NJ Healthy Choice, Inc will notify the Department in writing, of the amount destroyed.

A qualifying patient or a primary caregiver in possession of unused, unadulterated marijuana that is no longer needed will return the drug to NJ Healthy Choice, Inc or transport or arrange for pickup by the NJ State Police. The person returning the marijuana shall present a valid registry card and State Issued Identification with photograph.

8. Miscellaneous.

Hours of Operation will be 8:30am-4:30pm Monday, Wednesday and Friday, and 10:am-7:00pm on Tuesday and Thursday.

Fee for 1oz of medical marijuana is $150. Sliding fee schedule based upon income will be developed in conjunction with the registered qualified patient or caregiver.

Onsite personnel will maintain full physical, verbal and electronic confidentiality and privacy of the operations and clients of NJ Healthy Choice, Inc.