EMPLOYEE PERFORMANCE ACCOUNTABILITY AND TERMINATION POLICY

SECTION 1 – POLICY PURPOSE

The purpose of this Employee Performance Accountability and Termination Policy is to establish a clear, structured, and objective framework for evaluating employee performance and administering corrective action within Lartey Wellness Group. The organization operates in a regulated healthcare environment where clinical integrity, documentation accuracy, regulatory compliance, and professional conduct are essential to maintaining the quality of services provided to clients and the integrity of the organization’s operations.

Lartey Wellness Group recognizes that effective performance management is essential for ensuring that employees meet professional expectations, comply with internal procedures, and adhere to applicable legal and regulatory requirements. This policy therefore establishes standardized criteria for identifying performance deficiencies, implementing corrective measures, and, when necessary, making termination decisions in a fair and consistent manner.

The policy is designed to promote accountability while also providing employees with clear expectations regarding job performance, conduct standards, documentation requirements, and operational responsibilities. By establishing defined performance benchmarks and procedural safeguards, the organization seeks to ensure that disciplinary and termination decisions are based on documented evidence rather than subjective judgment. This approach protects both employees and the organization by creating transparency, consistency, and procedural fairness in employment decisions.

In addition, the policy supports the organization’s broader operational objectives, including the protection of client welfare, preservation of regulatory compliance, maintenance of billing and revenue integrity, and protection of confidential information. Employees of Lartey Wellness Group frequently work with sensitive health information, payer systems, and clinical documentation standards. Accordingly, maintaining high standards of professional conduct and operational reliability is critical to safeguarding the organization’s licensure, payer relationships, and legal compliance.

This policy also serves as a governance mechanism to ensure that performance concerns are addressed in a timely and structured manner. Where performance deficiencies arise, employees will generally be given notice of concerns and an opportunity to correct performance through progressive discipline and performance improvement measures. However, the organization also recognizes that certain forms of misconduct or regulatory violations may pose immediate risks to clients, organizational compliance, or operational integrity and may therefore warrant immediate termination without prior disciplinary steps.

By implementing this policy, Lartey Wellness Group seeks to maintain a professional work environment in which employees understand their responsibilities, supervisors apply performance standards consistently, and employment decisions are documented in a manner that supports organizational accountability and legal compliance.

SCOPE

This Employee Performance Accountability and Termination Policy applies to all personnel working for or on behalf of Lartey Wellness Group, including full-time employees, part-time employees, temporary staff, clinical providers, psychiatric rehabilitation program (PRP) personnel, administrative staff, billing and insurance personnel, intake coordinators, customer service representatives, management personnel, and executive leadership.

The policy establishes the standards and procedures used by the organization to evaluate employee performance, address performance deficiencies, implement corrective action, and administer separation decisions where necessary. All supervisors and department leaders are responsible for applying this policy consistently when managing employee performance within their respective areas of responsibility.

In addition to traditional employees, the principles contained in this policy may also apply to independent contractors or consultants who provide services to Lartey Wellness Group under contractual arrangements. While independent contractors are governed primarily by the terms of their written service agreements, the organization may utilize the documentation standards and performance accountability principles outlined in this policy when evaluating contractor performance or determining whether contractual relationships should be continued or terminated.

Where a written employment agreement or contractor agreement contains specific termination provisions, notice requirements, or dispute resolution procedures, those contractual provisions will control to the extent required by law. However, the documentation practices and internal review procedures described in this policy may still be used by the organization to support termination decisions and maintain consistent internal governance standards.

Nothing in this policy is intended to alter or modify the at-will employment relationship that may exist between Lartey Wellness Group and its employees under applicable state law. Employees who are employed on an at-will basis may resign from their employment at any time, with or without notice, and the organization may terminate employment at any time, with or without cause or prior notice, except where otherwise required by applicable law or contractual agreement.

This policy is intended to function as an internal governance framework that promotes consistency, accountability, and compliance with applicable employment laws, healthcare regulations, payer requirements, and organizational standards. All employees and supervisors are expected to comply with the procedures and standards described in this policy when addressing performance concerns, implementing corrective action, or recommending termination.

The policy applies across all operational departments and service lines of Lartey Wellness Group and shall be implemented in a manner that supports fair treatment of employees while protecting the organization’s regulatory standing, operational stability, and commitment to providing high-quality services to its clients.

SECTION 3 – DEFINITIONS

For the purposes of this Employee Performance Accountability and Termination Policy, the following terms shall have the meanings set forth below. These definitions are intended to ensure consistent interpretation of the policy across departments and supervisory levels within Lartey Wellness Group.

Corrective Action Corrective action refers to any formal or informal measure taken by the organization to address performance deficiencies, behavioral concerns, or operational noncompliance. Corrective action may include verbal counseling, written warnings, training requirements, supervision directives, performance monitoring, or placement on a Performance Improvement Plan. The objective of corrective action is to provide employees with notice of performance issues and an opportunity to improve before more serious disciplinary action is taken.

Performance Improvement Plan (PIP) A Performance Improvement Plan is a structured performance management tool used when an employee’s performance falls below organizational standards. The plan establishes measurable performance expectations, identifies specific deficiencies, outlines required corrective steps, and provides a defined monitoring period during which the employee must demonstrate improvement. Performance Improvement Plans typically include defined timelines, performance benchmarks, and supervisory evaluation checkpoints. Failure to demonstrate adequate improvement during the monitoring period may result in additional disciplinary action, including termination of employment.

Progressive Discipline Progressive discipline refers to the graduated series of corrective measures used by Lartey Wellness Group to address ongoing performance deficiencies or conduct concerns. Progressive discipline typically begins with verbal counseling or warning, followed by written warning, formal performance improvement measures, and ultimately termination if deficiencies persist. The purpose of progressive discipline is to provide employees with fair notice of performance issues and an opportunity to correct deficiencies while maintaining accountability for meeting organizational standards.

Immediate Termination Immediate termination refers to the separation of an employee from employment without prior progressive discipline due to conduct that poses a significant risk to client safety, regulatory compliance, operational integrity, or organizational reputation. Immediate termination may occur when an employee engages in serious misconduct, legal violations, fraud, falsification of records, confidentiality breaches, or other conduct that undermines the organization’s ability to safely and lawfully provide services.

Operational Compliance Operational compliance refers to adherence to all internal procedures, regulatory requirements, payer policies, and documentation standards that govern the organization’s operations. This includes compliance with Medicaid billing requirements, payer documentation standards, credentialing requirements, clinical supervision rules, privacy regulations, and internal workflow procedures established by Lartey Wellness Group. Employees whose duties involve client services, billing, documentation, or administrative processes are expected to maintain strict compliance with these operational standards.

Documentation Standards Documentation standards refer to the requirements governing the accuracy, completeness, timeliness, and integrity of written or electronic records created by employees in the course of their duties. These standards include clinical documentation requirements, encounter notes, billing documentation, administrative records, communications, and internal reports. Employees must ensure that all documentation accurately reflects services provided and complies with applicable organizational policies, payer rules, and regulatory requirements.

Supervisor For the purposes of this policy, a supervisor refers to any employee who has managerial authority to oversee the work of other personnel, evaluate performance, assign responsibilities, or recommend disciplinary action. Supervisors are responsible for monitoring employee performance, documenting performance concerns, providing corrective guidance, and initiating disciplinary procedures when appropriate.

Termination Review Process The termination review process refers to the internal administrative procedure through which termination decisions are reviewed and approved before final separation occurs. This process generally includes supervisory documentation, human resources review, and leadership authorization to ensure that termination decisions are supported by documented evidence and comply with organizational policy and applicable employment laws.

SECTION 4 – PERFORMANCE STANDARDS

Employees of Lartey Wellness Group are expected to maintain professional performance that supports the organization’s clinical mission, operational stability, regulatory compliance, and service quality. Because the organization operates within a healthcare and behavioral health service environment, employee performance directly affects client care, payer compliance, regulatory oversight, and organizational reputation.

Performance expectations are evaluated across several core operational categories. Employees are expected to meet acceptable standards within each category as part of their professional responsibilities. Failure to maintain satisfactory performance within one or more categories may result in corrective action, performance monitoring, or disciplinary measures as outlined in this policy.

Supervisors are responsible for monitoring employee performance, identifying deficiencies, documenting concerns, and providing guidance to ensure that employees understand and meet these expectations.

In situations where concerns or complaints are raised by clients regarding a clinician’s conduct, communication, or service delivery, Lartey Wellness Group will ensure that the matter is reviewed in a fair and objective manner before any disciplinary action is taken. All such concerns will be evaluated by internal management to ensure that the clinician is provided an opportunity for fair consideration of the circumstances and that any decisions are based on verified information and documented evidence rather than solely on client allegations.

4.1 Clinical or Service Delivery Performance

Employees who provide direct client services must maintain professional standards consistent with clinical ethics, regulatory requirements, and the organization’s service delivery expectations. Clinical personnel and service providers are responsible for delivering services in accordance with approved treatment plans, applicable program requirements, and supervisory guidance.

Employees providing client services must complete all required documentation accurately and within established timelines. Clinical notes, encounter documentation, and service records must reflect services that were actually provided and must comply with payer documentation requirements. Documentation delays that exceed established internal timelines, particularly repeated delays in excess of seventy-two hours, may create compliance risks and may therefore result in corrective action.

Service providers are also expected to maintain appropriate service encounter levels where minimum service thresholds are required by program guidelines, payer requirements, or organizational operational planning. Repeated failure to maintain expected service levels without reasonable justification may trigger supervisory review.

Employees must also maintain appropriate professional boundaries with clients, adhere to ethical standards of care, and comply with supervisory directives related to clinical practice. Substantiated client complaints, violations of ethical guidelines, refusal to follow supervision instructions, or conduct that compromises client safety may result in disciplinary review.

4.2 Operational Compliance and Documentation

Operational compliance is essential to the organization’s ability to maintain regulatory standing, payer relationships, and operational stability. Employees are therefore expected to comply with all internal policies, administrative procedures, documentation standards, and regulatory obligations associated with their role.

Employees must follow established procedures related to client intake, insurance verification, credentialing requirements, record management, and documentation submission. Failure to follow internal procedures may result in administrative errors that affect billing, service authorization, or regulatory reporting.

Employees must also comply with applicable healthcare privacy standards and confidentiality requirements. Any improper disclosure of confidential information, mishandling of protected information, or failure to follow privacy safeguards may result in disciplinary action.

Repeated operational errors, failure to follow updated procedures, or disregard for established workflows may lead to performance review and corrective action, particularly where such deficiencies create compliance risks or operational disruption.

4.3 Billing and Revenue Integrity

Employees whose duties affect billing, reimbursement processes, insurance verification, or claims submission play a critical role in maintaining the organization’s financial integrity. Accuracy and timeliness in billing-related activities are essential for ensuring that services are properly reimbursed and that the organization complies with payer requirements.

Employees involved in billing processes must ensure that claims are submitted accurately, that services billed correspond to documented services provided, and that payer requirements are properly followed. Incorrect billing codes, incomplete documentation supporting claims, or delayed submission of claims may result in claim denials or financial losses for the organization.

Employees responsible for denial management or billing correction processes must take appropriate steps to resolve errors promptly. Repeated preventable billing errors, failure to correct known claim issues, or patterns of negligence affecting reimbursement processes may result in disciplinary review.

Maintaining billing accuracy is also essential for preventing regulatory violations. Any conduct that suggests intentional misrepresentation of services, falsification of billing records, or misuse of billing codes will be subject to immediate investigation and may result in immediate termination.

4.4 Communication and Professional Conduct

Professional communication and conduct are essential to maintaining a productive workplace and ensuring effective coordination among staff members. Employees are expected to communicate respectfully with colleagues, supervisors, clients, and external partners while maintaining professional standards of behavior.

Employees must respond to internal communications, scheduling requests, and operational directives within reasonable timeframes. Failure to respond to supervisors, repeated disregard of operational instructions, or misrepresentation of work availability may disrupt workflow and may result in disciplinary action.

Employees are also expected to maintain professionalism in all interactions, including electronic communications, meetings, and client interactions. Conduct that includes harassment, intimidation, discrimination, or disrespectful treatment of colleagues or clients will not be tolerated and may result in disciplinary action.

In addition, employees must accurately represent their work schedules, availability, and service commitments. Misrepresentation of work hours, falsification of time records, or failure to disclose scheduling conflicts may undermine operational planning and may result in corrective action.

4.5 Attendance and Reliability

Consistent attendance and professional reliability are necessary for maintaining continuity of services and operational stability. Employees are expected to fulfill their assigned schedules, attend required meetings, and meet service obligations associated with their roles.

Employees must notify supervisors promptly when scheduling conflicts, absences, or delays occur. Failure to communicate scheduling issues may disrupt service delivery, affect client care, and create operational challenges for the organization.

Repeated unapproved absences, chronic lateness, failure to attend required meetings, or delays in completing onboarding requirements may indicate performance deficiencies requiring corrective action. Employees are expected to demonstrate reliability in fulfilling their assigned responsibilities and maintaining consistent participation in organizational operations.

Supervisors may review attendance patterns when evaluating overall employee performance, particularly where attendance issues affect service delivery, team coordination, or client care continuity.

4.6 Client Respect and Dignity Standard

Lartey Wellness Group is committed to providing services in an environment where every client is treated with dignity, respect, and compassion. Employees must recognize that many individuals receiving services may be experiencing emotional distress, mental health challenges, financial hardship, or other difficult circumstances. As such, all staff members are expected to demonstrate patience, empathy, and professionalism when interacting with clients at all times.

Employees must communicate with clients in a courteous and supportive manner, using clear, respectful language and maintaining a calm and understanding tone. Staff members should listen attentively to client concerns, respond thoughtfully, and ensure that clients feel acknowledged and respected throughout the service process. Employees must avoid dismissive language, confrontational communication, or any conduct that may cause clients to feel disrespected, belittled, or ignored.

All employees must also respect the cultural, social, and personal backgrounds of clients. Communication should be sensitive to differences in language, cultural identity, religion, gender identity, disability status, and personal experiences. Employees are expected to demonstrate professionalism and fairness in all client interactions regardless of personal opinions or biases.

In situations where clients may be frustrated, upset, or confused, employees are expected to maintain composure and respond with professionalism and empathy. Staff members should attempt to de-escalate conflicts respectfully and should seek assistance from supervisors when necessary to resolve complex situations.

Employees must never engage in behavior that could be interpreted as abusive, discriminatory, humiliating, or threatening toward clients. Conduct that undermines the dignity, safety, or well-being of clients is strictly prohibited and may result in disciplinary action. Depending on the severity of the conduct, violations of this standard may lead to corrective action, suspension, or immediate termination of employment.

Maintaining respectful and compassionate interactions with clients is a fundamental responsibility of all employees and is essential to the organization’s commitment to ethical service delivery and quality care.

Addition to Professional Conduct and Communication Standards

Employees of Lartey Wellness Group are expected to interact with clients, colleagues, and external partners in a manner that reflects professionalism, respect, empathy, and cultural sensitivity. Because the organization provides behavioral health and supportive services, many clients may be experiencing emotional distress, mental health challenges, or difficult personal circumstances. Employees must therefore maintain a communication style that is patient, respectful, and understanding in all interactions.

Employees are expected to use a calm, professional, and supportive tone when communicating with clients in person, by telephone, through electronic communication, or through written correspondence. Staff members should make reasonable efforts to ensure that clients feel heard, respected, and treated with dignity during all interactions. Even when addressing difficult situations, service delays, billing concerns, or scheduling conflicts, employees must communicate clearly and respectfully without displaying frustration, hostility, or dismissive behavior.

Professional communication includes listening attentively to client concerns, responding to questions in a courteous manner, and providing accurate information about services, procedures, and expectations. Employees must avoid language that could be interpreted as disrespectful, condescending, or insensitive. The organization expects staff members to demonstrate patience and professionalism even when interacting with clients who may be upset, frustrated, or confused.

Failure to maintain appropriate professional conduct with clients, including repeated disrespectful communication, dismissive behavior, or inappropriate tone, may be considered a performance deficiency and may result in corrective action under the progressive discipline procedures described in this policy. In cases where employee conduct toward a client is abusive, threatening, or otherwise harmful to client welfare, disciplinary action may escalate to immediate termination depending on the severity of the conduct.

Maintaining respectful and compassionate communication with clients is a fundamental expectation of all employees and is essential to the organization’s mission of providing high-quality behavioral health services.

SECTION 5 – PROGRESSIVE DISCIPLINE

Lartey Wellness Group is committed to addressing employee performance concerns through a structured and fair corrective process whenever possible. The organization recognizes that performance deficiencies may arise for a variety of reasons, including misunderstandings of expectations, workload challenges, training gaps, or operational changes. Accordingly, the organization generally utilizes a progressive discipline process designed to notify employees of performance concerns and provide a reasonable opportunity for improvement.

Progressive discipline is intended to promote accountability while also supporting employee development and operational stability. The process allows supervisors to communicate expectations clearly, document performance deficiencies, and implement corrective steps before more severe disciplinary measures are taken.

Although progressive discipline is typically followed, the organization reserves the right to accelerate or bypass disciplinary steps when circumstances warrant, particularly where employee conduct presents significant operational, regulatory, financial, or safety risks.

5.1 Verbal Counseling or Verbal Warning

The first stage of progressive discipline generally involves verbal counseling or a verbal warning issued by the employee’s supervisor. This step is used when performance concerns first arise or when minor deficiencies are identified.

During verbal counseling, the supervisor will discuss the performance concern with the employee, explain the expected standard of performance, and clarify the actions necessary to correct the deficiency. The purpose of this discussion is to ensure that the employee understands the concern and is provided with guidance on how to improve.

Although this step is referred to as a verbal warning, supervisors are required to document the conversation in writing for internal records. The documentation should summarize the issue discussed, the expectations communicated to the employee, and the date of the conversation. This documentation may be placed in the employee’s personnel file to establish a record of the corrective discussion.

5.2 Written Warning

If the performance concern continues after verbal counseling or if the issue is more serious in nature, a written warning may be issued. A written warning formally documents the performance deficiency and clearly communicates the expectations for improvement.

The written warning should describe the specific performance issue, reference any prior discussions or counseling related to the matter, and outline the corrective actions required from the employee. The document should also specify the timeframe within which improvement must occur and explain the potential consequences if the employee fails to meet the required performance standard.

Employees receiving a written warning may be asked to acknowledge receipt of the document by signing it. The employee’s signature does not necessarily indicate agreement with the contents but confirms that the employee has received and reviewed the warning.

Written warnings are retained in the employee’s personnel file and may be referenced in subsequent disciplinary actions if performance deficiencies continue.

5.3 Performance Improvement Plan (PIP)

If performance deficiencies persist or if the performance concern is substantial enough to require closer monitoring, the employee may be placed on a Performance Improvement Plan. A Performance Improvement Plan is a structured corrective action process that outlines measurable expectations for improvement and establishes a monitoring period during which the employee’s performance will be evaluated.

The Performance Improvement Plan will identify the specific areas in which the employee’s performance is below standard and will define measurable benchmarks that must be achieved to demonstrate improvement. The plan will also specify the timeframe during which performance will be monitored. In most cases, monitoring periods may range from thirty to ninety days depending on the nature and severity of the performance concern.

Supervisors may schedule periodic meetings with the employee during the monitoring period to review progress, provide feedback, and ensure that the employee understands the expectations outlined in the plan. Employees are expected to actively cooperate with the improvement process and take reasonable steps to meet the established benchmarks.

Failure to demonstrate sufficient improvement during the Performance Improvement Plan period may result in additional disciplinary action, including termination of employment.

5.4 Escalation or Acceleration of Discipline

While progressive discipline generally follows the sequence described above, Lartey Wellness Group reserves the discretion to accelerate the disciplinary process when circumstances require a more immediate response.

For example, if multiple performance categories are deficient simultaneously, if prior corrective measures have proven ineffective, or if the employee’s conduct presents a heightened risk to clients, regulatory compliance, or organizational operations, the organization may proceed directly to a later stage of discipline.

Supervisors must consult with Human Resources or executive leadership before accelerating disciplinary action to ensure that decisions are consistent with organizational policies and applicable employment laws.

5.5 Final Disciplinary Action

When an employee fails to meet required performance standards despite prior corrective actions, or when performance deficiencies significantly impair the organization’s operations, termination of employment may be recommended.

Termination decisions must follow the termination review procedures described in this policy and must be supported by documented evidence demonstrating that performance deficiencies were identified and addressed through appropriate supervisory actions.

The progressive discipline process is intended to provide employees with notice and opportunity for improvement; however, it does not guarantee continued employment or prevent the organization from taking appropriate disciplinary action when operational, regulatory, or safety concerns arise.

SECTION 7 – TERMINATION REVIEW PROCESS

Lartey Wellness Group is committed to ensuring that termination decisions are made in a consistent, fair, and well-documented manner. Because employment separation decisions may have legal, regulatory, and operational implications, all termination actions must follow an internal review process designed to confirm that disciplinary procedures were properly administered and that sufficient documentation supports the decision.

The purpose of the termination review process is to ensure that employment separation decisions are based on objective performance evidence, consistent application of organizational policies, and appropriate supervisory review. This process also helps protect the organization from inconsistent decision-making and ensures that employment actions comply with applicable employment laws and internal governance standards.

Except in situations requiring immediate action due to serious misconduct, termination decisions should generally follow the progressive discipline procedures described in this policy. Supervisors must ensure that appropriate warnings, corrective guidance, and performance improvement opportunities have been provided and documented prior to recommending termination.

7.1 Supervisory Documentation and Recommendation

When a supervisor determines that termination may be warranted, the supervisor must first prepare documentation supporting the recommendation. This documentation should clearly describe the performance deficiencies, behavioral concerns, or policy violations that led to the recommendation for termination.

The documentation should include relevant performance records, written warnings, performance improvement plans, incident reports, client complaints where applicable, and any other materials demonstrating that the employee’s conduct or performance failed to meet organizational standards. The supervisor’s documentation should also describe the steps previously taken to address the issue and the employee’s response to corrective actions.

The purpose of this documentation is to ensure that termination recommendations are supported by objective evidence and that the organization maintains a clear record explaining the basis for the decision.

7.2 Human Resources Review

Once supervisory documentation has been prepared, the recommendation for termination must be submitted for review by the Human Resources function or designated administrative leadership responsible for personnel oversight.

The Human Resources review is intended to confirm that the termination recommendation is consistent with organizational policy, that appropriate disciplinary procedures were followed where required, and that the documentation supports the proposed action. This review also ensures that termination decisions are applied consistently across employees and that the decision does not raise concerns related to discrimination, retaliation, or other employment law considerations.

Human Resources may request additional information or clarification from the supervisor before approving the recommendation if the documentation is incomplete or requires further review.

7.3 Executive Leadership Approval

Final approval for termination must be provided by executive leadership or another authorized decision-maker designated by the organization. Executive review provides an additional level of oversight to ensure that termination decisions align with organizational standards, regulatory obligations, and operational priorities.

Executive leadership may evaluate the circumstances of the case, review the supporting documentation, and determine whether termination is appropriate or whether alternative corrective measures should be considered. No termination decision should be finalized until executive approval has been obtained.

7.4 Termination Justification Memorandum

Prior to final separation, a termination justification memorandum should be prepared and retained within the employee’s personnel file. This memorandum should summarize the basis for the termination decision, including the performance deficiencies, policy violations, or misconduct that led to separation.

The memorandum should also reference any prior disciplinary actions, corrective measures, or performance improvement efforts that were undertaken. Maintaining a clear written record of the termination decision helps ensure transparency and provides documentation supporting the organization’s decision-making process.

7.5 Post-Termination Administrative Procedures

Once termination has been approved and communicated to the employee, appropriate administrative procedures must be implemented to protect the organization’s operational systems and confidential information.

These procedures may include revoking system access, disabling electronic health record access, retrieving company equipment or materials, securing confidential documents, and updating internal records to reflect the employee’s separation. Supervisors and administrative staff should also coordinate continuity planning to ensure that any client responsibilities, service obligations, or operational tasks previously assigned to the employee are reassigned appropriately.

Implementing these administrative steps promptly helps protect organizational data, maintain service continuity, and ensure a smooth operational transition following employee separation.

SECTION 8 – DOCUMENTATION AND RECORD RETENTION

Lartey Wellness Group maintains strict documentation standards to ensure that all disciplinary actions, performance evaluations, and termination decisions are supported by clear and contemporaneous records. Proper documentation is essential for maintaining organizational accountability, ensuring consistency in employment decisions, and demonstrating compliance with applicable employment laws and regulatory requirements.

All supervisors and managerial personnel are responsible for maintaining accurate records of employee performance concerns, corrective actions, and disciplinary measures taken under this policy. Documentation must be factual, objective, and sufficiently detailed to describe the nature of the issue, the actions taken by management, and the outcome of any corrective efforts.

8.1 Performance and Disciplinary Documentation

When performance deficiencies, behavioral concerns, or operational compliance issues arise, supervisors must document the issue in a timely manner. Documentation should include the date of the incident or performance concern, a clear description of the issue, any relevant supporting information, and the corrective steps communicated to the employee.

Records of verbal counseling, written warnings, and Performance Improvement Plans must be retained in the employee’s personnel file. Even when corrective actions are initially communicated verbally, supervisors must create written summaries of those conversations for internal documentation purposes. These records help establish a clear history of performance management efforts and ensure that employees receive consistent guidance regarding expectations and improvement requirements.

Supervisors should ensure that all documentation remains professional, factual, and free from subjective or emotional language. Records should describe observable conduct or measurable performance outcomes rather than personal opinions.

8.2 Personnel File Maintenance

Personnel records maintained by Lartey Wellness Group may include employment applications, onboarding documentation, job descriptions, performance evaluations, disciplinary records, corrective action documentation, termination memoranda, and other employment-related materials.

These records must be maintained in a secure manner that protects employee privacy while ensuring that authorized personnel can access documentation when needed for legitimate business purposes. Access to personnel files should generally be limited to supervisors, Human Resources personnel, and authorized executive leadership.

Personnel files must be maintained in accordance with applicable employment laws and internal organizational policies governing record management.

8.3 Confidentiality of Employment Records

Employee performance records and disciplinary documentation contain sensitive information and must therefore be treated as confidential internal records. Unauthorized disclosure of personnel file contents may violate privacy expectations and organizational policy.

Supervisors and administrative personnel responsible for maintaining records must ensure that documentation is stored securely and that access is restricted to individuals with legitimate administrative responsibilities.

Employees may be permitted to review their personnel records in accordance with applicable law and organizational procedures governing personnel file access.

8.4 Retention of Disciplinary and Termination Records

Records relating to employee discipline, performance management, and termination decisions must be retained for a period consistent with organizational retention policies and applicable legal requirements. Maintaining these records allows the organization to respond appropriately to regulatory inquiries, employment disputes, or internal audits.

Termination documentation, including termination justification memoranda and supporting records, must be retained as part of the employee’s permanent personnel file for the duration required by applicable record retention guidelines.

Incomplete or missing documentation may weaken the organization’s ability to support disciplinary actions or termination decisions. Accordingly, supervisors must ensure that all disciplinary actions are properly documented and preserved within the employee’s personnel file.

SECTION 9 – CONSISTENCY AND NON-DISCRIMINATION

Lartey Wellness Group is committed to administering all performance management, disciplinary actions, and termination decisions in a fair, consistent, and non-discriminatory manner. Employment decisions must be based on legitimate business considerations, documented performance standards, and adherence to organizational policies rather than personal bias, favoritism, or unlawful factors.

Supervisors and organizational leadership are responsible for applying this policy consistently across similarly situated employees. Employees who engage in comparable conduct or demonstrate similar performance deficiencies should generally be subject to similar disciplinary standards, taking into consideration the specific circumstances of each situation and any relevant prior disciplinary history.

The organization strictly prohibits discrimination in employment decisions on the basis of legally protected characteristics as defined under applicable federal, state, or local law. Termination decisions must never be influenced by factors unrelated to job performance or professional conduct. All disciplinary and separation actions must be grounded in documented performance concerns, policy violations, or legitimate operational considerations.

Lartey Wellness Group also prohibits retaliation against employees who engage in legally protected activities. Employees who raise concerns about workplace conditions, report suspected compliance violations, participate in internal investigations, or exercise other protected rights must not be subjected to disciplinary action or adverse employment decisions as a result of those activities.

Supervisors must exercise professional judgment when evaluating employee performance and recommending disciplinary action. Decisions should be supported by objective evidence, documented performance history, and adherence to established procedures outlined in this policy. When uncertainty exists regarding the appropriate course of action, supervisors should consult with Human Resources or executive leadership to ensure that decisions remain consistent with organizational standards and legal requirements.

The organization recognizes that consistent application of employment policies promotes fairness, transparency, and organizational integrity. By maintaining uniform performance expectations and applying disciplinary procedures consistently, Lartey Wellness Group seeks to create a workplace environment that supports accountability while also respecting the rights and dignity of employees.

SECTION 10 – POLICY REVIEW

Lartey Wellness Group is committed to maintaining policies that remain current, effective, and aligned with applicable laws, regulatory requirements, and operational practices. Accordingly, this Employee Performance Accountability and Termination Policy shall be reviewed on a regular basis to ensure that it continues to support the organization’s governance standards, regulatory obligations, and service delivery objectives.

At a minimum, this policy shall be reviewed annually by organizational leadership or designated administrative personnel responsible for human resources oversight. The purpose of the review process is to evaluate whether the policy remains consistent with current employment laws, healthcare regulations, payer requirements, and organizational operational needs.

During the review process, leadership may consider updates to regulatory standards, changes in healthcare compliance requirements, organizational growth, operational restructuring, or lessons learned from internal performance management experiences. Where necessary, revisions may be made to strengthen the policy, clarify procedures, or address newly identified compliance considerations.

Supervisors and administrative personnel may also provide feedback during the review process regarding the practical implementation of the policy and any challenges encountered in applying its provisions. This feedback may assist leadership in refining procedures to ensure that the policy continues to promote consistent and effective performance management across the organization.

Any modifications or updates to this policy must be formally approved by executive leadership before they become effective. Once approved, revised versions of the policy will be communicated to supervisors and employees as appropriate to ensure awareness of the updated standards and procedures.

Maintaining a structured policy review process helps ensure that Lartey Wellness Group continues to uphold high standards of professionalism, accountability, and regulatory compliance while supporting a fair and transparent workplace environment.