emergency management disaster preparedness …

EMERGENCY MANAGEMENT DISASTER PREPAREDNESS PLAN

SOP

Manual Business Continuity Plan

Location: Liberty Corporate Office

Table of Contents Topic Page #

SOP – Emergency Management and Disaster Preparedness Plan

1

Introduction 3 Local Emergency Contact Information 4

Corporate Emergency Contact Information 5

Communication Tree 8

On-Site Evacuation Route 17

Emergency Notification 18

Specific Disaster Response 18

• Fire 18

• Flooding 18

• Hazardous Materials Release 18

• Medical Emergencies 18

• Pandemic 19

• Severe Weather 19

• Threats 19

• Utility Emergency 21

Information Management Services 22

Media Relations 22 Business Continuity Plan ………………………………………………………………………………………………………………………………………… 23

Liberty Healthcare Corporation

Emergency Operation Procedure

Created: 12/7/2016

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General Procedure

Liberty Healthcare Corporation and Affiliates (Liberty)

Standard Operating Procedures

Title:

Emergency Management Disaster

Preparedness Plan Effective Date: 4-1-2014

Author: Last Review Date:

Location: Corporate Office Last Revision Date: 06-30-2018

Functional Area: All Functional Areas

POLICY This plan provides the procedures necessary to effectively manage and mitigate major emergencies by:

• Providing an organizational structure for the direction, control, response, and communication of events;

• Reducing the exposure of employees to potential hazards;

• Minimizing the impact of the emergency on the operations of the company, its environment, and;

• Minimizing the damage to property, equipment, and company operations.

PROCEDURE



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Emergency Plan

Responsible Parties: Liberty will designate an Emergency Response Team consisting of members representing critical

areas of the company’s infrastructure such as technology, program operations, finance, human resources, and sales

and marketing. From this group an Incident Commander will be appointed.

An Emergency Plan has been created and members of the Emergency Response Team will communicate this Plan to

all personnel via in-service trainings and twice yearly drills.

As soon as an emergency occurs the Incident Commander will activate the Emergency Plan. An assessment will be

made of the situation and provide for the immediate safety of all personnel. The Incident Commander has the

responsibility and authority to activate the Emergency Plan. The Incident Commander will communicate to

emergency personnel: the specific location of the emergency, nature of the emergency, any area evacuation

recommendations, and request for any immediate assistance (i.e. fire, hazmat, rescue, medical, etc.)

Twice yearly drills are conducted for training purposes so all personnel are aware of all evacuation routes and will be

instructed to use these routes in an emergency. Fire Marshalls have been identified to assist in the quick evacuation

of all personnel. A holding area in the parking lot has been identified for all personnel to meet once an evacuation

has occurred. Fire Marshalls will account for the status of all employees and will report those findings to the Incident

Commander.

The Incident Commander will have the authority to call an “all clear”.

In the event of a prolonged emergency a central command post will be established to set up communication with our

employees and clients and to begin to resume normal operations of our organization. If Liberty is unable to use its

current telephone system, use of company cell phones will be used. All important phone numbers of clients and

employees are saved on these phones. A member of the Emergency Response Team will be designated as the

communication liaison and will be responsible for initial communication on the status of the emergency and further

instructions on any change in usual business operations.

Liberty’s information systems are housed on servers and backed up each evening. A copy of those backup files is

kept off site. Using the information from the backup files, Liberty’s information system will be recreated and placed

on a server for immediate access. This information contains records of all Liberty’s critical business operations and

will aid in the business recovery. In addition, Liberty’s HR and payroll information is housed “on the cloud” and can

be accessed from any computer with the use of the security passwords, thus expediting Liberty’s ability to continue

business without interruption.



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Approved By: ____________________________________ Date: ______________________



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Introduction

The Standard Operating Procedure above outlines the formulation of the Emergency Response Team and the role they play when emergencies

occur. The information outlined in this manual, along with common sense, is intended to help mitigate against possible injuries and address

emergencies that might happen at 401 E. City Avenue. While every emergency is different, it is important to establish some general guidelines

and provide information to handle any crisis. Remember in the event of any emergency dial 911 first and then contact the 401 Property

Management Company at 610-668-5959.



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Local Emergency Contact Information

Program Information

Program: Liberty Corporate

Address: 401 E. City Ave, Suite 820; Bala Cynwyd, PA 19004

Phone Number: 610-668-8800

Police, Fire, Ambulance 911

• Lower Merion Township Police Department 610-645-6270

• Lower Merion Fire Department 610-645-6190

Poison Control 800-222-1222

Roxborough Memorial Hospital 215-483-9900

• 5800 Ridge Avenue, Philadelphia, PA 19128

Lankenau Medical Center 484-476-2000

• 100 Lancaster Avenue, Wynnewood, PA 19096

Montgomery County Health Department 610-278-5117

Montgomery County Office of Emergency Preparedness 610-631-6500

401 Building Security 610-668-5959

Electric Company 610-668-5959

Gas Company, 610-668-5959

Water Company, 610-668-5959



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Telephone Company, Verizon 888-649-9500

Plumber, 610-668-5959

Heating, 610-668-5959

Air Conditioning 610-668-5959

Evans Pancoast, Managed Care Consultants 610-254-8237

Insurance Broker, Willis 610-254-5664



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Corporate Emergency Contact Information

Program Information




Emergency Response Team

Last Name First Name Preferred Method Home Phone # Cell Phone # Email Address

Nayda Sue Text 610-389-7425 [email protected]

Tanner Camille Cell 610-446-7959 215-813-7437 [email protected]

Caskey Herbert Email [email protected]

Mammuth Tod Cell 610-389-7428 [email protected]

McParland Tom 610-389-7432 [email protected]

Guda John Cell 610-331-6306 [email protected]

Robinson Rick 610-389-7444 [email protected]



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Communication Tree

Program Information




Sue Nayda - calls


Carabello Kenneth 310-384-9183 [email protected]

Graybill Todd 502-588-7592 [email protected]

Sproule Charlie 610-613-8516 [email protected]

Castronuovo Ian 610-389-7430 [email protected]

Shields Judith 610-389-7434 [email protected]

Little Alicia 267-398-5889 [email protected]

Sage Hugh 580-542-5772 [email protected]

Moore Marie OK Client 405-820-3176 [email protected]

Deming Adam 317-508-9178 [email protected]

Levenhagen Mark IN DOC Client 317-234-1926 [email protected]



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Camille Tanner - calls

Last Name First Name Preferred Method Home Phone

#

Cell Phone # Email Address

McNamara Melissa 610-804-3631 [email protected]

Smith Rena 484-477-2086 [email protected]

Butler Laura (on-call

administrator)

267-418-3698 [email protected]

Johnson Kareema 215-275-8272 [email protected]

Tod Mammuth - calls


Oblea Cathy 215-361-1334 [email protected]

Makoid Melinda 610-405-8067 [email protected]

Gerhart Kathy 484 574-2064 [email protected]

Tom McParland - calls


Greenlee Shirley 610-585-9627 [email protected]



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John Guda - calls


Anderson

Paul 215-888-0801 [email protected]

Back Eli 443-850-8775 610-389-7440 [email protected]

Rick Robinson – calls


Baglio Chris 815-426-2160 317-677-6631 [email protected]

Piontek Trish 610-310-7120 [email protected]

Jennings Jerry 610-304-3507 [email protected]

Hanna Mike 850-294-0560 [email protected]

LePostollec Mike 267-328-8525 [email protected]

Ulloa Tess 623-693-4327 [email protected]

Ken Carabello - calls


Shale Jayne 858-531-8080 [email protected]

Stillman Alan 858-337-8894 [email protected]



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Grabau Mark 916-709-7823 [email protected]

Rice Kevin text 626-665-7089 [email protected]

Fillman Terry 909-289-1599 [email protected]

Bryant Steve 217-801-7113 [email protected]

Scott Greg 217-322-3204

Ext 5003


Jumper Shan 217-491-0139 [email protected]

Yang Bryan 909-501-8787

Villeneuve Jake 510-600-5697 [email protected]

Tait Rachel 773-474-9347 [email protected]

Khouri Ramsey 619-227-1591 [email protected]

DeLucchi Mark 415-335-5118 [email protected]

Roberts Rachelle 510-600-5697 [email protected]

Todd Graybill - calls

Last Name First Name Preferred Method Cell Phone # Email

Stachowiak Barbara 202-570-0056 [email protected]

Chase Bryan 202-750-1523 [email protected]

Nelson Casey 202-285-3759 [email protected]



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Morris Jared 202-531-2859 [email protected]

Ferido-Agapito Jo Ann 302-344-6272 [email protected]

Wemlinger Adele 866-552-5758 [email protected]

Muthukumar Aruna 302-897-9133 [email protected]

Quinlan Louis 302-388-4558 [email protected]

Haque Mohammad 302-354-2962 [email protected]

Barbieri Michael 302-255-2700 [email protected]

Zwick Wayne 260-485-4580 [email protected]

Judkins Lyneka


Lea Sabrena 919-208-1746 [email protected]

Harmon Aaron 419-262-4481 [email protected]

Finn Patti 419-591-6148 [email protected]

Gibbs Gretchen 765-977-3771 [email protected]

Baker Michele 810-956-7200 [email protected]

Benoit Matthew 518-645-5970 [email protected]

Charlie Sproule calls

Last Name First Name Preferred

Method

Home

Phone #


Golden Kirk 724-679-

1728

[email protected]

Zumbrun Katherine 717-736-

7050

[email protected]



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Piccone Jocelyn

937-901-

2378

[email protected]

Bank Robert 803-898-

4802

[email protected]

Harkins Joe 207-356-

0838

[email protected]

Gardner Michelle 207-356-

8796

[email protected]

Kincaid Reid 207-758-

0330

[email protected]

Medical Director, Riverview

Scola Kim 617-710-0261 [email protected]

Murray Paul 978-697-4567 [email protected]

Silva Jane 339-203-3242 [email protected]

Nevulis Rita 781-894-3600 Ext. 2575 [email protected]

LaJenuness, Jennifer 208-283-9121 [email protected]

Ian Castronuovo - call

Last Name First Name Preferred

Method

Home Phone

#


Wertley Carol 610-389-7437 [email protected]

DiGirolamo Marc 215-219-3571 [email protected]

Caskey Michael 610-952-1611 [email protected]



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Underwood Meagan 559-273-9714 [email protected]

DiGirolamo Matt 610-952-3328 [email protected]

David Dotti 415-521-8228 [email protected]

Feigin Susan 864-556-3152 [email protected]

Salazar Liz 630-696-5515 [email protected]

Judith Shields - calls


Yankawitz Abby 215-779-4842 [email protected]

Rushiti Alba 267-432-1005 [email protected]

Shirley Greenlee - calls


Palicki Rose 215-426-2175 215-292-4053 [email protected]

Knipe Dana 201-519-9387 [email protected]

Busby Michael [email protected]

Rozman Denise 215-332-9657 [email protected]

Snyder Debi 215-442-9731 [email protected]

McBride Maxine 215-275-2694 [email protected]

Chauhan Andy 610-328-9380 610-931-6398 [email protected]



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On-Site Evacuation Route

Program Information




Accounting/ Payroll

OFFICES

Cubical Area

Server Room

Copy Area

Kitchen

Mail

Room Red Room

Bo

ard

Ro

om

Storage Room

File Room

OF

FIC

ES

Hotel Suite

Reception Area

Copy Area

Office

Conference Room

EMERGENCY EXIT

OF

FIC

ES

Liberty Healthcare Corporation Emergency Operation Procedure Created: 12/7/2016

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Emergency Notification Program Information Program: Liberty Corporate Address: 401 E. City Ave, Suite 820; Bala Cynwyd, PA 19004 Phone Number: 610-668-8800

A. Radio:

1. In Montgomery County, the Emergency Alert Station is KYW 1060 AM. All Emergency information will be broadcast on this radio station.

B. Television: 1. Local television will broadcast Emergency Alert information

C. Weather Radio

1. Most weather radios are equipped to activate by tone alert. The radio should be set to the alert position. In the event of severe weather the National Weather Service out of Mt. Holly, New Jersey will broadcast a tone that activates the radio and it will then receive the emergency message.


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Specific Disaster Response Program Information Program: Liberty Corporate Address: 401 E. City Ave, Suite 820; Bala Cynwyd, PA 19004 Phone Number: 610-668-8800

Fire –if fire is discovered, activate the nearest fire alarm, notify the local fire department by calling 911 and notify the building security office by calling 610-668-5959. Upon notification of a fire in or near the building at 401 E. City Avenue, exit the building by using the evacuation route noted above. All employees and visitors should meet outside the building in the designated area and await further instructions. Flooding Flooding can occur as a result of hard rain over several hours, steady rain over several days, snow and ice melt or if a dam breaks. The National Weather Service will issue both watches and warnings to alert the public to a flooding condition. If a watch is issued it means there is a threat that flooding will occur. A warning means flooding is imminent or occurring. In the event of flooding follow these procedures:

1. Monitor weather updates through the radio or television news broadcasts 2. Maintain contact and communication with staff 3. If evacuation is needed, remember that 2 feet of moving water can cause most vehicles to float. Use caution when

operating vehicles in these conditions. If help is needed, call 911 for assistance before putting yourself at risk. Hazardous Materials Release - in the event of a large chemical spill, immediately notify a member of the Emergency Response Team, or a member of management. Contain the spill with available equipment. Secure the area and alert other personnel. Do not attempt to clean the spill unless trained to do so. If toxic fumes are present, evacuate the building by using the emergency route above. Contact the Fire Department for clean up or further instructions. Medical Emergencies – any injury or illness, such as seizure, failing, heat exhaustion, etc. that occurs on location should be reported to the Vice President of Human Resources, or her designee. This should be done after a call to 911. If a person has fallen, struck their head or hurt their back or neck, DO NOT ATTEMPT TO MOVE THEM. The best treatment you can provide is to wait for emergency personnel and keep the patient warm and comfortable. Minor injuries such as cuts and bruises, can be administered to by using the First Aid kit located in the office in the cubicle closest to the lunch room. Employees with specialized training may volunteer to provide basic first aid as appropriate. All work related injuries need to be reported to Liberty’s workers’ compensation carrier, AIG. To report a claim contact the Triage Nurse at 1-855-365-7279. The nurse will instruct the worker on treatment options and will report the claim to AIG directly if medical treatment beyond first aid is required. If only first aid or no medical treatment occurs, the employee must report the injury to their supervisor who will in turn report it to the VP of HR.


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Pandemic – The threat of a serious pandemic flu can have a direct and significant impact on all employees at our location. A pandemic flu involves the easy and rapid spread of an aggressive and potentially lethal virus. Public health officials recommend a strategy of social distancing to mitigate the spread of such an illness. In the case of threat of such an illness communication from the Emergency Response Team will suggest when such distancing is recommended and the plans for business continuity in the event the office much close to prevent the spread of the disease. Severe Weather

In Montgomery County, a wide range of severe weather is a constant threat throughout the year. In any severe weather event it will be classified as a watch or warning. A watch means that a threat of severe weather exists. A warning means severe weather is imminent or occurring. In all severe weather emergencies make sure to:

1. Remain calm 2. Maintain contact and communication with the staff 3. Notify the person in charge of any updates

Thunderstorm Watch:

1. Notify staff of the thunderstorm watch 2. Under these conditions, staff members may proceed cautiously with their daily activities 3. Monitor weather updates through the radio or television news broadcasts

Thunderstorm Warning:

1. Notify staff of thunderstorm warning 2. Stay away from windows and limit the use of electrical equipment or a corded phone 3. Monitor weather updates through the radio or television news broadcasts

Tornado Watch:

1. Notify staff tornado watch 2. Under these conditions, staff members may proceed cautiously with their daily activities 3. Identify the lowest floor and inner most room or hallway with the least amount of windows to shelter in place 4. Monitor weather updates through the radio or television news broadcasts

Tornado Warning:

1. Notify staff of tornado warning 2. Move all building occupants to the lowest level room in the location 3. Get in a crouching position face down, with your hands behind your head if possible, assist consumers that may not be

able to achieve this position on their own 4. Monitor weather updates through the radio or television news broadcasts

Threats

Bomb Threat Bomb threats are a growing concern and have become much more prevalent. The majority of bomb threats are hoaxes and unfounded, but all threats should be taken seriously and handled properly. If speaking with the threatening caller, remain calm and try to keep the individual on the line, do not interrupt, but try and get as much information as possible. Is the caller Male___ Female____ Adult____ Juvenile____ Caller ID?__________________


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Voice Characteristics: Loud___ Soft___ High Pitch___ Deep ___ Raspy___ Intoxicated__ Machine Altered Voice___ Accent: Local ___ Foreign__ What country___ Speech pattern: fast___ Slow___ Distorted ___ Nasal___ Slurred ___ Stutter___ Language use: Excellent__ Poor___ Good___ Foul___ Background Noises: Factory__ Machines__ Trains___ Airplanes___ Animals ___ Music___ Street Noise__ Voices___ Traffic ___ Quiet ___ Party___ After receiving a bomb threat follow these procedures:

1. Remain Calm 2. Without using a cellular phone dial 911 3. Pull closest fire alarm to begin evacuation 4. Quickly check the area you are in for anything suspicious or out of place 5. Evacuate the building using the on-site evacuation route 6. While evacuating keep a look out for anything suspicious or out of place

Intruder / Workplace Violence If you are the person that makes the initial contact with an intruder or witnesses acts of workplace violence:

1. Approach with caution and do not be confrontational 2. Do not make any sudden movements 3. You should ask them normal questions as to what and why they are there 4. Try to keep the intruder away from the consumers & staff if possible

If there is a lockdown situation in effect

1. A VP will declare a Lockdown situation. Once a Lockdown is determined an announcement will be made over the phone system. “Mr. Adams Report to Reception.”

2. The property manager or receptionist will call 911. 3. All doors will be locked 4. Staff will Shelter in Place. 5. A mass text, e-mail, and/or phone call will be sent to all employees. 6. Staff and clients on outings will shelter in place if possible. If not possible, they should go to the Liberty designated site

pending the lifting of the Lockdown status. 7. The Lockdown status will be posted on the website. 8. Staff that have scheduled meetings and are expecting visitors will let the potential attendees know that we are in

Lockdown and will reschedule as needed 9. Staff will continue to shelter in place until the Lockdown status is lifted.

Hostage Situation – if you are involved in a hostage situation:

10. Keep calm and follow directions 11. Do not speak unless spoken to 12. Do maintain eye contact, but don’t stare 13. Do not volunteer information 14. Be patient; time is on your side 15. Be observant; you may be released or escape and others will depend on your memory


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Suspicious Mail In today’s heightened awareness of possible threats of terrorism everyone is a potential target. All staff should be able to identify what could be a suspicious package. According to the United States Postal Service follow these procedures when dealing with a potential suspicious package:

1. Do not handle the mail piece or package suspected of contamination 2. Make sure that damaged or suspicious packages are isolated and the immediate area cordoned off 3. Ensure that all persons who have touched the mail piece wash their hands with soap & water 4. Call 911 to notify your local law enforcement authorities 5. List all persons who have touched the letter and/or envelop, include contact information and have this information

available for the authorities 6. Place all items worn when in contact with the suspected mail piece in a plastic bag and have them available for law

enforcement agents 7. As soon as practical, shower with soap & water 8. Notify the Center for Disease Control Emergency Response at 770-488-7100 for answers to any questions

The extent of these actions will be determined according to the severity or credibility of the incident. Utility Emergency In the event of an extended power outage certain precautionary measures should be taken depending on the location and

environment of the facility. All personnel should evacuate the building. Unnecessary electrical equipment and appliances

should be turned off in the event that power restoration would surge causing damage to electronics. Equipment that contains

fluids that may freeze due to long term exposure to freezing temperatures should be moved to heated areas, drained of liquids,

or provided with auxiliary heat sources.

Employee Assistance Program (EAP)

As a result of any of the above disasters employees may have physical, financial and emotional needs. Liberty provides an

Employee Assistance Program, through MetLife. To contact the EAP, call 1-800-511-3920.


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Information Management Services Program Information Program: Liberty Corporate Address: 401 E. City Ave, Suite 820; Bala Cynwyd, PA 19004 Phone Number: 610-668-8800

Liberty’s information systems are housed on servers and backed up each evening. A copy of those backup files is kept off site. Using

the information from the backup files, Liberty’s information system will be recreated and placed on a server for immediate access. This

information contains records of all Liberty’s critical business operations and will aid in the business recovery. In addition, Liberty’s HR

and payroll information is housed “on the cloud” and can be accessed from any computer with the use of the security passwords, thus

expediting Liberty’s ability to continue business without interruption.

Media Relations Program Information Program: Liberty Corporate Address: 401 E. City Ave, Suite 820; Bala Cynwyd, PA 19004 Phone Number: 610-668-8800

All media relations are handling by the Development Team at Liberty Healthcare. All inquiries should be directed to any of the

individuals on the team.


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Liberty QualityCare® Business Continuity Plan (BCP)

Purpose of the BCP: This Liberty Healthcare Corporation BCP is provided as an overall BCP for our business and to assist our business lines in fulfilling their need to create and maintain business line-specific BCPs and emergency contact communication lists in compliance to the Joint Commission Healthcare Staffing Services Certification requirements and as the disaster recovery plan for Liberty. This BCP recognizes that many of our business lines rely on parts of their customers’ BCP for many mission-critical functions for their contracts. If your business line relies on elements of your customer’s BCP or mission-critical systems you should be familiar with that plan and forward a copy to Liberty Healthcare Corporation (Liberty), if possible.

• For the purpose of this plan the Pennsylvania Bala office is a business line Critical Elements of the BCP: There are 10 critical elements of this BCP*:

(1) Data back-up and recovery (hard copy and electronic); (2) Re-constitution and re-configuration of all Liberty critical applications and supporting technical infrastructure including but not limited to the Network, Servers, Databases, Applications and Voice Communications; (3) Financial and operational assessments to include analysis of how insurance Coverage would respond to various disaster scenarios in order to ensure that Adequate funding for the execution of the BCP will be available; (4) Alternate communications between customers and business line leadership; (5)Alternate communications between business line leadership and Liberty employed staff; (6) A recovery strategy for relocation to alternate premises; (7) Critical business contract impact; (8) Regulatory reporting; (9) Communications with Liberty executive leadership; and (10) How Liberty will assure customers’ prompt access to our services in the event of a business interruption.

*Some of the above critical elements may not apply to certain business lines. The reason for the omission of one or more critical elements from a business line BCP should be documented as part of that BCP. Conversely, a business line may identity other critical elements to be included in its BCP. INTRODUCTION

Implementation of Business Continuity Plan and Crisis Management Plan Plan Owner: Camille Tanner, VP- HR or named Incident Commander of Emergency Response Team


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Phone Number(s): cell (215-813-7437) home (610) 446-7959 Date Created: 5/17/2016 Date Revised: 5/17/2016 Responsibilities of Plan Owner:

1. Reviews and updates plan quarterly. 2. Keeps hard copy of plan on site and in shared drive. 3. Keeps hard copy offsite (home location) 4. Keeps soft copy on Flash Drive 5. Ensure all employees are educated on planning procedures and review with department heads quarterly.

IN CASE OF DISASTER: Follow the steps listed below and track when completed in the event of discovery or notification of a disaster. A disaster is defined as any event at a Liberty location which:

• Results in a disruption of some or all business operations at the site • Leads to a decision to mobilize a portion or all of the Business Continuity Organization • Causes initiation of recovery of some or all of the interrupted operations at an alternative site.

Task Required Action Status

Completed/Pending Date and Time Completed

1. Notify COO, Sue Nayda, via cell phone at 610-389-7425 and provide description of event.

Notify CEO, CFO 610-389-7432, General Counsel 610-389-7428 and CIO/CTO 610-331-6306

2. Use attached phone tree to notify clients and employees of crisis. .

3. Determine initial meeting location. Set up a conference bridge and inform teams of command center.

4. Assess damage as a result of crisis 5. Ascertain viability of continuing business in current location or determining

alternate location

6. If alternative location is used communicate to corporate office employees the location and identify employees who can work remotely and those who should report to the alternate location. Those employees who are not identified as remote employees will be told to report to new location or remain not working at home until further directives are given.

7. If it is determined that contents from 401 E. City Avenue, Suite 820 can be

retrieved, request each department head to list contents to be retrieved.


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8. If access to 401 E. City Avenue, Ste. 820 is denied, confirm internet access at alternate location and confirm e-mail server functionality to enable essential business functions to continue, (i.e., payroll, HR)

9. If corporate phone system is inoperable inform all employees of communication method to use.

10. Send communication to all VPO’s and department heads with status of office, means of communication and request notices be sent to all Liberty locations, clients and employees.

11. Notify insurance broker, Willis, to report claim BCP Objectives Liberty’s objective is to respond to a Significant Business Disruption (SBD) by safeguarding employees’ lives and firm property, making a financial and operational assessment, quickly recovering and resuming operations, protecting all of the firm’s books and records, and allowing our customers to transact business. In the event that we determine we are unable to continue our business, we will assure customers prompt access to our executive leaders.

Significant Business Disruptions (SBDs) Our plan anticipates two kinds of SBDs, internal and external. Internal SBDs affect only Liberty’s ability to communicate and do business, such as a fire in our building. External SBDs prevent the operation of business lines or a number of our business lines such as a terrorist attack, a city flood, or a wide-scale, regional disruption. Our response to an external SBD relies more heavily on several organizations and systems, especially on the capabilities of our local business lines.

Approval and Execution Authority The Vice President of Human Resources is the owner of the Business Interruption planning process and has the authority to initiate this plan. The Vice President, Human Resources or their designee is responsible for conducting the required annual review. The Chief Financial Officer and the Senior Vice President/Chief Operating Officer are responsible for approving the plan.

Plan Location and Access Liberty Healthcare Corporation shall maintain copies of this BCP plan and the annual reviews, and the changes that have been made to it. An electronic copy of our BCP is located on the Intranet and the Shared Drive, Operations, Active Contracts, Liberty QualityCare®, Business Continuity. Office Locations


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Office Location #1

Our Location #1 Office is located at 401 E. City Avenue, Suite 820, Bala Cynwyd, Pa. 19004-1155. Its main telephone number is 610.668.8800. Our employees may travel to that office by means of motor vehicle, hired car (e.g. taxi) or public transportation. We engage in the business line services at this location and serves as the centralized call center for business interruptions at Liberty. Alternative Physical Location(s In the event of an SBD, Liberty shall identify a recovery strategy for relocation to alternate premises. Liberty shall coordinate with program leadership to move staff from an affected office(s) to the closest unaffected office location(s). If none of our other office locations is available to receive those staff, we will move them to an established location (e.g. another selected rental property). Liberty’s leadership contact is Camille Tanner, vice president, human resources, 215.813.7437. Customers’ Access to Services In the event of an internal or external SBD, Liberty Healthcare Corporation shall work in tandem with our customers to provide administrative leadership until our services can be fully restored. If a business line executive determines that we are unable to meet our obligations to our customers, the vice president of operations shall be notified immediately with a cc to Sue Nayda, senior vice president/chief operating officer to review strategies and options. Data Back-Up and Recovery (Hard Copy and Electronic) Liberty Healthcare Corporation maintains its primary hard copy books and records and its electronic records at 401 City Avenue, Suite 820, Bala Cynwyd, Pa., 19004-1155. Liberty Healthcare Corporation’s security officer Eli Back, 610.389.7440 is responsible for the maintenance of these books and records on a data backup system for recovery. Eli Back, 610.389.7440 is responsible for the maintenance of these back-up books and records. The firm backs up its electronic records daily and keeps a copy at a location designated by our security officer. In the event of an internal or external SBD that causes the loss of our paper records, we will physically recover them from our back-up site. If our primary site is inoperable, we will continue operations from our back-up site or an alternate location. For the loss of electronic records, we will either physically recover the storage media or electronically recover data from our back-up site, or, if our primary site is inoperable, continue operations from our back-up site or an alternate location. Supporting Technical infrastructure and Mission Critical Systems Liberty Healthcare Corporations “mission critical systems” are those that ensure prompt and accurate processing of our contract deliverables and the delivery of services and administration of our programs. This would include but is not limited to the Network, Servers, Databases, Applications and Voice Communications. During a SBD, reconstruction


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and re-configuration of all Liberty critical applications and supporting technical infrastructure may be required. Eli Back at 610-389-7440 would be the key contact if such reconstruction was required. We also have primary responsibility for establishing and maintaining our business relationships with our customers and have sole responsibility for our mission critical functions. If we reasonably determine that our leadership has not or cannot put its business continuity plan in place quickly enough to meet our customer needs, or is otherwise unable to provide access to our contracted services, our executive leadership shall assist in seeking alternative plans. Executive leadership shall work with the operating program if a geographically separate area with the capability to conduct the same volume of business as its primary site is required. Our vice presidents of operations and program directors confirm the effectiveness of its back-up business continuity planning to recover from a wide scale disruption by testing, and it has confirmed that it tests its back-up arrangements annually. Recovery-time objectives provide concrete goals to plan for and test against. They are not, however, hard and fast deadlines that must be met in every emergency situation, and various external factors surrounding a disruption, such as time of day, scope of disruption and status of critical infrastructure—particularly telecommunications—can affect actual recovery times. Recovery refers to the restoration of clearing and settlement activities after a wide-scale disruption; resumption refers to the capacity to accept and process program services after a wide-scale disruption. Recovery time and resumption objectives: recovery time period of within 8 hours; and resumption time of within the same business day. Vice presidents of operations and our service vice presidents will periodically review our program’s capabilities to perform the mission critical functions. Financial and Operational Assessments

Operational Risk

In the event of an SBD, we will immediately identify what means will permit us to communicate with our customers, employees, critical business constituents, critical banks, critical counter-parties and regulators. Although the effects of an SBD will determine the means of alternative communication, the communications options we will employ will include our intranet, our website, our telephone voice mail and our secure email. In addition, we will retrieve our key activity records as described in the section above, Data Back-Up and Recovery.

Financial Risk

In the event of an SBD, Tom McParland, chief financial officer, 6 10.389.7432 and Shirley Greenlee, controller, 610-585-9627 shall determine our ability to continue to provide clinical and administrative operations. If they determine that Liberty Healthcare Corporation may be unable to meet our obligations to customers, they shall notify Sue Nayda, senior vice president/chief operating officer, 610.389.7425 who in turn shall contact the president and the general counsel.

Analysis of Insurance Coverage


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In the event of an SBD, Tom McParland, chief financial officer, 6 10.389.7432 and Shirley Greenlee, controller, 610-585-9627 shall analyze the insurance coverage for the specific disaster to ensure that adequate funding for the execution of the BCP is available.

Alternate Communications between the Firm and Customers, Employees, and Regulators

A. Customers Liberty Healthcare Corporation (Liberty) communicates with our customers using telephone, encrypted email, and our website, fax, U.S. Mail and in-person visits at our programs at other locations. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party. For example, if we have communicated with a party by email but the Internet is unavailable, we will call them on the telephone and follow up where a record is needed with paper copy in the U.S. mail. B. Employed staff and subcontracted physicians We now communicate with our employed and physician subcontracted staff using cell phones, smartphones, texting, encrypted email, our website, fax, U.S. Mail and in-person visits at our programs at other locations. In the event of an SBD, we will assess which means of communication are still available to us, and use the means closest in speed and form (written or oral) to the means that we have used in the past to communicate with the other party. We will also employ a communication tree so that senior management can reach all employees quickly during an SBD. The communication tree includes the identified key communication method for each key staff member. The persons to invoke use of the communication tree is: Camille Tanner and Sue Nayda

Communication Method Communication Recipients See above Specific Plans for our Major Functional Areas: Payroll: In the case of a Business Continuity interruption, Payroll’s contact is Debi Snyder, Payroll Manager: Home: (215 442 9731) Cell: (215 694 6891) email: [email protected] Alternate Contact: Maxine McBride, Payroll Administrator Cell: (215 275 2694) In case of a Business Continuity interruption due to inability to access our current work location, below are the items we would need to function out of an emergency site.

1. Two laptops set up to access Liberty servers along with complete email access. 2. One printer 3. Access to Personal (Snyder 484-434-1540)and payroll (610-617-3792)fax numbers


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4. One calculator 5. Two phones 6. Shredder (not immediate)

SYSTEMS 1 ICON 2 Workforce Management 3 Employee Self Service 4 Fidelity

WEB ADDRESS AND PHONE NUMBERS TO ALL SYSTEMS AND SUPPORT STAFF

1. (ICON) http://mgr.unicornhro.com 2. (WFM) https://secure.saashr.com/ta/2629.login 3. Pay Support email: [email protected] 4. Pay Support contact and phone number: Julia Richard – 919-544-5008 ext. 1106 5. WFM support email: [email protected] 6. WFM support contact and phone number: Elizabeth McDonald – 713-589-5506 7. Unicorn Cash Dept: Cash Dept email: ([email protected]) 8. Unicorn Cash Dept. contact and phone number: Shelly Cowans – 919-361-3704 9. Unicorn Tax Support: Tax Support ([email protected]) 10. Unicorn Tax Support contact and phone number: Linda Johnson – 919-544-5008 ext. 1110 11. Employee Self Service: http://emp.unicornhro.com

Accounting: See VIII- Financial & Operational Assessments Human Resources:

Business Continuity Plan: Human Resources – Corporate Office Plan Owner: Camille Tanner, VP- HR Phone Number(s): cell (215-813-7437) home (610) 446-7959 Date Created: 5/17/2016 Date Revised: 5/17/2016 Responsibilities of Plan Owner:

6. Reviews and updates plan quarterly. 7. Keeps hard copy of plan on site and in shared drive. 8. Keeps hard copy offsite (home location) 9. Keeps soft copy on Flash Drive

IN CASE OF DISASTER: Follow the steps listed below and track when completed in the event of discovery or notification of a disaster. A disaster is defined as any event at a Company location which:


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• Results in a disruption of some or all business operations at the site • Leads to a decision to mobilize a portion or all of the Business Continuity Organization • Causes initiation of recovery of some or all of the interrupted operations at an alternative site.

Task Required Action Status

Completed/Pending Date and Time Completed

2. Notify COO, Sue Nayda, via cell phone at 610-389-7425 and provide description of event (unless already contacted by the Emergency Response Team)

Notify CEO, CFO 610-389-7432, General Counsel 610-389-7428 and Director of IT610-389-7440 or 443-850-8775

2. Notify direct reports: Kelly Hunsicker 610 804-3631, Rena Smith 484 477-2086 of situation and not to report to work until further instructions are given. Instruct direct reports to contact their direct reports.

3. Notify Insurance Brokers – Management Care Consultants 610-254-8099 of situation to notify insurance carriers, if necessary

4. If crisis occurs during working hours, conduct head count and identify missing individuals. Inform authorities of personnel who are missing so that search and rescue and can take place.

5. HR will monitor employee injuries and notify emergency contacts. Continue communication with authorities and employee/families

4. If message is received from Emergency Response team that an alternative location is required, inform direct reports of location and who will be required to work from alternate location. Determine employees who can work remotely and inform them of duration of time this will continue

5. If it is determined that contents from 401 E. City Avenue, Suite 820 can be

retrieved, request computers, printers and fax machine. Identify any physical files that should be retrieved from location.

6. If access to 401 E. City Avenue, Ste. 820 is denied, confirm internet access at alternate location for access to Unicorn and confirm e-mail server functionality.

7. If corporate phone system is inoperable inform all employees of communication method to use.

8. Send communication to all VPO’s and department heads of status of office, means of communication and request notices be sent to all Liberty locations, clients and employees.


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IT: See VI- Data Backup and Recovery Marketing and Development: Following are the goals of a disaster recovery plan with respect to marketing operations:

• minimize interruptions to the normal operations (i.e. proposal deadlines) • limit the impact and extent of disruption • establish alternative means of operation • communicate emergency procedures with employees in advance

Following are Liberty Healthcare’s marketing personnel:

Name Position Telephone (M) Telephone (H) Alt Email Address Trish Piontek Director, Marketing (610) 310-7120 (610) 827-0717 [email protected]

Mike LePostelec Tess Ulloa In the event of a disaster the Director, Marketing will notify personnel listed above via phone and email to communicate:

• degree of the disaster • anticipated timeline for restoration of normal operations including access to shared files, email, voicemail, etc. • need to report to an alternate location or otherwise remote location • availability of shared document files and alternate instructions for access (including files stored on SharePoint) • availability of email, voicemail, etc. • company phone number for updates on the status of the organization’s operational recovery

Following the communication of this information the Director, Marketing will confirm with EVP, communication with all direct reports. In the event of a disaster the marketing department would need to access to following to ensure continuity of operations:

• Liberty Healthcare shared drive • Liberty Healthcare SharePoint site

Performance/Competency Evaluation/Corporate Compliance: Following are the goals of a disaster recovery plan with respect to Performance/Competency/Corporate Compliance/HIPAA:

• minimize interruptions to the normal operations (i.e. competency benchmarks) • limit the impact and extent of disruption • establish alternative means of performing this functional area’s responsibility • communicate emergency procedures with employees in advance

Following are Liberty Healthcare’s Competency Evaluation personnel:

Name Position Telephone (M) Telephone (H) Alt Email Address


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Name Position Telephone (M) Telephone (H) Alt Email Address Judith Ann Shields Vice President,

Performance/Corporate Compliance Officer/HIPAA Privacy Officer

(610) – 389 - 7434 (610) – 825-5509 [email protected]

Alba Rushiti Supervisor, Credentialing Abby Yankawitz Associate, Credentialing

In the event of a disaster the vice president, performance will notify the credential associate who shall then contact the credential supervisor via phone and email to communicate:

• degree of the disaster • anticipated timeline for restoration of normal operations including access to shared files, email, voicemail, etc. • need to report to an alternate location or otherwise remote location • availability of email, voicemail, etc.

Following the communication of this information the vice president, performance will confirm with vice president, Human Resources, communication with all direct reports. In the event of a disaster, the competency evaluation work group would need to access to following to ensure continuity of operations:

• Liberty Healthcare shared drive • Laptops with Internet Access • Liberty Healthcare Unicorn

Legal Following are the goals of a disaster recovery plan with respect to legal:

• minimize interruptions to the normal operations (i.e. contract agreements) • limit the impact and extent of disruption • establish alternative means of performing this functional area’s responsibility • communicate emergency procedures with employees in advance

Following are Liberty Healthcare’s Competency Evaluation personnel:

Name Position Telephone (M) Telephone (H) Alt Email Address Todd Mammuth General Counsel (610) – 389 - 7428 (610)-525-7997 [email protected] Cathy Oblea Director, Legal Support Melinda Makoid Associate, Legal Kathy Gerhart Associate, Legal

In the event of a disaster General Counsel will notify the Director, Legal Support who in turn shall notify the associate, legal via phone and email to communicate:

• degree of the disaster • anticipated timeline for restoration of normal operations including access to shared files, email, voicemail, etc. • need to report to an alternate location or otherwise remote location


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• availability of email, voicemail, etc. Following the communication of this information General Counsel will confirm with the vice president, Human Resources, communication with all direct reports. In the event of a disaster, legal would need to access to following to ensure continuity of operations:

• Liberty Healthcare shared drive • Liberty Healthcare Unicorn

Critical Business Constituents

Business constituents

We will contact our critical business constituents (businesses with which we have an ongoing commercial relationship in support of our operating activities, such as vendors providing us critical services), and will determine the extent to which we can continue our business relationship with them in light of the internal or external SBD. We will quickly establish alternative arrangements if a business constituent can no longer provide the needed goods or services when we need them because of a SBD to them or our firm. Updates and Annual Review Liberty Healthcare Corporation shall update this plan whenever we have a material change to our operations, structure, business or location or to those of our clearing firm. In addition, our firm will review this BCP annually, in January, to modify it for any changes in our operations, structure, business or location or those of our clearing firm. Signatures of Approval: Chief Financial Officer Senior Vice President/Chief Operating Officer Approval We have approved this Business Continuity Plan as reasonably designed to enable Liberty Healthcare Corporation to meet its obligations to customers in the event of an SBD. Signed: _______________________________ Title: Chief Financial Officer Date: _______________________________

Signed: _______________________________ Title: Senior Vice President/Chief Operating Officer Date: _______________________________


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