Veterinary HR failures happen every day. Holdsworth & Co., CPA’s support Veterinary Practices in every function of business management including Accounting, Operational Efficiency, HR consulting and financial planning. To assist our clients in limiting liability of Veterinary HR issues, we have compiled a best practices reference so that your practice is dotting the i’s and crossing the t’s when it comes to personnel files.
Managing personnel files like a BOSS
An organized and compliant Personnel File system is possible. To start, have a pre-determined maintenance plan:
- Determine if your personnel files will be maintained as paper or electronic files, we recommend you choose one; a hybrid system can be difficult to track.
- Ensure the files are secure – this will mean paper files are stored in a locked cabinet(s). Electronic files will require password protection and an offsite backup system at minimum.
Next, plan your file organizational structure:
Employment Files: Job postings, interview notes, reference checks, applications, resumes, handbook acknowledgement. Be sure to exclude information that is not relevant to the hiring decision such as protected information: EEO data, SSN, arrest records etc.
Payroll Files: Federal and State withholding forms, time keeping records, wage records, garnishments and wage deduction forms.
Performance Files: Evaluations, Client/Team acknowledgements, performance improvement plans and disciplinary action records.
Training Files: Training program records, training certificates and safety training records.
Medical: Worker’s compensation records, medical leave records, health insurance information and records concerning visits or payments to any healthcare professional.
Confidential Files: Background checks, drug testing, credit checks etc.
Investigation Files: Maintained as one practice file as they generally include more than one team member. Only information that is found to be relevant and results in individual documentation should be filed in a team member’s performance file.
EEO Records: EEO data collection is generally completed by private employers with 100 or more employees. Data collection related to EEO should never be included in a team member’s personnel file.
I-9 Files: Maintained as practice file, we recommend one for current employee and one for terminated employees. Access should be HIGHLY restricted. It is important to have a comprehensive audit process to ensure compliance. http://www.uscis.gov/i-9
Terminated Employee Files: Each file relating to a terminated employee should be relocated to a central secure location (excluding I-9, see above). Your practice should have a written policy specifically addressing:
- File Maintenance
- Retention Guidelines
- Destruction Guidelines
- Extended Maintenance Plans – worker’s compensation claims/lawsuits
- Rehire records Policy
It is important to consider your veterinary practice’s size and location to determine applicable Federal and State laws when developing your Personnel File Policy.
Your organizational structure will need to consider appropriate access and storage locations. A written policy will address the levels of your leadership structure. Document clearly who has access to what files and when. This will help you determine what files may be appropriate to store in the same location and which files must be located in another location. Be sure to include employee access procedures to ensure your practice applies and follows a consistent policy regarding employee access.
Organization is imperative. We recommend a file master form and chronological order filing for ease of locating documents quickly.
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