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OPM FORM 652 1/79
Attachment to FPM Letter 792-9
TABLE OF CONTENTS
III. PROGRAM RATIONALE
A. Earlier Identification and Treatment
B. Wider Range of Treatment
C. Integration of Programs into the Management System
D. Stimulus to Self Referrals
IV. PROGRAM GUIDELINES
A. Program Support and Endorsement
B. Relationship with Labor Organizations
C. Role of the Personnel Office
D. Role of Program Administrators and Coordinators
F. Relationship to Disciplinary Actions
G. Role of the Supervisor
H. Scope of Program
I. Community Resources
J. Cooperative Programs
V. MAINTENANCE OF RECORDS AND REPORTS
A. Maintenance of Records/Confidentiality
Attachment to FPM Letter 792-9
A. Public Laws 91-616 of December 30, 1970, and 92-255 of March 21, 1972, as amended
by Public Law 93-282 of May 14, 1974, provide that the Civil Service Commission (now
Office of Personnel Management) shall be responsible for developing and maintaining, in
cooperation with the Secretary (Of HEW) and with other Federal departments and agencies,
appropriate prevention, treatment and rehabilitation programs and services for Federal
civilian employees with alcohol or drug problems, respectively. The Office of Personnel
Management's policies and guidelines for implementing these programs are contained in
FPM Subchapter 792-5, FPM Supplement 792-2, and FPM Letter 792-8, dated August 25, 1977.
B. Public Law 79-658 (5 U.S.C. 7901), approved August 8, 1946, authorized heads of de-
partments and agencies to establish health service programs for the purpose of promoting
and maintaining the physical and mental fitness of employees of the Federal Government
and authorized agencies to contract for these programs.* (1)
This issuance transmits to the heads of departments and agencies guidelines for incor-
puriting the Federal Civilian Alcoholism and Drug Abuse Programs into a management sys-
tem for dealing with a broader range of medical-behavioral problems. Problems en-
visioned by these guidelines include: alcohol and drug abuse, personal/emotional,
financial, marital, family, legal, etc. Problems concerning equal employment, upward
mobility, and grievances, are not covered, but it is advisable to coordinate programs
relating to them with employee counseling services programs since personal problems of
any sort tend to overlap and impact on one another. This letter supplements, but does
not supersede, FPM Subchapter 792-5, and FPM Supplement 792-2. It is to be used with
these issuances, since much material contained in them is applicable to ECS programs
but is not repeated here.
These guidelines are not intended to reduce, in any way, efforts to combat alcoholism
and drug abuse, but rather to increase their effectiveness. As in the guidelines for
alcoholism and drug abuse, there is latitude for each department and agency to develop
programs adapted to specific settings and individualized agency needs.
III. PROtRAM RATIONALE
Programs dealing with a wide range of employee problems which adversly impact on job
performance offer at least four distinct benefits not characteristic of the narrower
substance abuse programs. These are: A. Earlier Identification and Treatment; B.
Wider Range of Treatment; C. Integration of Programs into the Management System; and
D. Stimulus to Self-Referrals.
A. EARLIER 1L)E:ILIFLCATION AND INTERVENTION
It is generally conceded that the probability of success in dealing with any medical,
behavioral or emotional problem is vastly increased if it is recognized and treated
in its early stages before it has irreparably damaged the physical, mental or emo-
tional well-being of the individual. The earliest indicators of alcoholism, for ex-
ample, are not the familiar "tell-tale odor," "slurring of speech," "poor motor tunc-
tion," "tremors," etc. Rather, the earliest signs on the job are such indicators as
absenteeism, declining work performance, and poor interpersonal relations. These are
behavior patterns that the supervisor is trained and expected to recognize and act
upon. The supervisor is not, however, trained or expected to determine underlying
causes or to recommend treatment.
*(i) See CG Decision B-187074, November 7, 1977; also OMB Circular A-72, June 18, 1965.
Attachment to FPM Letter 792-9 (3)
Clearly, though, it's advisable that someone be in a position to assist the employee in
problem identification and recommend proper treatment if problems are not to progress
to the point where damage is so great that chances for rehabilitation are minimal. That
this "someone" is not the supervisor is recognized in most Alcoholism and Drug Abuse
programs. Often, nevertheless, a supervisor has been placed in the position of la-
beling an employee, implicitly, by referring him to the only sources) of help avail-
able, viz., alcoholism/drug abuse programs. When faced with this prospect, the super-
visor may (1) back away from any referral whatsoever, or (2) take immediate disciplinary
action without benefit of any counseling. Both of these responses are self defeating.
The first simply prolongs the problem, the second lays the agency open to possible re-
versal of the disciplinary action, if it is later determined that the employee had a
drinking or drug problem.
B. WIDER RANGE OF TREATMENT
While some supervisors, as indicated above, avoid referral to a program labelled
alcoholism or drug abuse, others, lacking alternatives, will refer employees who are
suffering from a wide range of other problems. Unless a further referral is then
made, the employee is likely to get little help for medical, emotional, financial,
marital problems, etc. In addition, employees with primary problems relating to
alcohol or drug abuse usually have secondary problems, such as those noted above, for
which they need help if they are to resume proper functioning on their jobs. Adop-
tion of a coordinated range of services through a broad medical-behavioral approach
is geared to meeting these needs.
C INTEGRATION OF PROGRAMS INTO THE MANAGEMENT SYSTEM
A broad Employee Counseling Services Program can consolidate what might otherwise be
a splintered effort by management to deal with problem employees (e.g. an alcohol pro-
gram, drug program, a personnel counseling program, and a health unit). Also, be-
cause other segments of the organization can often be useful in case identification, it
is strongly recommended that the employee counseling service program utilize and
be coordinated with various personnel and other management functions (e.g. training,
performance evaluation, disciplinary and grievance systems, medical, safety and secur-
ity, EEO, employee organizations, women's programs, etc.) It's also advisable that
these functions be fully knowledgable of the goals of the Employee Counseling Services
Program and provide support to it.
D. STIMULUS TO SELF-REFERRALS
Often, employees are aware that they are in trouble long before their problems come
to the attention of their supervisors and co-workers. They may be seriously con-
cerned about the way things are going in their lives, but unable to accurately pin-
point underlying causes. They may be reluctant to approach their supervisor, but
uncertain about who else to turn to for help. Such employees, offered the services
of a strictly confidential general counseling service, may well avail themselves of
an opportunity to get help before supervisory pressure becomes necessary.
IV. PROGRAM GUIDELINES
A. PROGRAM SUPPORT AND ENDORSEMENT
The support and endorsement of top management is vital to the success of an Employee
Counseling Services Program. This support will be reflected in a policy statement
signed by the head of the department, agency, bureau, post, etc. Policy statements
and program planning are most effective when they are developed by a committee of those
most directly concerned, rather than unilaterally by one individual or segment of the
organization. Typically, such a team might include, along with the employee counseling
services coordinator, the Director of Personnel, Training Director, Chief of Health/
Medical Services, union appointed representativess, and, where appropriate, employees
Attachment to FPM Letter 792-9
who, as a result of their personal rehabilitation and/or experience, have become
effective in helping others. We recommend that policy statements closely follow the
statements suggested for alcoholism/drug abuse programs (See FPM Supplement 792-2,
Sl-3) with appropriate variations.
B. RELATIONSHIP WITH LABOR ORGANIZATIONS
The support and active participation of labor organizations will be a key factor in
the success of any employee counseling services program. Therefore, agencies are re-
minded of their obligations under Title VII, P.L. 95-454, to negotiate, when appro-
priate, with those unions which have been accorded exclusive recognition, or consult,
when appropriate, with those unions which have consultation rights, in formulating
and implementing ECS policies and programs.
In many instances, union officials and stewards have the confidence of the employees
they represent and can be very influential in creating employee cooperation and support.
Therefore, it is advisable to have them participate in briefings and other joint en-
deavors involving managers, as a means of fostering common understanding and joint
support of the program.
Union officials, stewards, members, etc. may be effective when trained as ECS Coun-
selors. In addition to an added credibility with employees as a result of their
union affiliation, such persons may also possess natural talents as counselors and/or
experiences or training which equip them for these duties.
C. ROLE OF THE PE:RSONIIEL OFFICE
We recommend that the personnel director and his organization be assigned program de-
velopment, implementation, and review responsibilities consistent with other personnel
management functions. As noted in section IVA, however, this responsibility may be
shared with other segments of the organization as well as concerned individuals (train-
ing, medical/health, persons with experience qualifications, etc.) and a "team" approach
A major goal of broad Employee Counseling Services Programs is to bring medical/be-
havioral assistance to employees into the mainstream of personnel management. It
is the responsibility of the personnel office to identify and assist employees with
problems. Systems relating to discipline, grievances, union relations, position
classification, placement, etc., are a means of identifying persons with work-related
problems (e.g. absenteeism, security violations, difficulties with co-workers,
etc.). Once identified, these employees can be referred to the Employee Counseling
Services Program through a clearly established channel of referral.
While we consider the program to be a part of progressive personnel management, it is
also true that many employees, with or without basis, may view it with distrust
for this very reason. They may fear that confidentiality of records will not be
maintained and that records of their meetings with counselors may become a part of
their Official Personnel File, and subsequently be used against them. It is important
that the program be carried out in such a way as to allay these fears and to increase
employees' confidence and partipation in the program,
D. ROLE OF PROGRAM ADMINISTRATORS AND COORDINATORS
The responsibilities of Employee Counseling Services Program administrators and
coordinators are the same as those for Alcoholism/Drug Abuse Program administrators
and coordinators (see FPM 792-5-4). Where previously assigned Alcoholism/Drug Abuse
Program administrators and coordinators have functioned effectively, it is appropriate,
in most instances, to designate them as the ECS Program administrators and coordinators.
Attachment to FPM Letter 792-9
Program personnel will continue to receive specialized training in these two illnesses.
It is also important, however, that employees in these positions be able to relate to
a broad span of personal and emotional problems and to an equally wide range of commu-
nity resources. We recommend that their focus not be confined to alcoholism/drug
abuse problems. We strongly recommend that those individuals selected receive contin-
uing training to provide them with a broad background in a range of personal and emo-
tional problems, coupled with a specific knowledge of alcoholism and drug abuse.
It's advisable that the organizational location of persons in a counseling/referral
role be compatible with their function. It will, for example, be difficult to main-
tain program credibility if the counselor also has responsibility for, or is closely
aligned with, disciplinary procedures.
Evaluations of alcoholism and drug abuse programs have consistently shown that many
agencies have not allowed program personnel sufficient time to implement effective
programs. It is important that programs be closely monitored to insure that adequate
time is allowed to produce a functioning program.
The effects of social and moral stigma associated with alcoholism and drug abuse en-
courage victims of either of these addictions to deny their primary problem. As a
result, they typically will go to great lengths to convince supervisors, coordinators,
counselors, etc. that their problem is something other than alcoholism or drugs. It
is important that the person in the agency to whom the client is referred for assist-
ance be qualified and trained in alcoholism and drug addiction, so that he or she can
accurately determine whether or not alcoholism or drugs are involved. Otherwise the
client may be successful in concealing the primary problem and effective treatment will
be delayed while focusing rehabilitation efforts on marital, financial or other prob-
lems that are actually caused by alcoholism or drugs.
F. RELATIONSHIP TO DISCIPLINARY ACTIONS
The purpose of the ECSP is to assist employees to correct their unacceptable conduct
or performance. A successful ECSP may avoid certain actions adverse to the employee
which otherwise might have to be taken.
Removal and Reduction in grade based on unacceptable performance. (Part 432 of OPM's
Chapter 43 of the CSRA provides that the performance appraisal systems) of an agency
shall provide for assisting employees in improving unacceptable performance and for
reassigning, reducing in grade, or removing employees who continue to have unaccept-
able performance -- but only after an opportunity to demonstrate acceptable perfor-
mance. The ECSP may well be utilized by the agency in meeting these statutory criteria
before an action based on unacceptable performance is effected.
Adverse actions (Part 752)
The adverse action regulation covers suspension, removal, and reduction in grade or
pay taken for such cause as will promote the efficiency of the service. Depending
on the circumstances of a particular situation, it may be appropriate to offer assis-
tance to the employee to help him or her overcome unsatisfactory conduct as an alter-
native to disciplinary action. On the other hand, it may be in the best interests of
the Government for the agency to initiate action, at the same time that assistance is
offered. We want to stress that such an offer of assistance made concurrent with
Attachment to FPM Letter 792- 9
the initiation of a disciplinary action, does not stand in the way of or shield the
employee from the disciplinary action, We realize that there are instances where
assistance has been offered earlier to the same employee to little or no avail. Per-
haps the agency may be unable to make a meaningful offer of assistance in some sit-
uations (e.g. where the employee has been jailed, or in emergency situations where
the employee must be removed immediately from a duty status). The agency will need
to decide whether a meaningful contribution can be made to the employee's welfare
by an offer of assistance in extreme circumstances such as those above. By all
means, offer it, when appropriate.
G. ROLE OF THE SUPERVISOR
The role of the supervisor in an Employee Counseling Services Program is essentially
the same as in an Alcoholism/Drug Abuse program. The broadening of the program
should result in even greater help to the supervisor in dealing effectively with a
wide range of performance problems. As soon as it is determined that ordinary super-
visory methods are not bringing about improvement, it's a good idea for the super-
visor to consult the ECS program coordinator for advice on how to proceed. The pro-
gram coordinator (or other contact) can then recommend to the supervisor whether or
not a confrontation with and/or referral of the employee to the program is advisable
and, if so, how to prepare for it and carry it through. In some cases, for a variety
of reasons, the advice given the supervisor may lead directly to a solution of the
problem, without a confrontation or referral of the employee ever becoming necessary.
Training for supervisors is essential if they are to effectively utilize the Employee
Counseling Services Program. Where employees are represented by unions it is highly
desirable to train supervisors and employee representatives jointly.
H. SCOPE OF PROGRAM
As indicated in section II, the scope of problems envisioned by these guidelines in-
clude: alcohol and drug abuse, personal/emotional, financial, marital, family, and
legal problems. A special word is necessary about family problems. Often employees
who are not alcoholics, drug abusers or suffering from any specific neurotic or psy-
chotic disorder are, nevertheless, "troubled" by family members who suffer from any,
or a combination of the above conditions. Family members who are alcoholic, for ex-
ample, can cause employees acute emotional stress and sometimes even physical harm
(e.g. the "battered person" syndrome). These conditions inevitably impact on an em-
ployee's job performance, in much the same way that they would if the employee had
an alcohol, drug or other problem himself. Absence from work, lateness, lack of con-
centration, irritability, sloppy work, etc. may indicate a problem family member.
This does not mean that the employee does not need help. On the contrary, he or she
needs assistance at least as much as does the family member with the alcohol, drug,
or other problem. While, ideally, the entire family (or at least both partners)
should be referred to treatment, this sometimes may not be possible.
Referral to treatment of an employee whose performance is affected by the medical/be-
havioral problem of a family member, should be handled in the same way as any other
client referral. The performance problem is his or hers, as well as the obligation
to correct it. If, after assistance is offered, performance does not improve, con-
tinuing assistance, combined with disciplinary action may be appropriate.
I. COMMUNITY RESOURCES
It's advisable that Employee Counseling Services Programs be closely linked to communi-
ty resources. We recommend that program administrators and coordinators determine
which agencies or individuals can offer screening and/or diagnostic services. It's
good practice, too, to learn about admission requirements, agency function, provisions
Attachment to FPM Letter 792-9 (7)
for referral and follow-up, types of treatment provided, treatment staff's composition
and qualifications, socio-economic status of clientele, costs and fee schedules, and
insurance coverage. In addition, it's advisable that communications and relation-
ships be established with specialized resources such as the following:
State alcoholism and drug abuse authorities
State mental health authorities
Councils on Alcoholism and Drug Abuse
Alcoholics Anonymous, Al-Anon, and Alateen
Other self-help groups for medical/behavioral/emotional problems (e.g. Gamblers
Anonymous and Narcotics Anonymous)
Local mental health associations
Hospitals and other inpatient treatment facilities
Clinics and other outpatient treatment facilities
Family counseling services
Financial counseling services
J. COOPERATIVE PROGRAMS
While the program outlined above is simple and cost effective, it assumes the assign-
ment of qualified personnel and an investment in staff time sufficient to produce
results. A problem, especially for all but the very largest agencies, is how to
get the expertise to do this and how to bear the expenses of the program.
One approach that has been used with success is a cooperative effort, sometimes called
a consortium, through which Federal activities in close geographic proximity bear
jointly the expense of an Employee Counseling Services Program. In some cases, one
agency might share its resources with other agencies on a reimbursable basis. In most
cases, a group of agencies will contract with an outside organization for the services.
This approach eliminates the need of each participating agency to develop or obtain
its own counseling capability; and, therefore, aside from lending more assurance that
employees will have access to qualified counselors, it is usually less costly.
The services furnished through such a cooperative program can include advice in devel-
oping policies and procedures, supervisory training, employee education programs,
counseling for supervisors with problem employees, and counseling for employees them-
If you are interested in participating in or helping to start a cooperative program
in your area, call one of the following for technical assistance:
1. Occupational Health Representatives (OHR's), located at OPM regional offices in
the following cities: Boston (Maine, New Hampshire, Vermont, Massachusetts, Connecti-
cut, and Rhode Island), New York (New York, Puerto Rico, New Jersey, and Virgin
Islands), Philadelphia (Pennsylvania, Delaware, Maryland, Vriginia, and West Virginia),
Atlanta (North Carolina, South Carolina, Georgia, Florida, Alabama, Mississippi,
Tennessee, and Kentucky), Chicago (Minnesota, Michigan, Wisconsin, Illinois, Indiana,
and Ohio), St. Louis (Kansas, Missouri, Iowa, and Nebraska), Denver (Wyoming, Mon-
tana, North Dakota, South Dakota, Colorado, and Utah), Seattle (Alaska, Washington,
Oregon, and Idaho), San Francisco (California, Nevada, Hawaii, and Arizona), Dallas
(Texas, Arkansas, Louisiana, New Mexico, and Oklahoma).
or (for Washington, D.C. metropolitan area):
2. Alcoholism and Drug Abuse Program
Occupational Health, Room 233K
UNIVERSITY OF FLORIDA
Attachment to FPM Letter 792-9 (8) 11111I III III111111111111111111
3 1262 08741 9460
1900 E. Street, NW
Washington, DC 20415
V. MAINTENANCE OF RECORDS AND REPORTS
A. MAINTENANCE OF RECORDS/CONFIDENTIALITY
The confidentiality of information maintained about Employee Counseling Services Pro-
gramo-articipants with drug and alcohol problems is protected by statute (PL 93-282)
and regulations (42 CFR 1A2) contained in FPM Letter 792-8, dated August 25, 1977.
As a general rule, information about participants, whether or not recorded, is con-
fidential. It may only be disclosed as authorized in the regulations.
The regulations also prohibit implicit and negative disclosures. "The disclosure that
a person....is not or has not been attending a program.... is fully as much subject to
the prohibitions....as a disclosure that such a person is or has been attending such
a program. Any improper or unauthorized request for any disclosure of records or in-
formation subject to this part must be met by a noncommittal response" (2.13 (e) ).
This means that agencies running broad Employee Counseling Services Programs must
adhere to the confidentiality requirements cited above in dealing with information
about all program participants, so as to prevent implicit or negative disclosures
about participants with alcohol or drug problems.
The reporting requirements cited in FPM Supplement 792-2 (Subchapter S6-1C), have
been adapted to allow agencies to include counseling activities other than those
related to drug and alcohol problems.
U. S. GOVERNMEN\ ,'IHL.NING OFFICE : 1979 0- 280-535 (159)
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