EZ Messenger Staff - Subcontractor(Vendor) Management Policy

Policy Name: Subcontractor Management Policy

Lauch Date: 5/4/2020

Author Name: Gerri Gentilquore

Author Title: Director of Compliance

Version: 1.0

1. Purpose

The Subcontractor Management Policy outlines the methods by which EZ Messenger will assure that In Network subcontractors (Independent Contractors or Process Servers) comply with all appropriate laws, regulations, contract specified qualifications, and professional standards.

2. Responsibilities

Operations Department

Compliance Department

3. Escalation Point of Contact

Director of Compliance

4. Policy

Subcontractors will be provided a contract that defines the responsibilities, duties, and constraints of each party, as well as the appropriate terms and conditions to be imposed on both EZ Messenger and the Subcontractors. Formal and informal methods of contact with Subcontractors will be documented when possible and applicable. When possible, contact with Subcontractors will be in written format. Subcontractors will be given authorization to proceed with assigned work only after all contractual, legal, or professional requirements have been met and appropriate documentation is submitted to EZ Messenger. This documentation must be updated prior to expiration and is expected to be maintained in order for Subcontractors to continue working for EZ Messenger.

EZ Messenger may provide opportunities for system usage training, best practices information, and/ or information on updates to pertinent changes to rules, regulations, laws, or contracts which may affect the Subcontractor’s ability to perform the necessary work. When pertinent, EZ Messenger will document this information in the Subcontractor’s profile and track any required expiration dates that may be pertinent to the Subcontractor’s ability to continue as a Subcontractor.

The Operations Department will support the needs of Subcontractors with delivery of appropriate documentation, testing, and/or other items which may be necessitated to begin and maintain In Network Subcontractor status. The Operations Department will also ensure that any expiration dates are noted in the Subcontractor’s profile and monitor certain expiration dates such as driver’s license, process server license, automotive insurance, background screening, etc. If any items are found to be expired or expiring soon, the Subcontractor will be given time to obtain said item(s). If any items continue to remain expired/ overdue the Subcontractor’s ability to work with EZ Messenger may be subject to actions up to and including remediation, suspension, termination, or other remedies as may be pertinent in their contract or as appropriate based upon the situation.

The Compliance Department will perform a regular review of these Subcontractors to ensure appropriate access is maintained or denied to these Subcontractors based upon adherence to any of EZ Messenger’s policies and procedures. This review may include but is not limited to review of items for the Subcontractor and their employee(s) of background screening, applicable testing, license expirations, insurance expirations, and court/ administrative proceedings. These reviews are to be performed at a minimum of annually for every Subcontractor. For any Subcontractor who is not in compliance they will be given the opportunity to remedy the situation within a timeframe appropriate to the specific circumstance so as to avoid any legal, contractual, or ethical complications due to lack of compliance. Subcontractors who continue to remain out of compliance may be subject to actions up to and including remediation, suspension, termination, or other legal remedies as may be pertinent in their contracts or as the situation warrants.

5. Exceptions

In rare instances there may be specific and compelling circumstances where exceptions to this policy may be warranted. All requests for exceptions to this policy will be thoroughly reviewed then documented in the Subcontractor’s profile. Any exceptions which may be relative will immediately be relayed to Clients which may be affected by said decision. Exceptions may also occur on behalf of EZ Messenger when the Company may elect to run audits in advance of scheduled times, either on one, some, or all the Subcontractors. On an as-needed basis EZ Messenger may provide an informal review of the Subcontractor, the work they have done, and any/ all documentation required to be kept current in order for them to maintain Subcontractor status, and the results of informal reviews are not required to be documented if all items are found to be in order.

6. Risk Assessment

Subcontractors identified as a risk after the review of any item mentioned will immediately receive a review. Low risk Subcontractors will be reviewed without suspension of work. If the risk is identified as medium to high risk, the Subcontractor will have all work suspended during the review period. The Subcontractor will then receive a full review and any shortcomings addressed. For all risk levels, if the risks cannot be remedied thru various methods, the Subcontractor will be placed into the appropriate status and notifications will be performed as pertinent to Client(s), state/ local/ federal/ administrative agencies. The Subcontractor may then be subject to actions up to and including remediation, suspension until a formal hearing is concluded, termination, or other legal remedies as may be pertinent in their contracts or as the situation warrants.

7. References and Resources

Client Contracts

Local/ State/ Administrative/ Federal Rules

In Network Independent Contractor Service Agreement

Keywords: Subcontractor, Compliance