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B. RowanSOM Individuals and accepted applicants who have HBV, HCV or HIV may not, by reason of such disability, be excluded from participation in or be denied the benefits of RowanSOM's services, programs or activities, except as provided in this policy.

VII. ATTACHMENTS

A. Policy Attachment 1, Policy Implementation Procedures

B. Updated Attachment 2, Updated CDC Recommendations for the Management of Hepatitis B Virus-Infected Health-Care Providers and Students. MMWR July 6, 2012; 61(3) (CDC Classification of exposure-prone patient care procedures).

C. TableAttachment 3, Table: Follow-up Plan for RowanSOM individuals with Hepatitis B Virus Infection

D. Example Attachment 4, Example Student Health/Occupational Medicine counseling letter for HBV positive RowanSOM individuals receiving no HBV Committee review (HBV<1,000 IU/ml, and Category I procedures not required, but reasonable expected. See EXHIBIT C)

E. CDC Attachment 5, CDC Recommendation - Notification of Patients of HBV-Infected Health-Care Providers

F. Excerpt Attachment 6, Excerpt from: SHEA Guideline for Management of Healthcare Workers Who Are Infected with Hepatitis B Virus, Hepatitis C Virus, and/or Human Immunodeficiency Virus

ATTACHMENT

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1

Policy Implementation Procedures

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  1. As recommended for all health-care workers, RowanSOM individuals who are infected with HIV and/or HCV should follow strict aseptic technique and standard precautions including, but not limited to, appropriate hand washing frequencies and techniques; protective barriers; and appropriate use of sharps disposal containers, sharps with engineered sharps injury protections, and other safer medical devices, as required by the PEOSHA/OSHA Bloodborne Pathogens standard and RowanSOM policy, Bloodborne Pathogens.
  2. RowanSOM individuals must be provided with explicit procedures to be followed in the event of a potential exposure, in accordance with University policy, Management of Potential Occupational/Educational Exposures to HIV, HBV, and HCV, 00-01-40-40:10.
  3. RowanSOM individuals who have reason to believe they may be infected with HIV, HBV and/or HCV because of occupational exposure or non-occupational high risk activities have a duty to periodically determine their serostatus as frequently as is indicated by the nature of their risk. If found to be infected with HIV, HBV and/or HCV, these individuals shall consult with the Student Health Services director or Occupational Medicine/Employee Health Service director. Such directors shall refer all such matters to the HBV Committee for appropriate review in accordance with this policy.
    Individuals who are found to be infected with HIV or HCV shall be counseled by the Student Health Service director or Occupational Medicine/Employee Health Service director as to the appropriate precautions necessary to protect patient safety, including current recommendations by the Society for Healthcare Epidemiology of America (SHEA). Refer to attachment F for a link to the SHEA guidelines and excerpts pertaining to management of HIV and HCV in the health care setting. 
    Individuals who are found to be infected with HBV shall be counseled by the Student Health Service director or Occupational Medicine/Employee Health Service director in accordance with current guidelines from the CDC. (See Attachments B and C)
  4. In accordance with University policy, RowanSOM shall not make any inquiries of applicants for admission regarding the existence, nature or severity of disabilities prior to acceptance, but may inquire about the ability of applicants to meet the published Essential Functions of the educational program, with or without reasonable accommodations. In evaluating applicants to RowanSOM educational programs, an applicant's limitations or impairments due to HIV, HBV and/or HCV infection may be considered on a case-by-case basis, as with other medical illnesses and disabling conditions, to determine the applicant's ability to perform the essential functions and curricular requirements of the academic program. In no case shall information or inference about HIV, HBV or HCV status be used as the basis for denying an applicant full and complete consideration in the admissions process. Evaluation for admission should focus on whether the individual in his or her current state of health, with reasonable accommodation by the University, will be able to successfully complete the essential functions and curricular requirements of the academic program.

ATTACHMENT

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2

CDC classification of exposure-prone patient care procedures

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These and similar procedures are not included in Category I as they pose low or no risk for percutaneous injury to a health-care provider or, if a percutaneous injury occurs, it usually happens outside a patient's body and generally does not pose a risk for provider-to-patient blood exposure. These include surgical and obstetrical/gynecologic procedures that do not involve the techniques listed for Category I; the use of needles or other sharp devices when the health-care provider's hands are outside a body cavity (e.g., phlebotomy, placing and maintaining peripheral and central intravascular lines, administering medication by injection, performing needle biopsies, or lumbar puncture); dental procedures other than major oral or maxillofacial surgery; insertion of tubes (e.g., nasogastric, endotracheal, rectal, or urinary catheters); endoscopic or bronchoscopic procedures; internal examination with a gloved hand that does not involve the use of sharp devices (e.g., vaginal, oral, and rectal examination; and procedures that involve external physical touch (e.g., general physical or eye examinations or blood pressure checks).

Attachment

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3
Table: Follow-up Plan for UMDNJ Individuals with Hepatitis B Virus Infection

 

 

 

 

Category I procedures

Hepatitis B Virus Viral Load

 

 

<1,000 IU/ml or 5,000 GE/ml

>1,000 IU/ml or 5,000 GE/ml

 

 

 

Required

No restrictions

Semi-annual monitoring

Review by HBV Committee

Review by HBV Committee to determine whether reasonable modifications can be made, such as, eliminating Category I procedures.

If yes: individual may continue enrollment/employment, but restricted from participation in Category I procedures;Semi-annual monitoring

If no: individual cannot continue employment/enrollment while HBV DNA levels equal or exceed 1,000IU/ml or 5,000 GE/ml

 

 

 

Not required, but reasonably expected

No restrictions

Semi-annual monitoring

Restricted from participation in Category I procedures

Semi-annual monitoring

Review by HBV Committee

 

 

 

Not required, Not reasonably expected

No restrictions

No monitoring

No restrictions

No monitoring

 

 

 



ATTACHMENT

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4
Example Student Health/Occupational Medicine counseling letter for HBV positive UMDNJ individuals receiving no HBV Committee review (HBV<1,000 IU/ml, and Category I procedures not required, but reasonable expected. See Attachment C)


Dear ____________________________:

...


I have read and understood the contents of this letter and the attached policy, and I agree to any requirements expressed in this letter in all respects. I understand that if I do not comply with the requirements in this letter and/or the attached policy, I may be subject to [discipline, up to including dismissal/termination].



___________________________
Student /Employee Name (Print)


___________________________
Student/Employee Signature


___________________________
Date


ATTACHMENT

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5

CDC Recommendation -
Notification of Patients of HBV-Infected Health-Care Providers

There is no clear justification for or benefit from routine notification of the HBV infection status of a health-care provider to his or her patient with the exception of instances in which an infected provider transmits HBV to one or more patients or documented instances in which a provider exposes a patient to a bloodborne infection. Routine mandatory disclosure might actually be counterproductive to public health, as providers and students might perceive that a positive test would lead to loss of practice or educational opportunities. This misperception might lead to avoidance of HBV testing, of hepatitis B vaccination (if susceptible), of treatment and management (if infected), or of compliance with practice oversight from an expert panel (if infected and practicing exposure-prone procedures). In general, a requirement for disclosure is accepted to be an insurmountable barrier to practice and might limit patient and community access to quality medical care.

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ATTACHMENT 6

Excerpt from: SHEA Guideline for Management of Healthcare Workers
Who Are Infected with Hepatitis B Virus, Hepatitis C Virus,
and/or Human Immunodeficiency Virus
*(see: http://www.shea-online.org/Assets/files/guidelines/BBPathogen_GL.pdf)*

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