Relating to a peer support network for first responders.

Contracts

• Employment Agreements: Review "Code of Conduct" and "Termination for Cause" clauses. Explicitly exclude state-sanctioned peer support participation from definitions of "conduct unbecoming" or "instability."
• Vendor Agreements (EAP): If you contract with an external Employee Assistance Program (EAP), amend the scope of work to ensure their counselors meet the forthcoming vetting standards set by TDEM/TSU to ensure continuity of care.

Hiring/Training

• Management Training: Operations Managers and HR staff must be retrained immediately. They must understand that referring an employee to the network is a protected activity.
• Disciplinary Boards: Institute a mandatory "stop-check" in all disciplinary proceedings to verify that evidence is not derived from confidential peer support interactions.

Reporting & Record-Keeping

• Data Segregation: You must establish a "Confidentiality Firewall." If your organization receives data regarding an employee's network participation (e.g., for scheduling), this data must be segregated from the standard personnel file and treated with higher security than standard HIPAA data.
• No Employer Reporting: You are *not* required to report employee usage to the state; the burden of reporting lies with TDEM.

Fees & Costs

• Budget Impact: Low direct costs.
• Indirect Costs: Potential increase in paid administrative leave. You may need to place an employee on paid leave for "safety" reasons while they utilize the network, rather than unpaid suspension, to avoid the appearance of retaliation.