General — Charleston, WV
Date: 2023-07-27
Time: 18:00

Goodwill Prosperity Center
 Helms/McFadden Room
 215 Virginia St. W.
 Charleston, WV
 July 27, 2023
 6:00 pm to 7:00 pm
 NOTICE AND AGENDA
 FOR
 PUBLIC HEARING

WOMEN'S HEALTH CENTER, WASHINGTON ST LOCATION

 1. TO HEAR FROM WOMEN'S HEALTH CENTER CONCERNING THEIR APPLICATION FOR A SYRINGE
 SERVICE PROGRAM AT THEIR WASHINGTON STREET LOCATION.

 2. TO HEAR PUBLIC COMMENT CONCERNING WOMEN'S HEALTH CENTER'S APPLICATION FOR A
 SYRINGE SERVICE PROGRAM AT THEIR WASHINGTON STREET LOCATION.*

*WRITTEN COMMENT MAY ALSO BE SENT TO THE CLERK’S OFFICE 501 Virginia St. E. Charleston, WV 25301
Nicole.smith@cityofcharleston.org
PER GOODWILL POLICY, NO INDIVIDUALS UNDER THE AGE OF EIGHTEEN (18) ARE ALLOWED TO ATTEND
RENTED SPACE EVENTS, WITHOUT PRIOR NOTICE TO AND APPROVAL BY GOODWILL STAFF.




Meetings may be recorded and streamed

Goodwill Prosperity Center
 Helms/McFadden Room
 215 Virginia St. W.
 Charleston, WV
 July 27, 2023
 6:00 pm to 7:00 pm
 NOTICE AND AGENDA
 FOR
 PUBLIC HEARING

WOMEN'S HEALTH CENTER, WASHINGTON ST LOCATION

 1. TO HEAR FROM WOMEN'S HEALTH CENTER CONCERNING THEIR APPLICATION FOR A SYRINGE
 SERVICE PROGRAM AT THEIR WASHINGTON STREET LOCATION.

 2. TO HEAR PUBLIC COMMENT CONCERNING WOMEN'S HEALTH CENTER'S APPLICATION FOR A
 SYRINGE SERVICE PROGRAM AT THEIR WASHINGTON STREET LOCATION.*

*WRITTEN COMMENT MAY ALSO BE SENT TO THE CLERK’S OFFICE 501 Virginia St. E. Charleston, WV 25301
Nicole.smith@cityofcharleston.org
PER GOODWILL POLICY, NO INDIVIDUALS UNDER THE AGE OF EIGHTEEN (18) ARE ALLOWED TO ATTEND
RENTED SPACE EVENTS, WITHOUT PRIOR NOTICE TO AND APPROVAL BY GOODWILL STAFF.




Meetings may be recorded and streamed
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  WOMEN’S HEALTH CENTER OF
 WEST VIRGINIA
 HARM REDUCTION/SYRINGE
 SERVICE POLICY MANUAL




Jun-23

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1 INTRODUCTION AND OVERVIEW
The WHC Harm Reduction Program was established by the Women’s Health Center of West Virginia
(WHCWV) in 2023, in an effort to address a serious gap in health care needs and harm reduction services
for people who use drugs. As are all services as WHCWV, the WHC Harm Reduction Program focuses on
non-judgmental care, informed consent and respecting the dignity of all people. The program is
patterned after the best practices and evidenced-based practices of the World Health Organization and
the US Centers for Disease Control and Prevention for harm reduction and syringe access. Due to the
standards for one-to-one exchange outlined in WV law, these policies do not currently meet the CDC
recommended guidelines for operation that best prevent infectious diseases in people who use drugs.
Therefore, our efforts are more important than ever to ensure that we do not see increases in overdoses
and viral and bacterial infections such as Human Immunodeficiency Virus (HIV) and Hepatitis C in our
community.



1.1 WHAT IS HARM REDUCTION AND WHAT IS OUR ROLE?
Harm reduction is a set of values and practical strategies that aim to meet people “where they are” to
assist them in reducing harms associated with high-risk behaviors, such as drug use. Harm reduction
accepts the reality that people can and will use drugs and engage in other activities that can cause them
harm and works to minimize the harmful effects of these behaviors rather than ignore, condemn, or
focus on ending the behavior. Harm reduction is focused on providing participants the opportunity to
make “any positive change,” and seeks to empower participants by providing information and techniques
so they can work towards decreasing potential harm in high-risk behaviors. Harm reduction-based
programs have been critical to HIV prevention efforts since the 1980s and continue to play a key role in
reducing new HIV infections and promoting the long-term health and well-being of people living with
both HIV and Acquired Immunodeficiency Syndrome (AIDS). Empowering patients with the information
necessary to make informed decisions about their own bodies has long been a core tenet of the work of
the WHCWV.

Our role as service providers working from a harm reduction framework includes:

 • Recognizing that drug use, sex, and other activities that may cause harm are not inconsistent with
 seeking to improve one’s health, community public health, or the health of drug sharing and
 sexual partners.
 • Respecting the autonomy and choices of people we support and working with them to find the
 best strategies to improve their health.
 • Collaborating with our communities, community leaders, and concerned persons to find the best
 strategies to improve the public health of all communities.
 • Providing services that are non-judgmental, non-coercive, and based on the best available
 scientific evidence when applicable.
 • Providing services tailored to the wants and needs of each unique participant.
 • Engaging all individuals who access our services with respect, dignity, and empathy.


WHCWV affirms people who engage in high-risk behavior have as equal a right to our services and
programs as people who do not. People engaging with WHCWV will be treated with dignity and respect,


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and services will be offered in a non-judgmental, non-coercive and equitable manner. We recognize that
substance use and other high-risk behavior may, at times, be a barrier to a person benefiting fully from
WHCWV’s programs and services.WHCWV’s response will remain person-centered and when necessary,
meeting them “where they are.” We will engage and involve individuals in these situations to deliver
services that support their overall health and well-being.

WHCWV recognizes that people who use drugs have been at the forefront of developing harm reduction
practices and will continue to play an important role developing effective programming to prevent
overdose, support people living with HIV/AIDS, and prevent new HIV and Hepatitis C infections. WHCWV
recognizes that people who use drugs bring valuable experience to the agency and will do its best to
support those who have used or do use drugs to be full participants within our agency as clients and
potential future staff or volunteers.

WHCWV will support ongoing training on harm reduction practices for all staff, contract labor, volunteers,
students, and board members to ensure that harm reduction is consistently and effectively implemented
within the agency. WHCWV will create an environment where access to training programs, up to date
information on harm reduction practices, HIV/AID treatment facilities, Sexually Transmitted Infection (STI)
prevention, and Substance Use Disorder (SUD) treatment is easily accessible either in-house or through a
referral partner.



2 SERVICE ENVIRONMENT

2.1 SAFE AND SECURE SPACE
The WHC Harm Reduction Program staff and WHCWV will be responsible for maintaining a safe work
environment for all staff, volunteers and participants. The Harm Reduction and Syringe Services will take
place in the clinical area of the WHCWV. There is one waiting room and one check-in desk, with an
entrance featuring a security door and buzzer for participants. Both the Harm Reduction Program
Coordinator’s office and exam rooms are located adjacent to the waiting rooms and both will be used for
one-on-one encounters with participants. The Hazardous Waste Room is equipped with a key lock to
store all returned sharps as well as additional storage. All educational materials and supplies will be
stored in the Harm Reduction Program Coordinator’s office, with all syringes, naloxone and other safe use
supplies kept in a locked cabinet. Overflow supplies are stored in the locked supply closet adjacent to the
Hazardous Waste Room. No areas of the clinic are accessible from the waiting room, with most additional
doors in the clinic secured with access only by staff key fob. Once they leave the waiting room,
participants will be accompanied by staff at all time. All supplies and equipment to provide services will
be made available to appropriate staff and not accessible to participants. Common areas and walkways
will remain clear of obstruction. Participant interactions will be conducted in private exam rooms or other
designated private spaces such as the Harm Reduction Program Coordinator’s Office. All syringe exchange
will take place in marked, designated areas during service hours and no children will be present in these
areas at any time. In the event of a staff member or participant being diagnosed with or showing
symptoms of COVID-19, arrangements will be made individually for services to ensure the health and
safety of everyone involved.



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2.2 EMERGENCY PLAN
For the purposes of this policy, Person in Charge (hereafter referred to as PIC) refers to the Harm
Reduction Program Coordinator, Chief Nurse Executive, or the most senior service provider. All incidents
and adverse events should be reported on the WHC Harm Reduction Program Incident and Adverse
Reporting Form (Appendix A.). For further description of adverse events, see “Community Relations.”


2.2.1 Location of the Fire and Emergency Plan
The Fire & Emergency Action Plan can be found in the WHCWV Safety Manual located at the front desk,
in volunteer and employee on-boarding packets and posted on the wall in the Harm Reduction Program
Coordinator’s Office.


2.2.2 Reporting & Evacuating During a Fire or Other Emergency:
This description relates to fires and other life threatening situations and emergencies that require
evacuation. In the event of fire, power failure, or other emergency requiring immediate evacuation of the
building, staff will follow the procedure below:
Step 1 – Use Fire Extinguisher
 • If fire is very limited, use fire extinguishers located by the Washington Street emergency exit, in
 the back entrance hallway, in the lab, or in the staff lunchroom.
Step 2 – Notify Staff and Patients
 • The person first aware of the emergency requiring evacuation will immediately give notice of the
 need to evacuate by pulling one of the fire alarms located in the entrance foyer, by the
 Washington Street emergency exit, or by the staff exit.
Step 3 –Call Authorities
 • The person aware of the emergency will dial 911 and request assistance.
Step 4 – Evacuate the Building
 • Staff members will assume responsibility for the calm communication and evacuation of patients
 and staff and for closing doors (leave unlocked for firefighters) in their work areas. If possible,
 they should bring a copy of the patient and staff schedule for the day to the evacuation area to
 ensure that everyone is accounted for. EXITS are located on the front, side, and rear of building.
 Area evacuation assignments are as follows:
Greendale Emergency Exit and/or Greendale Main Exit: Receptionist and front office staff assist patients
in waiting room, patient restroom, conference room, and front office. Receptionist takes appointment
sheets if possible. Administrative office exits to Greendale through the Greendale main exit.
Washington Street Emergency Exit: Lab, Harm Reduction Program Coordinator office, GYN exam rooms,
lab medical assistant, Parent Program and nurses’ office exit to Washington Street.
Rear Parking Lot Staff Exit: Procedure and Recovery rooms—attending nurse, medical assistant and/or
autoclave technicians, and counselor. Clients needing assistance evacuating with a wheelchair or
stretcher may be evacuated through the closest safe exit. Staff in charge of the procedure and recovery
areas will ask for assistance from other staff to evacuate clients in those areas. These evacuations will
take place through the rear exit or the closest safe exit.
Persons evacuated will be instructed to go to the auxiliary WHC parking lot as a primary location and
across West Washington Street in the vacant lot as a secondary location. The supervisor on duty will
verify that all areas are cleared. They will also serve as contact with emergency crews. Re-entry will not
be allowed until all danger has passed and notification of such has been given by the Fire Department or
Police Department, depending on the type of emergency and department handling the call. The
supervisor on duty will notify staff and patients when it is safe to return to the building.

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2.2.3 Portable Fire Extinguishers
There are portable fire extinguishers at the following locations in the building:
 1. By the Washington Street emergency exit
 2. In the back entrance hallway
 3. In the lab
 4. In the staff lunchroom

All portable fire extinguishers are marked by a red fire extinguisher sign directly above. Fire
extinguishers should be used only by staff trained to use them to control fires from non-combustible
hazards. Training will be provided on a yearly basis. Fire extinguishers are inspected monthly by the
WHCWV Office Manager and annually by AirGas, phone number- 304-346-0875.


2.2.4 Pull Alarm Stations
Pull alarm stations are located in the entrance foyer, by the Washington Street emergency exit, or by the
staff exit. These bright red metal boxes are activated by pulling the handle down firmly until the alarm is
heard. Proceed to the nearest exit to evacuate the building.


2.2.5 Escape Procedures and Exit Routes
All exit doors at WHCWV have panic bars and are marked with lighted signs. Exit is always permitted
regardless of whether the door is locked to outside visitors. During an emergency due to fire or other
hazard, all employees must exit the building in a quiet and orderly manner. Employees are to leave
through the nearest and safest exit door. All exits, stairways, doorways, and hallways must always remain
clear and unobstructed. All persons exiting should remain low to the ground in smoke filled areas.

The following staff is responsible for ensuring the building is evacuated quickly and orderly:

 • The Office Manager will ensure that all staff, volunteers, and participants are evacuated from the
 following areas: waiting room, patient restroom, conference room, and front office.
 • The Harm Reduction Coordinator will ensure that all employees, patients, and volunteers are
 evacuated from Lab, counseling office, GYN exam rooms, Parent Program and nurses’ office
 • The Chief Nurse Executive will ensure that all staff, volunteers, and participants are evacuated
 from the Procedure and Recovery rooms.


2.2.6 Accounting for Employees, Patients, and Volunteers
Persons evacuated will be instructed to go to the auxiliary WHC parking lot as a primary location and
across West Washington Street in the vacant lot as a secondary location. Participants are strongly
encouraged to join staff and volunteers in this area but will not be required to do so. The PIC(s) are
responsible for ensuring that staff and volunteers comply with this requirement and encouraging
participants to comply.

The PIC must then take inventory of staff and volunteers and note any absent parties. The PIC must call
the Executive Director of WHCWV as soon as possible to report the fire or emergency.




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2.2.7 Facility Lockdown
Any threats to the building/facility, any threats to a person inside the building, an active shooter or violent
person in the area, or any other credible imminent life-threatening danger around the building will result
in a lockdown.

In the event of a facility lockdown the PIC(s) shall ensure that all doors are locked to the outside and that
someone has called 911 and reported the imminent threat. Staff, volunteers, and participants will calmly
retreat to the secure area in the recovery room. This area shall be used for a lockdown area because it is
located centrally, is secure with no windows and it is also near an emergency exit. In the event this
designated space cannot be accessed, the PIC(s) will instruct to stay in place.

The PIC shall call the Executive Director of WHCWV to report the lockdown as soon as possible. All locked
down persons in the building shall shelter in place or in the lockdown area until the PIC has announced
that the lockdown is over.


2.2.8 Resuming Operations after Fire or Other Emergency
The PIC will ensure the safety of staff, volunteers, and participants on the property and assess any
remaining hazards. Re-entry will not be allowed until all danger has passed and notification of such has
been given by the Fire Department or Police Department, depending on the type of emergency and
department handling the call. The supervisor on duty will notify staff and patients when it is safe to
return to the building. The PIC will complete an incident report and take photographs or video of any
potential damage.


2.2.9 Response to Medical Emergency
A medical emergency situation can occur anywhere in the clinic. If ambulance transportation to the
hospital is necessary, an ambulance from the City of Charleston (911) will be called. It should arrive
within 3-5 minutes.
Emergency equipment and medications are located on the crash cart. Oxygen is located in each
procedure room. Physicians and nursing staff are responsible for complete knowledge and proper usage,
location and maintenance of emergency supplies.
Staff roles are outlined below.
MEDICAL EMERGENCY PROCEDURE PROTOCOL
STAFF ROLES
STAFF MEMBER FINDING PATIENT IN CRISIS
 1. Call out in a loud voice “I need help.”
 2. Ask a coworker to call 911.
 3. Begin CPR if indicated. If staff member finding crisis does not know CPR, call for a medical staff
 person.
PROVIDER
 1. Provider informs the medical assistant who calls for the charge nurse.
 2. Medical assistant remains in the room for assistance and periodically checks and records vital
 signs.
 3. Provider makes the referral on the telephone to the emergency room regarding the patient
 status and documents the condition of the patient.
 4. Provider talks with family member/friend of the patient (if applicable) regarding the condition
 and plan of care.

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 5. Provider takes care of the patient in the other procedure room prior to going to the emergency
 room.
CHARGE NURSE
 1. Remains with patient and provider (reviews provider orders, starts progress sheet, records vital
 signs and documents as needed).
 2. Assesses the situation and advises autoclave technician regarding notification of Chief Nurse
 Executive and Executive Director’s office.
 3. Carries out necessary procedures (i.e., starts IV, oxygen, records vital signs).
 4. Assigns someone to copy chart for transfer to the hospital and to call an ambulance.
AUTOCLAVE TECHNICIAN
 1. Responds to requests from charge nurse.
 2. Remains in procedure area.
 3. Moves the crash cart into the procedure room.
 4. Calls 911 emergency transport when instructed to do so by the charge nurse.
 a. Request “silent code”, ambulance does not arrive with siren and lights flashing.
RECOVERY ROOM NURSE
Remains with patients, closes door, reassures. Does not discharge patients until hallway is clear.
FRONT OFFICE/RECEPTIONIST
The receptionist will copy the patient chart. Front office will assist in suspending patient flow and
maintaining clear entrance to facility without creating undue alarm to visitors and clients.

WHC Harm Reduction Program staff will follow the guidance of EMS upon their arrival. In the event of a
potential opioid overdose, a trained staff member will administer naloxone if warranted. All WHCWV
employees carry current certification in basic CPR. At no time is there to be syringe services without a
WHCWV employee present. All WHCWV staff and incoming volunteers will be trained on the
administration of opioid antagonist using a combination of WV Health and Human Resources and
www.prescribetoprevent.com resources. The Harm Reduction Program Coordinator shall provide a
voluntary de-briefing session to discuss the group’s response to an opioid overdose and any psychological
effects of those who witness the emergency.


2.2.10 Handling Accidents
ACCIDENT AND INCIDENT INVESTIGATION:
All accidents and incidents should be investigated by the Department Manager or Supervisor. Serious
accidents or any unusual frequency of accidents in any department should be investigated by the Safety
Committee.

ACCIDENT REVIEW
Every accident and incident report should be reviewed and studied to determine cause. Proper
recommendations to prevent recurrence should be made to the Safety Committee.

The Executive Director should be furnished quarterly safety committee minutes containing the following
information:
 • Number of accidents and incidents quarterly. Separate reports of employee accidents and
 patients, visitors and others.
 • Predominant causes of accidents should be shown.
 • Monitoring to evaluate specific trends relating to causes and type of incidents/accidents.


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 • Recommendation to the executive director containing actions to reduce the likelihood of a similar
 accident occurring in the future.

ACCIDENT INVESTIGATION
The detection and elimination of accident hazards through investigation is one of the most effective
methods of improving the safety record of an organization. nce the accident sequence is set in motion,
little can be done to control the degree of severity. For this reason, all accidents and “near misses” should
be investigated.

Documentation of accident investigation is provided by the supervising manager on the incident report
form. Additional investigation may be conducted by the Safety Officer. For further explanation about
what to do in the event of a needle stick or blood borne pathogens, see “Blood Borne Pathogens Post
Exposure Plan.”


2.2.11 Flooding, Natural Disasters, Extreme Weather, and States of Emergency
In the event of forecasted flooding, natural disasters, or extreme weather the facility will be closed until
the weather has subsided. In the event of a declared State of Emergency, the facility will follow the
guidance of local officials. The Executive Director will determine and inform staff and volunteers as soon
as possible when the facility will close due to any of these conditions. Staff and volunteer safety is of the
upmost importance and no staff or volunteer should travel to the facility if they do not feel it is safe.
Special accommodations shall be made to ensure clients have access to the full array of harm reduction
services as soon as possible after a flood, natural disaster, extreme weather or State or Emergency.


2.2.12 Handling Serious Illness
Staff or volunteers that are sick will be instructed to stay home. Staff and volunteers will not be permitted
to perform work duties if they have a serious illness that compromises their safety or the safety of others.
If it is determined that a WHC Harm Reduction Program staff or participant has a serious and contagious
illness, they will be sent home or to a place of isolation immediately.

WHCWV will engage in activities that reduce the spread of contagious illnesses. This includes, but is not
limited to, paying for daily cleaning and sanitation services, ensuring access to masks and other Personal
Protective Equipment (PPE), and offering access to health insurance to eligible employees.


2.2.13 Addressing the Needs of Special Populations in Emergency
Participants with physical disabilities will be provided services and special accommodations under the
Americans with Disabilities Act (ADA). During one of the previously mentioned emergencies that may take
place on site the Harm Reduction Program Coordinator will designate a staff or volunteer to support the
disabled participant’s needs. Participants who live in substandard housing or who are experiencing
homelessness will be provided access to information about city-run emergency shelters during the event
of extreme weather situations.

2.2.14 Relocation of Syringe Services in the Event of an Emergency
If relocation becomes necessary due to a fire, flood, natural disaster, and other life-threatening situation
the WHC Harm Reduction Program shall operate out of the Unitarian Universalist Congregation of
Charleston, WV (hereafter referred to as UUC). The address for the UUC is 520 Kanawha Blvd W,


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Charleston, WV 25302. The contact for the facilitation of our use of this facility is Congregational
Administrator Sarah Stone. She can be reached at 304-345-5042. Upon identifying the need for
relocation, the Harm Reduction Program Coordinator shall notify the congregational administrator of the
UUC. The UUC will assign the WHC Harm Reduction Program the most appropriate location in the church
to provide services based on the church’s programs and needs. The church has many safe, clean, and
private areas that could accommodate the WHC Harm Reduction Program. This includes, but is not
limited to the meeting area and the front room. All the identified areas can be accessed from the main
entrance on Kanawha Boulevard.


2.3 STAFF SECURITY AND SAFETY POLICY
Policy: All WHC Harm Reduction Program staff and volunteers must observe proper safety and security
precautions during syringe service operations. The physical environment must remain clear of
obstructions and with adequate lighting. Wet floors should be marked as such. All safety concerns are to
be addressed by the PIC immediately to avoid general accidents as well as needle stick injuries.

Procedure: Prevention of Needle Stick Injuries:

 • All WHC Harm Reduction Program staff and volunteers should be educated regarding the safety
 precautions for carrying and handling syringes and other sharps, emphasizing the agency’s safety
 policies and procedures during transactions with participants.
 • WHC Harm Reduction Program staff or volunteers must never handle used injection equipment
 without the proper safety equipment.
 • The following safety equipment must be available during syringe exchange operations:
 1. Puncture resistant gloves
 2. Standard exam gloves
 3. Spill Kit
 4. Forceps or tongs or grabber
 5. Eye Protection
 • Any WHC Harm Reduction Program staff or volunteer who directly handle hazardous waste must
 wear protective clothing which includes gloves, long sleeves or a lab coat, long pants, and closed
 toe footwear.
 • All used injection equipment should be placed in an approved leak-proof, rigid, puncture resistant
 sharps container.
 • Sharps containers should be placed on a secure surface or on the ground and always kept level.
 WHC Harm Reduction Program staff and volunteers should NEVER hold a sharps container during
 the exchange process.
 • Injection equipment that falls outside of the sharps container should be retrieved by the
 participant who is returning the equipment, when possible. If this is not possible, the tongs
 should be used to pick up any equipment to be placed in the container.
 • WHC Harm Reduction Program and volunteers should NEVER re-cap used syringes. Participants
 should be encouraged to put syringes directly into sharps container after using. Demo syringes
 used for naloxone training only may be re-capped by the trainer and are to be clearly marked as
 ‘Demo Use Only.”
 • Only one participant at a time should be in the designated sharps exchange area.
 • Sharps containers should never be filled above the manufacturer’s fill line.
 • No one should ever insert hands into the sharps containers or forcibly push used injection
 materials down into the container.

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 • All sharps containers must be disposed of in accordance with the company contracted to remove
 sharps and other biohazards from the clinic. See “Sharps Disposal Plan.”


2.4 BLOOD BORNE PATHOGENS POST EXPOSURE PLAN
DEFINITIONS:
Needlestick: contact with a needle contaminated with blood/body fluid which causes a break in the skin.
Exposure:
1. Exposure to blood or body fluids through needlestick, instruments, sharps, surgery or traumatic
 events;
2. Exposure of mucous membranes to visible blood or body fluids: or
3. Exposure of skin to visible blood or body fluids, when the exposed skin has an open cut, is
 chapped, abraded or afflicted with dermatitis or the contact is prolonged or involves an extensive
 area.
Source Patient/Individual: the individual whose blood/body fluid was involved in injury to another.
POLICY:
All injuries involving needlesticks and/or blood/body fluid exposures are to be reported to the WHC
Charge Nurse. Follow-up of all exposures will be coordinated by the Charge Nurse. Confidential
counseling and testing of the source individual and the injured person will be coordinated by the Charge
Nurse.
The Charge Nurse or supervisor on duty in the department/unit where exposure occurs is responsible for
immediate follow-up. Packets are located in an envelope in the lab titled “Exposure Follow-Up Packet”
with specific instructions for obtaining appropriate consents and lab work in a timely manner.
All follow-up is confidential. Results of testing are provided in a confidential manner to the exposed
employee. Positive test results will be reported to the source individual's treating physician and to the
source individual if requested. All exposure follow-up testing is to be ordered by the Charge Nurse or
clinical supervisor to ensure confidentiality and compliance with leqal requirements.
Prophylactic medications such as PreP may be administered based on lab results and review by the WHC
Medical Director.
PROCEDURE:
1. Any WHCWV or WHC Harm Reduction Program staff, volunteer, patient, or participant who is
 potentially exposed to a blood borne pathogen while performing regular duties shall immediately:
• Wash the affected area with soap and water
• Flush exposures to the face or eyes at the designated eye washing station
2. Report all needlesticks, blood/body fluid exposures to the Charge Nurse or clinical supervisor
 immediately. Initial evaluation including source lab work should be completed within two (2)
 hours of the injury or exposure to maximize opportunity for prophylactic care if needed.
3. Pick up an "Exposure Follow-up Packet" from the lab. The packet contains two sets of materials,
 one for the source and one for the exposed individual including:
 • Instructions
 • Consent forms, lab slips for both the source and the exposed individual


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 • Educational information
 • Accident/Injury report forms (for employee use)
 • Confidential Employee Health forms with areas highlighted to be completed
SOURCE ACTIVITIES:


 • CONSENT: Obtain informed consent from source to draw lab results (signed form). The Original
 copy is placed in the Employee Health file. DO NOT PUT ON PATIENT'S CHART. A script is
 provided on the top of the form to be read to the source before requesting consent. If consent
 is refused – notify the supervisory nursing staff immediately.
 • LAB WORK: Contact lab to draw blood for HIV, HbsAG, and Hepatitis C.
 o NOTE: If blood is available in the Lab, it may be used for testing.
 o If Nursing staff draws the blood, two (2) red top tubes are to be
 drawn. The tubes are to be labeled with the "P" number provided
 on the top of the consent form, the date, and initials of the
 person drawing the blood. DO NOT PUT SOURCE NAME ON THE
 TUBES. Lab slips are provided. The specimen is to be sent to the
 lab immediately with the lab slips.
EXPOSED INDIVIDUAL ACTIVITIES:

 • TEST RESULTS: HIV report will be called to the nursing staff within one hour after the specimen is
 received by the lab. If the source test results are positive, the nursing staff or Charge Nurse will
 contact the attending physician.
 • CONSENT: Obtain informed consent (educational information provided) from exposed individual
 to have lab work drawn (signed form). Original copy is placed back in the Employee Health file.
 Testing of the exposed individual is not mandatory but is highly recommended. If testing is
 refused, the declination section of the form must be signed.
 • LAB WORK: Coded numbers are used to maintain confidentiality. Lab work will be drawn at the
 direction of the Charge Nurse. If the exposed individual refuses consent for HIV, but consents to
 phlebotomy, blood will be drawn and held for 90 days. If within 90 days of the exposure incident,
 the employee elects to be tested, the HIV testing should be done as soon as feasible. If
 venipuncture is refused, the exposed individual is to sign a waiver for refusal.
 o Additional lab work may be required following initial testing at 6 weeks, 3 months and 6
 months.
 • TEST RESULTS: Source HIV test results will be called Employee Health within one hour after being
 received by the Blood Bank. Employee Health will notify the exposed individual immediately of
 source test results. HBsAG and Hepatitis C source results will be faxed to WHC within three days.
 If tests are positive, the exposed individual will be notified. Results of testing on the exposed
 individual will be provided to the individual by the Charge Nurse.
 • TREATMENT: (medications) If appropriate, prophylactic treatment such as PreP will be initiated at
 the direction of the WHC Medical Director. Counseling and follow-up will be coordinated by the
 Charge Nurse.
EXPOSURE PACKET COMPLETION:
Assure the following forms have been completed and are placed back in the employee exposure file by
the end of the shift.


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 • Employee Confidential Record: Complete section #1
 i. It is essential that both SOURCE and EXPOSED individual's information is provided
 and Employee Health accident/injury form
 • Source original consent form
 • Exposed individual's original consent form
CONFIDENTIALITY:
 • Exposure follow up records are maintained confidentially and kept separate from other Employee
 Health records.


2.5 SHARPS DISPOSAL PLAN
Policy: Women’s Health Center of West Virginia will comply with the rules set forth by the State of WV for
the proper storage and disposal of all infectious waste. The policy is designed to protect staff,
participants, and volunteers from encountering infectious medical waste.


Procedures: It is expected that MPHR will receive more than 50 pounds of infectious medical waste per
month. Therefore, a permit will be obtained and maintained if it is required by the State. The Harm
Reduction Program Coordinator and/or the WHC Harm Reduction Program Administrator will be
responsible for the ongoing review and development of policies and for obtaining and maintaining the
above-mentioned permits. The Harm Reduction Program Coordinator is also considered the Infection
Control Manager.

2.5.1 Infectious Waste
Infectious waste includes the following: Cultures and stock of microorganism or biologicals, blood and
blood products, pathological waste, sharps, animal carcasses, body parts, bedding and related wastes,
isolation wastes, contaminated soil, water, or other debris resulting from the clean-up of a spill.

Sharps will be collected in rigid, leak-proof, puncture resistant containers clearly marked as Biohazard
Infectious Waste.

2.5.2 Storage of Medical Waste
Storage of medical waste other than sharps cannot exceed 30 days. All medical waste containers will be
stored in a corrugated box in the Hazardous Waste Room which is locked with a key only authorized
individuals can access. Container lids should be locked in place and should not be re-opened for any
reason. The containers will be stored in this manner until the medical waste disposal company arrives to
remove them from the facility. They are currently scheduled once per month.

The storage area is clearly labeled with appropriate international bio-hazard signs and indicates that
unauthorized people are not allowed.

Sharps containers should be placed inside a red garbage bag labeled ‘bio-medical waste’ or ‘biohazard.’
Bags should be bound at the gathered end and taped shut prior to storage. WHC Harm Reduction
Program staff and volunteers must use appropriate PPE while packaging infectious medical waste for
storage.

The storage area should be kept clean and in good repair.

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2.5.3 Infectious Waste Removal
Infectious waste is removed from the facility by:

 Stericycle, Inc., 88 W Airport Industrial Park R, Parkersburg, WV 26104

 Phone: 800-424-9300

The manifests from MWS are paper copies and will be maintained for 6 years as per WHCWV’s document
retention policy.

NO INFECTIOUS WASTE IS TREATED AT WHCWV.

2.5.4 PPE and SPILL KITS
Policy: In support of Women’s Health Center of West Virginia, Inc.’s (WHC’s) intention to ensure a safe
work environment and regulatory compliance, a program has been developed to provide appropriate
personal protective equipment (PPE). In addition

Purpose: To determine, assign and enforce the use of personal protective equipment by assessing
workplace hazards.

Procedure:

Managers: Primary responsibility for implementation of the PPE Program in their departments, including

 • Identifying and evaluating hazards in their department
 • Providing appropriate PPE to employees
 • Ensuring employees are trained on the proper use, care, and cleaning of PPE

Employees: Responsible for using PPE and following PPE Program requirements:

 • Wearing PPE as required
 • Attending required training sessions
 • Caring for, cleaning, and maintaining PPE as required
 • Informing the supervisor of the need to repair or replace PPE
 o NOTE: Failure to comply may result in disciplinary action

WHC Safety Committee: Responsible for the development, implementation and administration of the PPE
Program including:

 • Assisting supervisors in conducting workplace assessments to identify hazards which necessitate
 the use of PPE
 • Reviewing, updating and evaluating the overall effectiveness of the PPE Program

Safety Office Staff:

 • Functions as a resource to employees, supervisors and the CAMC Safety Committee including:
 o Assisting with hazard assessments
 o Selection of proper equipment, and training
 o Providing regulatory updates

PROGRAM ELEMENTS

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Hazard Assessment

 • Supervisors will assess the workplace to determine the nature of hazards that may be present,
 and assign appropriate PPE.
 • Once the initial hazard assessment has been completed, the supervisor shall:
 o Purchase and issue the appropriate PPE according to this policy
 o Ensure defective or damaged equipment is not used.
 o Ensure required PPE is used by employees
 • Hazards should be reassessed by supervisors when new products, equipment, or procedures are
 introduced, or as needed.

Protective Equipment Selection

Eye and Face Protection

 • Suitable protectors shall be used when employees are exposed to hazards from flying particles,
 molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially
 injurious light radiation.
 • Side protectors shall be used when there is a hazard from flying objects.
 • Goggles or face shields shall be used when there is a hazard from chemical or biohazardous
 splashes
 • For employees who wear prescription lenses, eye protectors shall either incorporate the
 prescription in the design or fit properly over the prescription lenses.
 • Protectors shall be marked to identify the manufacturer.
 • Eye and face protectors shall meet all provisions contained in the American National Standards
 Institute standard (ANSI Z87.1-1989).

Hand Protection

 • Suitable gloves shall be worn when hazards from chemicals, blood, body fluids, cuts, lacerations,
 abrasions, punctures, burns, and harmful temperature extremes are present.
 • Glove selection shall be based on performance characteristics, conditions, duration of use, and
 hazards present.

Protective Clothing

 • Protective clothing shall be worn when hazards from heat, splashes of hot metals, hot liquids,
 caustic chemicals, blood and/or bodily fluids, impacts, cuts, acids and radiation are present.
 • Protective clothing is to be inspected to ensure proper fit and function for continued protection.
 • It is important to refer to manufacturers’ selection guides for the effectiveness of specific
 materials against specific chemicals.

Cleaning and Sanitizing

 • Protective equipment shall be capable of being cleaned and sanitized (or otherwise disposed of.)
 PPE shall not be shared between employees until it has been properly cleaned and sanitized.

Purchase of PPE


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 • WHC will purchase and provide required PPE based on the defined hazards in the work
 environment.

Training

 • Any worker required to wear PPE shall receive training in the proper use and care of PPE.
 Periodic retraining shall be offered to both the employees and the supervisors as needed. The
 training shall include, but not necessarily be limited to, the following subjects:
 o Why, when, and what PPE is necessary to be worn
 o Where PPE is located
 o How to properly put on, take off, adjust, and wear PPE
 o The limitations of PPE
 o The proper care, maintenance, and disposal of the PPE
 o Demonstration that the employee understands the training material and is able to use
 PPE properly
 • After the training, the employees shall demonstrate that they understand the components of the
 PPE Program and how and when to use PPE properly, or they shall be retrained. A record of
 training is maintained for each employee.

Recordkeeping

 • Written records shall be kept of the names of persons trained, the type of training provided, and
 the dates when training occurs.

Personal protective equipment (PPE) and spill kits will always be available at the clinic. Employees are
trained every year on blood borne pathogens and appropriate use of PPE and spill kits. Records of this
training are maintained. The Healthcare Provider on site should be called to respond to any medical
waste spill or bodily fluid spill that may occur in the facility. All other people should move away from the
area until the medical staff can intervene to clean up any spill or medical waste.

A spill kit is located within proximity to the storage area, and it contains all the necessary items to clean a
hazardous spill. The exact contents of each kit many vary by brand, but they are to be purchased from a
reputable medical supply vendor. Additional supplies will also be available if needed. The Healthcare
Provider will be responsible for being aware of and following the manufacturer’s instruction for cleaning
spills.

These policies will be modified and updated as needed to comply with current WV State guidelines for
medical waste disposal and hazardous spills.


3 STAFF TRAINING AND CREDENTIALING

3.1 REQUIRED TRAINING
The WHC Harm Reduction Program staff may consist of Women's Health Center of West Virginia
employees, contracted individuals, volunteers, or local university students on various clinical rotations.
For this document, any of these positions may be referred to as “WHC Harm Reduction Program staff and
volunteers” unless otherwise specified. Various positions are to only perform tasks and services within

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their unique licensure scope of practice where applicable or under the direct supervision of such licensed
professional. All service providing staff and volunteers must possess a friendly, non-judgmental attitude
towards participants and maintain the dignity and respect of all other staff and participants. Each licensed
individual will be responsible for license renewals and annual continuing education requirements. Any
new clinical staff or contracted individual shall receive an orientation on their first day with information
including, at a minimum, primary job responsibilities and confidentiality requirements. Any individual
interacting with participants at the WHC Harm Reduction Program, will have documented training
completion at least annually on topics including, at a minimum:

 • WHC Harm Reduction Program policies and procedures manual
 • Importance of maintaining confidentiality and privacy of participants
 • Available services and eligibility requirements of the WHC Harm Reduction Program, including
 syringe access
 • Overview of harm reduction principles and service model used by WHC Harm Reduction Program
 • Disposal of infectious waste and syringe safety
 • Sharps waste disposal in the facility as well as WV state guidelines for home-generated sharps
 • Procedures for making and referring to services not available on-site
 • Hierarchy of risk related to certain sex and drug use behaviors and how to reduce those risks
 • Education and demonstration of safer injection practices
 • Opioid antagonist administration
 • Overdose prevention, recognition, and response
 • Overview of community concerns and outreach strategies
 • Cultural diversity and sensitivity
 • Understanding of multiple paths to recovery and how to access these resources
 • Infection control and the importance of reporting exposure
 • How to handle and when to request assistance for potential verbal or physical threats or other
 escalating and potentially dangerous situations.

All WHC Harm Reduction Program staff must have the appropriate training to provide services with
individual personnel files maintained to document all credentials and training received. Non WHCWV
employees must keep a log of the hours they complete. The personnel files for all WHC Harm Reduction
Program staff and volunteers must include, at a minimum:

 • Application for employment or volunteering (including identifying information and emergency
 contacts)
 • Detailed job descriptions
 • Documentation of the date of employment and dates of completion for orientation and required
 training
 • Documentation of licenses, certifications, and continuing education where applicable
 • Documentation of any disciplinary actions, performance reviews, or termination notices


3.2 JOB/ROLE DESCRIPTIONS
The following roles are necessary for program operations and will be assigned based on availability of
WHC Harm Reduction Program staff and current training completions.


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3.2.1 Program Administrator
The WHC Harm Reduction Program Administrator is by default the Executive Director of Women's Health
Center of West Virginia, approved by the Board of Directors. The Program Administrator will be in part
responsible for; the contribution and development of policies and procedures for program operations,
maintenance, and security of the facility, ensuring staff credentialing and training, program evaluations,
ensuring program licensing compliance, contributing to management of budget, oversight of data
collection, and review of complaint and incident reports. These responsibilities are to be maintained with
the assistance of the Harm Reduction Program Coordinator and any other appropriate staff. The Program
Administrator is not required to be onsite during all harm reduction/syringe service hours, however,
should be available for consultation when applicable. Documentation of the Program Administrator’s
required education or experience will be provided alongside the application.


3.2.2 Harm Reduction Program Coordinator
The Harm Reduction Coordinator is responsible for assisting the Program Director in all above listed
responsibilities and reports directly to the Program Administrator and Chief Nurse Executive. The Harm
Reduction Program Coordinator’s responsibilities include, but may not be limited to; overseeing accurate
implementation of policies and procedures, training and supervision of other WHC Harm Reduction
Program staff and volunteers, maintaining WHC Harm Reduction Program staff and volunteer training
files, ensuring the safe handling of sterile and contaminated sharps waste (as Infection Control Manager),
management and purchasing of inventories, coordination of community events related to harm reduction
services, coordination of community syringe litter reports, managing of relations with referral providers,
addressing initial complaint and incident reports, and review of education and media materials related to
harm reduction and syringe services. The Harm Reduction Program Coordinator should be present during
program hours. In the event the Harm Reduction Coordinator cannot be present during program hours,
their responsibilities would default to the next highest ranking staff member present or the Program
Administrator.


3.2.3 Healthcare Provider
The Healthcare Provider role during program operations would be responsible for providing healthcare or
medical services within their specific scope of practice. These services may include wound care and
education, naloxone administration and overdose reversal training, hepatitis and HIV screening, infectious
disease education, referrals to additional care when applicable, STI screening and education, birth control
dispensing and administration, vaccine administration and education, blood collection when applicable,
and any other medical service that falls within the scope of practice. This role may be filled by any
licensed healthcare provider with the following credentials: Physician (MD), Advanced Practice Registered
Nurse/Nurse Practitioner (APRN/NP), Physician Assistant (PA), Registered Nurse (RN), Licensed Practical
Nurse (LPN), or Medical Assistant (MA). Medical students and APRN students working toward licensing
may perform some clinical tasks under the direct supervision of a licensed MD or APRN.

3.2.4 Additional Assignments or Roles During Service Hours as Related to Operational Flow
The following service assignments may be filled with any of the above-listed positions or any other WHC
Harm Reduction Program staff or volunteers based on availability and training.



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Reception/Greeter: Will receive training to confirm identification status. Will then direct participants to
the appropriate service area.

Syringe Collection: Will supervise the return of used syringes from participants per program policy for
“Collection and Distribution of Syringes.”

Runner/Float: Provide direction to participants throughout the service area. Fill in wherever needed
based on training completion. Assist in filling supply orders and services with the appropriate staff.



4 HARM REDUCTION AND SYRINGE SERVICES

4.1 AVAILABLE SERVICES
To provide syringe services, the WHC Harm Reduction Program will also offer a full array of Harm
Reduction Services. These services shall include at a minimum, sterile syringes and harm reduction
services, syringe recovery and disposal, infectious disease screening, vaccinations, birth control and long-
term birth control, behavioral health services, overdose prevention supplies and education, infectious
disease transmission education, and basic medical evaluations. All services are only to be provided by
WHC Harm Reduction Program staff with appropriate credentialing and within their scope of practice. If
any service is not available during WHC Harm Reduction Program hours or at WHCWV, a referral will be
completed to the appropriate facility.


4.2 REFERRAL POLICY
The WHC Harm Reduction Program recognizes the importance of making referrals as part of a
comprehensive harm reduction program. The following includes procedures for these referrals:

Procedures: WHC Harm Reduction Program staff will provide referrals to various services needed by
participants. Referrals will be offered for necessary services. No one will be denied syringe access for
choosing not to accept offered referrals. In general, participants will be given information to make their
own calls for assistance. However, participants who require assistance with scheduling appointments, etc.
will be provided with that service.


4.2.1 Medical Referrals
WHC Harm Reduction Program participants shall be asked at every visit if they have any medical
concerns. If the medical service cannot be provided by the staff on site, the participant will be provided a
document stating where they can obtain the needed medical service (Appendix B). This document will
include the contact information for the service and how the service can be obtained. If the participant is
uninsured, the participant will be instructed on how to obtain medical services at Cabin Creek Health
Systems. Participants will be referred to the Emergency Department or Urgent Care if the medical need is
immediate and cannot be handled by professional staff on-site.




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4.2.2 Behavioral Health Referrals
WHC Harm Reduction Program participants will be asked at every visit if they have mental health
concerns. If a participant expresses interest or a need for behavioral health services, they will be
provided a document stating where they can obtain the needed mental health service and how it can be
accessed. This document will include the contact information for the service and how the service can be
obtained. If the participant is uninsured, the participant will be instructed on how to obtain behavioral
health services at Cabin Creek Health Systems.


4.2.3 Referrals to Substance Use Disorder (SUD) Treatment
WHC Harm Reduction Program participants will be asked if they would like information about SUD
treatment at every visit. If the participant would like more information about treatment, they will be
provided a document with treatment options. This document will include the contact information for the
service and how the service can be obtained.

Any participant interested in additional information on SUD treatment, including MOUD, will be able to
meet with a healthcare provider at WHCWV and be provided with information about treatment options.
They are also able to meet with the Harm Reduction Program Coordinator who can assist them in
contacting HELP4WV and receiving information about facilities with openings best tailored to their needs.


4.2.4 General Social Service Referrals
Information regarding SNAP benefits, HUD applications, Medicaid and other general social services will be
available for participants at WHC Harm Reduction Program. If social work students are available, they will
assist with the actual forms and provide information on signing up for need services.


4.2.5 Other Harm Reduction Referrals and Agreements
Women’s Health Center of West Virginia must maintain referral relationships with other service providers
to ensure that participants have access to the full array of harm reduction services. These Referral
Agreements are generally made with health departments, hospital systems, and Federally Qualified
Health Centers. WHCWV has a large referral capacity and network that includes but is not limited to the
collection of attached agreements (Appendices D-E) WHCWV will continue to establish more relationships
with service providers and obtain additional referral agreements as appropriate.


4.3 INTAKE, ELIGIBILITY, & VISIT PROCESS
Any person in the community who feels they would benefit from WHC Harm Reduction Program services
is eligible, with minimal exceptions. To receive syringe services from WHC Harm Reduction Program, an
individual must be 18 or older, physically present and able to produce proof of West Virginia
identification. Persons under 18 years of age may be eligible to receive general harm reduction services
but are prohibited from syringe services. New participants will complete an intake questionnaire with a
trained staff member. The intake is used to collect data and assess for potential education and service
needs, as well as to review syringe service policies and procedures. Once these policies are reviewed,
including the Participant Rights and Responsibilities (located in Section 6), participants will sign the form
with their unique identifier to denote their agreement to follow them.



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After Intake (for new participants only) and ID verification, the participant will be directed to the
designated syringe return area to assess amount being returned and to be distributed per “Syringe
Collection and Distribution Policy.” They will then go to an exam room or the Harm Reduction Program
Coordinator’s office for privacy where they can more freely discuss any other services, referrals,
education, and supply needs with the appropriately trained staff member. They will then receive their
supplies and the visit is concluded.


4.4 ID POLICY
 • At each visit participants must present proof of WV Identification to receive syringe services.
 • The WHC Harm Reduction Program will not make copies of identification to protect participant
 confidentiality.
 • A unique identifying code will be assigned to the participant after ID verification that includes last
 letter of their first name, first letter of their mother’s name, first three letters of the city they
 were born in and the day they were born. (If a participant does not know their mother’s name,
 they can choose another parent or X can be substituted.) For example, Jane was born on January
 18th in Charleston, WV to her mother, Mary. Her code would be EMCHA18.

 Acceptable forms of Identification:
 • WV DMV issued ID
 • WV Birth Certificate (or completed application)
 • WV Medical Record
 • WV Insurance Card
 • Verification of homelessness on WV by a WV homeless service worker
 • Rental lease
 • Utility bill (or other form of official mail such as court documents, government agencies)
 • A pay stub or W2 showing a WV address
 • A WV hunting, fishing, or any other recreational ID.
 • WV DMV Affidavit of West Virginia Residency
 https://transportation.wv.gov/DMV/DMVFormSearch/Res-
 Aff_Affidavit%20of%20WV%20Residency-WF.pdf
 • COVID-19 Vaccination Card (or other vaccine record)
 • Voter Registration
 • Vehicle Registration
 • Tax document
 • Proof of WV public assistance
 • WV bank statement
 • WV auto insurance card
 • Letter from a WV homeless shelter, hotel, senior citizen's home, rehabilitation center, nursing
 home, children’s home, orphanage, shelter, battered women’s shelter, or Job Corps, including
 the facility’s physical address, that explains that the applicant is a resident at their facility
 (letterhead is preferred, but not required)
 • Pharmacy Record showing WV Address
 • WV State Harm Reduction Program Identification Card *only for clients who can be verified to
 have presented one of the above documents


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 o The WHC Harm Reduction Program card will include the participant’s code, WHC Harm
 Reduction Program contact info, and a notice of the immunity provided by WV law to
 protect those returning used syringes.



4.5 SYRINGE COLLECTION AND DISTRIBUTION POLICY
Syringes will be furnished and collected from participants according to the agency’s protocol with
purpose of providing a sterile syringe for each injection and a goal of 1:1 return ratio.

4.5.1 Syringe collection
 • Returning participants will be required to return used syringes in proper puncture proof container
 or to safely deposit syringes in a container provided onsite to be eligible to receive syringes.
 • A trained staff member will direct the participant to the exchange area and provide instruction
 based on the materials being returned.
 o If a participant has loose syringes, not in a container, they will discard each of syringes
 one by one in a large see-through sharps container on the floor in the designated
 exchange area. The number discarded will be weighed as they are placed in the
 container.
 o If a participant has used syringes in a sealed, previously issued sharps container, they will
 be instructed to remove the lid so WHC Harm Reduction Program staff can visually
 inspect the contents. Then the participant will be asked to set the container on the scale
 placed on the floor. WHC Harm Reduction Program staff will note the weight of the
 container and its contents. The weight of the container will then be subtracted from the
 total to determine the respective volume of syringes based on previously determined
 reference weights and measurements.
 o If the participant returns a puncture resistant household container such as a bleach
 bottle, they will be instructed to remove the cap so WHC Harm Reduction Program staff
 can visually inspect the contents. The participant will then place the container on a scale.
 The staff will note the weight of the container and its contents. The weight of the
 household container will then be subtracted from the total weight to determine
 respective volume of syringes based on previously determined reference weights and
 measurements.
 • All returned containers will then be boxed up in accordance with the current waste management
 policy and stored in a locked area until picked up by a contracted waste disposal company.
 • New participants will not be required to provide used syringes to receive initial supply.
 • Returning participants must return a minimum of 90% of the syringes they were given on their
 last visit. Participants will be encouraged and incentivized to return with at least 100% of
 previously distributed syringes. For participants who do not return with at least 90% of their
 syringes, the following procedures will be followed:
 ▪ First occurrence: A verbal warning by the Harm Reduction Program Coordinator
 and a reduction in the number of syringes given (I.e., if they were initially given
 50 and only returned 25, they will be given 25). An action plan will be created by
 the participant and Harm Reduction Program Coordinator to mitigate syringe



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 loss, which may include more frequent visits, different styles of sharps containers
 or addressing other mitigating factors.
 ▪ Second occurrence: A formal written warning by the Harm Reduction Program
 Coordinator, as well as a further reduction in syringes given.
 ▪ Third occurrence: Participant will be suspended from the WHC Harm Reduction
 Program for four weeks, after which they must complete the initial intake
 process again. Participants will be provided with safe use kits and any additional
 materials to help increase safety during this period.
Syringe Distribution
 • For New Participants: After intake process is complete, WHC Harm Reduction Program staff will
 predict the number of syringes needed based on reported number of injections per day, duration
 of time until next visit, and travel distance.
 o The participant may opt to receive any combination of available syringes to best match
 their injection needs. See “Syringe Descriptions” for available syringes.
 • For Returning Participants: The number of syringes provided to return participants will depend on
 the noted volumes of retuned syringes as noted in the Syringe Collection Procedure.
 • Prior to distribution, syringes will be weighed and weight/number of syringes distributed will be
 written down along with participant’s unique identifying code.
 • The participant will then be provided a puncture resistant sharps container of a size that best
 corresponds to the number of syringes provided.


4.6 SYRINGE DESCRIPTIONS
In the event a discarded syringe in the community must be identified as being distributed by the WHC
Harm Reduction Program, the following descriptions can be applied. All syringes distributed by the WHC
Harm Reduction Program will also be marked with a small round green sticker.

 • Easy Touch Insulin Syringe: Clear barrel, black text, orange needle and plunger caps,
 fixed/attached needle
 o 1cc (mL) or 100 units-large hash marks in increments of 10 with individual hash marks
 from 1-100
 o Text on Barrel: Easy Touch (logo), “USE U-100 INSULIN ONLY, SINGLE USE ONLY”
 ▪ 29 gauge, ½” needle, referred to as “longs”
 ▪ 30 gauge, 5/16” needle, referred to as “shorts”

Any discarded syringes found in the community may be returned to WHCWV for proper disposal, even if
found to not have been distributed by the WHC Harm Reduction Program.


5 HARM REDUCTION SERVICES OFFERED

5.1 REGULAR HARM REDUCTION CLINIC
The regular Harm Reduction Program Clinic hours will be Monday afternoons beginning at 1:00pm and
ending at 5:00pm as well as Thursday and Friday mornings beginning at 9:00am and ending at 12:00pm.
The regular Harm Reduction Program is available to anyone who feels that they need services or supplies

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on a walk-in basis. Any participants who arrive during Harm Reduction Program Clinic hours will be served
if they meet the requirement laid out by the State Code.


5.2 MOBILE HARM REDUCTION OUTREACH (NO SYRINGE SERVICES)
The Harm Reduction Program Coordinator will provide mobile outreach on Wednesdays beginning at
2:00pm and ending at 4:00pm. This outreach will consist of distribution of naloxone, safer use kits and
wound care kits, as well as providing referrals and information about various healthcare services to
participants. Rotations will vary week to week but will aim to service areas of highest need around
Charleston. PLEASE NOTE: NO SYRINGES WILL BE COLLECTED FROM PARTICIPANTS OR DISTRIBUTED TO
PARTICIPANTS AT THIS MOBILE OUTREACH. Participants interested in syringe services will be directed to
visit the clinic during regular Harm Reduction Clinic hours, as outlined above.


6 PARTICIPANT RIGHTS AND RESPONSIBILITIES
At the WHC Harm Reduction Program, we believe in compassionate and non-judgmental care. We strive
to provide the best possible care. By making sure participants understand their rights and
responsibilities, we are better able to provide care and meet people “where they are.” During the intake
process, the participants will be provided the following list of Rights and Responsibilities, both verbally
and in writing. This will also be available at the front desk and in the waiting room.

As our participant, you have the right to:

 • Be treated with dignity and respect regardless of race, ethnicity, sex or gender expression, sexual
 orientation, national origin, religion, class, veteran status, medical status, or physical or mental
 ability or any other status.
 • Be informed verbally and in writing of program rules and regulations and rights and
 responsibilities.
 • Be respected and have the right to privacy and to understand the extent of confidentiality (i.e.
 threats of harm to self or others and requirements for reporting abuse).
 • Understand that participation in any research project is completely voluntary and will not affect
 the services you are provided.
 • Information regarding all services and supplies available, including education on the use of
 supplies or any other services provided.
 • A 30-day advance notice of any changes in program or program hours or location via signage and
 social media.
 • File a complaint by filling out a WHC Harm Reduction Program complaint form (Appendix C) or
 calling 304-344-9834 and ask to speak to the Executive Director. You may file a complaint directly
 to the WV Office of Health Facilities and Licensure by calling 304-558-0050 or by visiting
 http://ohflac.wvdhhr.org/
 • Based on the new licensure law for syringe access, you have the right to return used syringes to
 the WHC Harm Reduction Program without prosecution.



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 • While all services are free of charge, should there be a charge for any supplies or services in the
 future you will be notified prior to providing the service or supplies.

As our Participant, you have the responsibility to:

 • Be responsible for the syringes you are given and return used syringes to WHC Harm Reduction
 Program in the provided sharps container.
 • Treat all members of the WHC staff and clientele with respect and without physical, sexual, or
 verbal threats, intimidation or solicitation. No violence will be tolerated.
 • Do not buy, sell, or use any illicit substances or paraphernalia on the property or in the
 surrounding areas at any time.
 • Do not loiter, sleep or store things on the property or in the surrounding areas.
 • Protect the confidentiality of others you encounter at the program.
 • Take only what is needed and dispose of used materials and supplies properly.
 • Clean up drug-related waste in the community and bring used syringes gathered off the street to
 WHC Harm Reduction Program for proper disposal.


6.1 CONFIDENTIALITY
WHC Harm Reduction Program participants have the right to confidentiality regarding their use of harm
reduction and syringe services, their patient care, and any data collected. However, there are limits to
confidentiality in our setting which include the following circumstances.

 • The participant is in imminent, credible harm or is a threat to themselves or others (that can be
 proved by observed actions or language from that participant).
 • The participant has admitted to or shows reasonable suspicion to be abusive (physically,
 financially, or sexually) towards a minor child, elderly person, or person with a disability).

In the event of the above circumstance the appropriate intervention will be made which includes, but is
not limited to, making a report to the Department of Health and Human Services 24-hour Child Protective
Services and Adult Protected Services hotlines, or contacting the appropriate local authorities such as 911
dispatch.


6.2 NON-DISCRIMINATION
WHCWV is an Equal Opportunity Employer. WHCWV does not discriminate in the provision of services
based on race, gender, gender identity, sexual orientation, family status, disability, socioeconomic status,
mental health, or housing situation. WHCWV will provide needs-based and person-centered support and
services to all populations, including those most vulnerable.


6.3 SPECIAL POPULATIONS
The WHC Harm Reduction Program is committed to serving the most vulnerable populations. The WHC
Harm Reduction Program and WHCWV will provide needs-based and person-centered support and
services to the following vulnerable populations which include, but are not limited to; youth, transitional
aged youth (18-25), sex workers, people who use drugs, people who are discharged from incarceration or


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hospitalization, people with psychiatric conditions, members of the LGBTQ+ community, and people of
color. The WHC Harm Reduction Program is committed to continually learning and increasing ways to
make our services and environment more inclusive to all underserved populations.

6.3.1 Participants with kids
No WHC Harm Reduction Program staff may be responsible for any child present with a participant during
syringe services. In the event that a child must accompany a participant, they must provide their own
guardian to supervise children while they receive syringe services. At no time should a child be in any
area where syringe services are taking place.


7 DATA COLLECTION AND QUALITY ASSESSMENT

7.1 DATA COLLECTION
The WHC Harm Reduction Program will collect data regarding program participants and activities which
will allow for reporting to agencies and grants as well as provide useful information for quality assessment
and performance improvement. Data reporting and analysis will be completed at different intervals and
reported with different processes, depending on the grant or agency in which it is being reported. An
annual report may be submitted to the state on a form provided by the Director that includes at a
minimum, total number of participants served, number and types of syringes dispensed, collected, and
disposed of, number of needle stick injuries, number of participants entering SUD treatment, and number
and types of referrals made for SUD treatment and other services. Data is collected and stored
indefinitely in a HIPAA compliant database. Data will sometimes be collected on paper in real time and
entered in the database by a trained WHC Harm Reduction Program staff member and original papers will
be shredded. All data is de-identified and is subject to all state and federal rules for privacy and
confidentiality. De-identified data will be made available for investigative and audit purposes when
requested. Data to be collected will include at a minimum; birth year, initials, race, ethnicity, zip code, sex
or gender identity, preferred language, pregnancy status, referrals made, syringes provided, syringes
returned, naloxone distribution, and overdose reversals.
If the participant is willing and eligible to become a patient at the Women’s Health Center of West
Virginia, then medical documentation will occur in the regular electronic medical record. No information
entered into the electronic medical record system will identify this patient as a WHC Harm Reduction
Program participant. It is the participant’s decision to share this information with their medical provider.
Based on WHCWV’s document destruction policies, all patient or participant information will be retained
for a minimum of 6 years. Information in the electronic medical record or any database will not be purged
but may become inactive in the system. For anyone under the age of 18 years of age, documentation will
be held 6 years past the date of their 18th birthday.




7.2 REDCAP AND OFFICE OF HEALTH SERVICES COLLABORATION
Support of Harm Reduction Programming | Data Collection, Data Stewardship, and Evaluation Planning
West Virginia University School of Public Health, Office of Health Services Research



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7.2.1 Background
The West Virginia University (WVU) School of Public Health, Office of Health Services Research (OHSR)
offers a secure, standardized, web-based harm reduction program (HRP) tracking and reporting system to
communities and organizations interested in supporting existing and building new HRPs. This is an
ongoing extension of support, intended to be inclusive of but not limited to the requirements of the
Office of Health Facility Licensure & Certification through the West Virginia Department of Health and
Human Resources. As background, OHSR has over a 40-year history in working with West Virginia
communities and health systems to better position and empower partners to make data-driven decisions
for priority health care needs. This work includes: health analytics support to primary care systems, local
health departments, and other community-based organizations; technical assistance and training on
health data quality and integrity; practice-based research training and implementation; informatics
support in merging and analyzing data from disparate systems; return-on-investment analyses; and
creation of data-centered referral systems across primary care and community partners for collective
impact in meeting the needs of communities and demonstrating program effectiveness.

7.2.2 Data Collection and Evaluation
OHSR has worked closely with two states based HRPs to gain an understanding of the data collection and
evaluation needs of these programs. To that end, OHSR has worked directly with HPR partners to build a
comprehensive, web-based clinical information database allowing HPRs to securely and reliably track and
report data on their HRP participants. This database is built within the Research Electronic Data Capture
(REDCap) platform, an internationally recognized solution for creating custom, secure, HIPAA compliant
data tracking and reporting. The database was built in collaboration with HRP partners and allows
partners to track key metrics more easily and more systematically such as:

 • Number of new and returning participants
 • State and county of residence
 • Gender
 • Employment status
 • Educational attainment
 • Insurance status
 • Dates of service
 • Time history of drug use
 • Preference in choice of drugs
 • Number of Naloxone kits received
 • Number of sharps containers received
 • number of syringes and needles dispensed, collected, and disposed of
 • Patterns of behavior in terms of sharing needles and other equipment
 • Human immunodeficiency virus (HIV) testing and results
 • Hepatitis B (HBV) and Hepatitis C (HCV) testing and results
 • Experience with overdosing
 • Experience in abstaining from drug use
 • Referrals made to medication assisted treatment, peer recovery programs and other applicable
 programming
 • Prevention education and materials provided


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 • Comprehensive/community services provided
 • Past recovery program participation

OHSR will work with each HRP to review initial (baseline) data and develop a plan for real-time data
monitoring and milestone evaluations of those data (such as monthly, quarterly, 6-month, and/or 12-
month reporting intervals). Reporting in REDCap offers each HRP the ability to reliably query their own
data, with OHSR providing a central administration of the data – allowing for ongoing checks of data
quality and completeness, with feedback to each HRP as needed. Data will be evaluated on participant,
site and organization levels, with the ability to interlay geographic information system level analyses to
help highlight program reach, impact, and potential gaps.

7.2.3 Data Protections and Data Stewardship
OHSR has extensive experience working with sensitive health related data in health care and community-
based settings as well as having an infrastructure in place for securely treating those data. All HRP-
related data collected via REDCap will reside on a secure, cloud-based server. REDCap is a HIPAA
compliant web-based software, designed for housing sensitive health related data. This software allows
for user-level auditing and tracking. Each HRP member accessing REDCap will have her/his own user ID
and password, combined with a two-factor authentication for added protection. At the WHC Harm
Reduction Program, only the Harm Reduction Program Coordinator and Program Administrator will have
REDCap access. REDCap functions with and without internet access. An app version of REDCap is
designed to function in off-line environments, providing a reliable means of data collection in situations in
which internet is unreliable or not available. Once the device has internet access, the data will be pushed
to upload. All data downloaded from REDCap for more in-depth analysis by OHSR for HRP needs will
reside on a secure virtual desktop infrastructure called VMware Horizon. This platform is provided to
OHSR by the WVU Health Sciences Center (HSC) Information Technology Services. This solution has been
deployed across the HSC to support the secure storage and use of sensitive data. All data entered into
REDCap by HRPs will remain the property of those HRPs. OHSR aims to help facilitate standardized,
reliable data tracking and reporting across West Virginia, with an emphasis on providing ongoing data
analysis, evaluation, and feedback to HRP partners. At any point in time, with or without explanation,
HRPs can request their data to be downloaded from REDCap and provided to them in common data
formats such as comma separated value (.csv), text (.txt), or Excel (.xlsx) for example. Prior to REDCap
implementation, OHSR will work with HRP leadership to put in place the necessary memorandum of
understanding and business associate agreements needed.

7.2.4 Training and Technical Assistance
OHSR will offer training and technical assistance to HRP partners at time of implementation and ad-hoc
based-on partner needs. OHSR is sensitive to varied levels experience with and comfort in using
computer-based systems and customizes training to suite partner needs and expectations. If HRP data is
housed in another electronic system or spreadsheet, OHSR will also offer technical assistance in importing
those data into REDCap to eliminate loss in historic information.


7.3 QUALITY ASSESSMENT
The WHC Harm Reduction Program seeks to provide quality care and services to participants. The
program centers the concerns of participants and tries to include people who use drugs in the ongoing
development of goals and objectives for effective and quality services.

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Procedure: The program administrator is responsible for and will review at least annually the
development, implementation, maintenance, and effective evaluation of quality assessments for
performance improvement and effectiveness.

This review will include the following:

 1. Data collected through the time being reviewed
 2. Services provided
 3. Participant surveys and feedback
 4. Any adverse events or incidents that have occurred during the time being reviewed
 5. Any community relations issues or grievances filed during the time
 6. Staff performance reviews and annual credentialing information
 7. Review of current policies and procedures
 8. Infection Control issues
 9. Participant outcomes, I.E. overdose reversals, treatment referrals, screenings performed, and
 people referred for medical care, etc.

The review team will be established by the Program Administrator to look at data and information listed
above and to develop recommendations for improvements to the program and/or modification of
policies and procedures. This review team may include at a minimum a representative from the WHC
Harm Reduction Program staff, a volunteer representative, the Medical Provider, and WHC Harm
Reduction Program participants. Representatives from select referral agencies or a WHCWV Board
member may also be included depending on the issues that arise during the review.

Quality assessment and performance improvement goals will be developed for the year ahead based on
the team’s findings.

The results of this review will be available to OHFLAC upon request. The information will also be shared
with the WHCWV Board of Directors.


8 COMMUNITY RELATIONS

8.1 COMMUNITY ENGAGEMENT
WHC Harm Reduction Program and WHCWV will document positive interactions between local law
enforcement or first responders and program staff members, contracted individuals, volunteers, and
participants in their role as program participants. WHC Harm Reduction Program will document positive
feedback expressed by participants, community members, neighborhood associations, or local law
enforcement officials. WHCWV will document the steps taken by the syringe services program and harm
reduction program have taken to address any reasonable concerns. These positive interactions should be
reported to the Harm Reduction Program Coordinator or the Executive Director of WHCWV in writing.

WHCWV and the WHC Harm Reduction Program will continue to provide ongoing engagement with the
community regarding Harm Reduction. This includes training upon request from any person or agency
who is interested in learning about harm reduction topics such as overdose recognition and reversal,
infectious diseases, and substance use. WHC Harm Reduction Program staff, volunteers and participants

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will also participate in monthly syringe pickups in the area around the clinic and in the surrounding
neighborhoods. For more information, see “Community Clean Up”.

The WHC Harm Reduction Program will maintain relationships with the municipalities and counties that
the program operates with-in. The WHC Harm Reduction Program will maintain a social media presence
to inform participants and community members regarding updates of the harm reduction and syringe
service programs, as well as educational materials about harm reduction.


8.2 COMMUNITY, GOVERNMENTAL, AND LAW ENFORCEMENT CONCERNS
It is the intent of WHCWV and the WHC Harm Reduction Program to cooperate fully with investigations
regarding legitimate complaints. Incidents involving the WHC Harm Reduction Program, including
community objections or concerns, law enforcement or governmental complaints and potential legal
action against the WHC Harm Reduction Program, must be reported, addressed, and documented by
WHC Harm Reduction Program. WHC Harm Reduction Program staff will adhere to the following process
when addressing or reporting community or law enforcement concerns:

8.2.1 Reporting, addressing and documenting community or law enforcement concerns

 • Incidents related to the WHC Harm Reduction Program must be immediately reported to the
 executive director, verbally and in writing within twenty-four hours of the incident. The purpose
 of the report is to ensure documentation of incidents to identify and address potential problems.
 • The executive director shall inform the WHCWV Board of Directors within 48 hours of any
 incident and provide recommendations for appropriate interventions.
 • Appropriate interventions related to the incident will be identified and executed.
 • Quarterly review of incidents and adverse effects will include the following review



8.2.2 Governmental Complaints
 • WHCWV will make available participant and program records related to the WHC Harm
 Reduction Program to governmental agencies and will comply with reasonable requests to
 observe service delivery and interview participants with proper consent.
 • WHCWV and the WHC Harm Reduction Program will develop and follow recommended plans of
 correction, if necessary, based on any governmental investigation findings.
 • Any violation that poses a severe safety risk to participants, employees or volunteers will be
 corrected immediately.

8.2.3 Incident Reporting and Adverse Events.
The WHC Harm Reduction Program has developed and implemented policies and procedures for
documenting, investigating, taking corrective action, and tracking instances of known adverse events or
incidents. If a WHC Harm Reduction Program staff member has a concern about a participant’s or
accompanying minor child’s safety, the individual shall follow the policy and procedure set forth below.
All WHCWV or WHC Harm Reduction Program staff will respond to all safety concerns and take
appropriate action, including, but not limited to, reporting to the appropriate protective services agency.
Incident or adverse events may include:


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 • Known completed participant suicide and suicide attempts.
 • Known participant death or serious injury due to trauma, suicide, or unusual circumstances.
 • Selling drugs or substances on the premises.
 • Harassment or abuse, including physical, verbal, sexual, and emotional, of participants by staff.
 • Theft, burglary, break-in, or similar incident at the syringe services program.
 • Physical violence leading to injury; and
 • Significant disruption of services due to disaster such as fire, storm, flood, or another occurrence.
 • Related accidents or emergencies as stated previously in “Service Environment.”




Incidents or adverse events shall be reviewed on a quarterly basis by the program administrator who may
choose to make recommendations and implement changes regarding improvements in the process to
prevent further incidents. All adverse events will be fully documented on an adverse event form (see
Appendix A) and appropriately reported to the police or correct State Agency as necessary and promptly
reported to the harm reduction coordinator and the executive director within 24 hours of knowledge of
the adverse event.



A prompt investigation and review of the situation surrounding the incident or adverse event will occur
and a timely and appropriate corrective action will be taken. Ongoing monitoring of the corrective action
will take place until effectiveness of the action is established.



Within seven days of an incident or adverse event, the program will file a report with the Director of
OHFLAC consisting of the following:

 o The action or actions implemented to prevent the reoccurrence of the incident or
 adverse event.
 o The time frames for the action or actions to be implemented.
 o The person or persons designated to implement and monitor the action or actions; and
 o The strategies for the measurements of effectiveness to be established


8.3 COMMUNITY CLEAN-UP
The WHC Harm Reduction Program is dedicated to working with all community members on minimizing
syringe litter in the area. We provide guidance to participants on the importance of proper disposal and
strive to decrease the stigma of syringe litter with education, demonstration, and participation in
community clean-up events. The following are some of the ways the WHC Harm Reduction Program
collaborates with the community to decrease syringe litter:

 • Make it known to First Responders in Kanawha County, the local health department, and
 community members that, with notice, trained WHC Harm Reduction Program staff will go to a
 particular location within Charleston and surrounding areas to retrieve syringes found in the
 community during business hours. Discarded syringes may be reported by phone, in person, or


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 email. Outside of business hours, syringe litter may be reported to the 24/7 SOAR Syringe Hotline
 by texting or calling 304-932-0087. A record will be kept of any syringes collected as a result of
 these community reports.
• The WHC Harm Reduction Program will work with all First Responders in the surrounding area to
 provide sharps containers and additional training if needed.
• All sharps collected in the community by First Responders or community members may be
 returned to WHCWV for proper disposal, either directly to WHC Harm Reduction Program staff or
 by utilizing the syringe drop box located in the WHCWV parking lot.
• WHC Harm Reduction Program staff, volunteers and participants will also participate in monthly
 syringe pickups in the area around the clinic and in the surrounding neighborhood.
• Partner with Public Works, City of Charleston, Code Enforcement, and local landlords to remove
 syringe litter from abandoned properties and encampments.




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Appendix A




 Women’s Health Center of WV Harm Reduction Program
 Incident & Adverse Event Report
Date: _________________
Person Reporting: ________________________________
Participants Involved (list by code or name): _______________________________________
Description of Adverse Event (add sheets as necessary):
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
_____________________________________________________________________________
Signature of Reporting Individual__________________________________
Report Within 24 hours to: Harm Reduction Coordinator or Executive Director
Plan of Correction (add sheets as necessary):
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
_____________________________________________________________________________
Signature of Harm Reduction Coordinator: __________________________________
Signature of Executive Director: ______________________________________
Executive Director Report To:
_______Women’s Health Center of West Virginia Board of Directors within 48 hours
_______OHFLAC Director within seven (7) days
 Women's Health Center of West Virginia
 510 W. Washington St., Charleston, WV 25302
 (304) 344-9834

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Appendix B




 Women’s Health Center of WV Harm Reduction Program
 Referral Form
Participant Need: __________________________________
(For Example: Medical Care, Behavioral Health/Mental Health Care, Homeless Services, SUD
Treatment, Clothing, Food, Family Planning & Birth Control, STI Testing & Infectious Disease
Treatment)
 Options to Obtain Contact Information for How to Obtain Service:
 Needed Services: Service:


 1.



 2.



 3.


Participant Code or First Name: _______________________________
 Follow Up Info (if applicable)
If yes, how can they be contacted? Text Email Phone Call Contact
Info:________________________________________
Follow Up Appointment Date/Time (if requested): ____________________________
Or, does participant want to meet at next exchange? If so circle & write date
M (1-5pm):______ Th (9am-12pm): ________ F (9am-12pm): ________
Staff to ask for:___________________________________


 Women's Health Center of West Virginia
 510 W. Washington St., Charleston, WV 25302

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(304) 344-9834




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Appendix C




 Women’s Health Center of WV Harm Reduction Program
 Complaint Form
I wish to remain anonymous: Yes or No
Participant Code or Name: ____________________________
Email or phone number (if you want a personal reply): ______________________________
Date of Incident: ___________________________
Please describe the issue or incident that occurred:
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
How could we do better:
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________
_____________________________________________________________________________________

 Staff Use Only
Reviewed by:_____________________________ Date: ______________________
Corrective Action:
______________________________________________________________________________
______________________________________________________________________________
______________________________________________________________________________
_____________________________________________________________________________
 Women's Health Center of West Virginia
 510 W. Washington St., Charleston, WV 25302
 (304) 344-9834




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35


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Appendix D




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37


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Appendix E




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39


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