Standards for public agencies

2020 Edition

Employee Assistance Program Services (PA-EAP) 6: Contractor Accountability

The EAP implements a mechanism to ensure that affiliates and subcontractors comply with EAP policies and procedures.


The EAP will need to demonstrate implementation of standards that address services provided by subcontractors. Implementation can be demonstrated via the contract that outlines elements of standards, and a mechanism to monitor quality. Subcontracting agencies are not required to be accredited, but as noted in the interpretation to PA-EAP 6.04, implementation of the standards can support quality improvement.
NA The EAP does not use affiliates or subcontractors.
2020 Edition




Employee Assistance Programs help agencies achieve business health and productivity goals, and support individuals working to maintain or improve their productivity, functioning, and pro-social behavior, as well as remain at or return to the workplace.
Note: Agencies must also implement the standards in PA-PQI 6 and PA-PQI 7 when they contract with subcontracting agencies. 
Full Implementation, Outstanding Performance
A rating of (1) indicates that the agency's practices fully meet the standard and reflect a high level of capacity.  
  • All elements or requirements outlined in the standard are evident in practice, with rare or no exceptions: exceptions do not impact service quality or agency performance. 
Substantial Implementation, Good Performance
A rating of (2) indicates that an agency's infrastructure and practices are basically sound but there is room for improvement.
  • The majority of the standards requirements have been met and the basic framework required by the standard has been implemented. 
  • Minor inconsistencies and not yet fully developed practices are noted; however, these do not significantly impact service quality or agency performance.

Partial Implementation, Concerning Performance
A rating of (3) indicates that the agency's observed infrastructure and/or practices require significant improvement.  

  • The agency has not implemented the basic framework of the standard but instead has in place only part of this framework.  
  • Omissions or exceptions to the practices outlined in the standard occur regularly, or practices are implemented in a cursory or haphazard manner.  
  • Service quality or agency functioning may be compromised.  
  • Capacity is at a basic level.
Unsatisfactory Implementation or Performance
A rating of (4) indicates that implementation of the standard is minimal or there is no evidence of implementation at all.  
  • The agency’s observed service delivery infrastructure and practices are weak or non-existent; or show signs of neglect, stagnation, or deterioration.
Self-Study EvidenceOn-Site EvidenceOn-Site Activities
  • Sample affiliate agreement
  • Procedures for conducting random quality improvement reviews of affiliates and subcontractors
No On-Site Evidence
  • Interviews may include:
    1. Program director
    2. Affiliates
  • Review affiliate client records

PA-EAP 6.01

Affiliate agreements address:
  1. compliance with all applicable laws, including health, safety, and accessibility laws;
  2. record maintenance;
  3. transfer of confidential information;
  4. hours of operation;
  5. CEU, PDH, and other professional training requirements, including training on the EAP's policies, procedures, and service delivery model;
  6. standards for physical facilities, including comfort and privacy provisions; and
  7. use of standard data collection and client information forms.


Record maintenance should address:
  1. ownership of records;
  2. information that must be recorded in client records;
  3. agency access to client records for internal and external quality oversight, including review by Medicaid and/or other external funders or regulators, and accrediting bodies;
  4. secure storage;
  5. destruction of records; and
  6. whether copies of records may be retained by the contractor.
NA The EAP does not use affiliates.

PA-EAP 6.02

Agreements with affiliates require them to carry professional liability insurance in the amount of $1 million/$3 million, or as required by applicable law.
NA The EAP does not use affiliates.

PA-EAP 6.03

The EAP routinely conducts random quality improvement reviews of a representative sample of affiliates used in the past year to assess:
  1. appropriateness of protocol and procedures;
  2. compliance with EAP contract requirements;
  3. attainment of the requisite credentials required of affiliates providing services, including assessment and referral, information and referral, and short-term counseling; and
  4. possession of current licensure, certification, or registration.


The EAP should determine an appropriate sampling methodology based on the volume of work affiliates produce (e.g., 10% of cases per year). Reviews can be conducted on-site or off-site through another quality improvement mechanism.
NA The EAP does not use affiliates.

PA-EAP 6.04

The EAP routinely conducts random quality improvement reviews of subcontractors to assess, as appropriate:
  1. appropriateness of service delivery procedures;
  2. safety of physical facilities;
  3. possession of current licensure; and
  4. compliance with EAP contract requirements.


Reviews can be conducted on-site or off-site through another quality improvement mechanism.
NA The EAP does not use subcontractors.
Examples: Examples of subcontracted services include, but are not limited to, legal services, work-life services, and financial services.