Employment Plan Office

The Employment Plan Office is staffed by CCH employees tasked with overseeing and supporting compliance with the Employment Plan, Employment Plan Manual, and Personnel Rules.


What is the Employment Plan? The Employment Plan is a document including the processes that govern hiring at Cook County Health (“CCH”). Because of CCH’s broad array of job types, there are several processes, but they are all designed to hire qualified candidates. They are also transparent, meaning that CCH hiring teams are required to document actions taken in accordance with the applicable process as well as the bases for their decisions.

The Employment Plan is supplemented by a Supplemental Policies and Procedures Manual that includes transparent processes, practices and procedures that govern non-hiring Employment Actions such as discipline, demotion, and the reclassification of positions.

Both the Employment Plan and Supplemental Policies and Procedures Manual prohibit CCH leaders from considering Political Reasons and/or Factors such as an employee, applicant, or potential applicant’s political affiliation in making decisions related to CCH Employment Actions.  Decisions based upon other unlawful factors are also prohibited.

The Employment Plan requires both internal and external oversight of CCH’s implementation of Employment Actions governed by the Employment Plan and Employment Plan Manual. Human Resources not only establishes, directs and coordinates employment actions, but also provides oversight to ensure compliance with the Employment Plan, Supplemental Policies, Personnel Rules, and other applicable requirements (e.g., CBAs). The Employment Plan Office (“EPO”) is a CCH employee responsible for providing internal oversight over both Human Resources and our departmental leaders’ employment-action related activity and providing guidance to support compliance with the Employment Plan, Supplemental Policies and Personnel Rules. For a more detailed description of the EPO’s duties, please click here. The Office of the Independent Inspector General (“OIIG ”) is a Cook County agency that provides external oversight of CCH’s implementation of the Employment Plan.
  • The EPO and OIIG have full access to CCH Employment Actions, meaning that may observe activity in real-time and may audit processes via document review to assess for compliance with the applicable rules.
  • Both offices also have investigative functions where non-compliance is reported or suspected.
    • Employees are required to report known or suspected non-compliance and to cooperate with investigations.
    • Retaliation for cooperating is strictly prohibited. Allegations are taken seriously, and anyone found to have retaliated would be subject to disciplinary action, up to termination.
Both offices have reporting requirements which provide transparency into their observations and determinations related to CCH’s activities and compliance.

All Employees are required to adhere to Employment Plan and Employment Plan Manual requirements. There is no mechanism for permitting modification of CCH processes on a case-by-case basis. Structure is necessary to ensure that CCH is meeting legal and organizational requirements and that requisite transparency is provided.

Where necessary (such as when there have been organizational or operational changes that require new or updated procedures), the Chief Executive Officer (“CEO”) has the authority to amend the Employment Plan. However, changes must first be proposed to both the EPO and the OIIG , and they must have an opportunity to review and comment prior to implementation. Their interest is in evaluating whether the proposed change comports with the spirit of the Employment Plan, meaning that the proposed process is transparent and not vulnerable to Unlawful Political Discrimination (decision-making based upon Political Reasons and Factors). If objections are raises, the CEO, CHRO, EPO and OIIG meet to discuss the stated concerns before the CEO makes a final determination.

The CCH Human Resources (“HR”) Department has the authority to update the Employment Plan Manual with EPO and OIIG approval. The EPO and OIIG review proposed modifications to verify that the policy comports with the spirit of the Employment Plan. If approved (or in the absence of a timely objection), HR posts the update on the CCH website. For a more detailed description of the EPO’s duties, please click here.

Please note that a majority of CCH’s workforce is unionized. Collective Bargaining Agreement (“CBA”) requirements must be applied instead of Employment Plan, Employment Plan Manual and/or Personnel Rules requirements in the event of a conflict (so long as the CBA does not involve or permit the use of any Unlawful Political Discrimination or Unlawful Political Contact).

In addition to providing structured processes for hiring and other Employment Actions that require documentation to support decision-making, the Employment Plan requires CCH to provide access to the following (available on the HR page of this website):
  • Current Job Descriptions
  • Job Postings
  • Employment Statistics (Quarterly Reports)
  • CCH’s response to OIIG investigation-related recommendations
The EPO is also required to post Semi-Annual (covering the EPO’s observations and Plan-related activities) on the website. For a more detailed description of the EPO’s duties, please click here.
The office’s primary responsibilities include:
  • Training Employees on the Employment Plan and Employment Plan Manual. All employees are introduced to the fundamental principles, an overview of the main hiring processes, and to the obligations and protections that apply to all employees.
    • Departmental leaders and Human Resources staff receive additional training necessary to implement our hiring processes and non-hiring Employment Actions.
  • Overseeing and Supporting Compliance with the Employment Plan. The Employment Plan Office has authority to observe and audit CCH Employment Actions to evaluate compliance, and to provide guidance and/or recommend remedial measures where necessary to support compliance.
  • Investigating Reports and Complaints of Known or Suspected Non-compliance. The EPO investigates alleged or suspected non-compliance and issues Incident Reports containing findings and any recommendations.
  • Reporting Known or Suspected Political Contacts and Unlawful Political Discrimination. The EPO refers all Political contacts and all allegations of Unlawful Political Discrimination to the OIIG and the OIIG will follow up as appropriate as the OIIG has sole jurisdiction to review and evaluate Political Contacts and to investigate allegations of Unlawful Political Discrimination.
    • Employees have a duty to report all Political Contacts and all known or suspected Unlawful Political Discrimination to the OIIG.
  • Preparing and Posting Semi-Annual Reports. The EPO issues semi-annual reports by March 15th and September 15th of each year describing activities, observations, and investigative findings and addressing violations identified and remedial actions recommended and posts them on the CCH website. Use this link to access past reports.
  • Reviewing Employment Plan and Employment Plan Manual. The EPO reviews proposed amendments to the Employment Plan and Employment Plan Manual and raises objections where the proposed process or procedure lacks requisite transparency.
  • Producing Requested Information. The EPO produces redacted Incident Reports, redacted copies of HR’s responses to Incident Reports, and the Ineligible for Hire List upon request. Use this link to request documents from the EPO.

If you have a concern regarding potential non-compliance with the Employment Plan, Employment Plan Manual or Personnel Rules , please submit a Complaint Form or contact the Employment Plan Officer directly.  You may also contact the CCH Chief Compliance & Privacy Officer.

Kimberly Craft, Employment Plan Officer

1950 W. Polk St., 9th Floor
Chicago, IL 60612

(312) 864-0368

Nicole Almiro, Chief Compliance & Privacy Officer

1950 W. Polk St., Suite 9217
Chicago, IL 60612

Corporate Compliance Hotline: (866) 489-4949

To report a Political Contact or known or suspected Unlawful Political Discrimination, please contact the Interim Independent Inspector General directly or submit a completed Political Contact Log  or Complaint Form.

Steven Cyranoski, Interim Inspector General

69 W. Washington
Suite 1160
Chicago, IL 60602
(312) 603-0350