General Administration Personnel Policies
Leech
Leadership Team
Management Team
Division Directors
Program Managers
Businesses and other components
Chain of command
100. General Administration Personnel Policies
100.1 Equal Employment
100.2 LLBO Fair Employment Standard Policy
100.3 Employment-at-will
100.4 Nepotism
100.5 Code of ethics and conduct
100.6 Conflict of interest
100.7 Receipt of Monetary Value Gifts
100.8 Bonding
100.9 Confidential Information
100.10 Retaliation
100.11 Reservation Documents
100.12 Political Activities
100.13 Drug, Alcohol, and Substance Abuse
100.14 Background Checks
100.15 Anti-Harassment and Offensive Behavior
100.16 Cash handling
100.17 Firearms and Weapons
100.18 Unauthorized use of LLBO Internet/Computers and Software
100.19 Use of Internet
200. Human Resources
200.1 LLBO Hiring Practices
200.2 Rating System
200.3 Promote from within
200.4 Application Process
200.5 Posting Provision
200.6 Selection Provision
200.7 Internal Hiring Procedures and Promotion
200.8 Job Descriptions
300. Employee Relations
300.1 Personnel File administration
300.2 Personnel File review
300.3 Progressive Discipline
300.4 Types of disciplinary action
300.5 Disciplinary Infractions
300.6 Grievance Process
300.7 Appeal
300.8 Audits
400. Employee
400.1 Position Classification
400.2 Introductory employees
400.3 Introductory Supervisory and Management Staff
400.4 Former employees
400.5 Transfer employees
400.6 Attendance policy
400.7 Use of time clock
400.8 Normal business hours
400.9 Excessive Absenteeism and tardiness
400.10 No-call/no-show
400.11 Job abandonment
400.12 Employment Separation
400.13 Resignations
400.14 Gambling
500. Benefits & Compensation
500.1 Performance evaluations
500.2 Leaves
500.3 Rate of pay
500.4 Overtime
500.5 Double Compensation/Secondary Employment
600. Training and Career Development
600.1 Orientation
600.2 Career Development
600.3 Responsibility for Training
600.4 Organizational Training
700. Finance
700.1 Pay Periods
700.2 Deductions
700.3 Travel Requests
800. Personnel Procedures
100.13 Drug, Alcohol and Substance Abuse Procedure
100.14 Anti-Harassment and Offensive Behavior Complaint Procedure
300.6 Grievance Procedure
300.7 Appeal Procedure
300.8 Division, Department and Program Audits Procedure
500.1 Performance Evaluation Procedure
500.2 FMLA Procedure
500.2 Short-term Medical Leave Procedure
appendix for Procedures
appendix for Definitions
The purpose of the manual is to establish a uniform system of policies, and procedures where applicable, for employees under the domain and authority of the Leech Lake Reservation Tribal Council (herein after referred to as the LLRTC) and to provide administrative guidelines in day-to-day operations.
Reservation businesses and other components such as the Housing Authority, Gaming Division, Bug-O-Nay-Ge-Shig School, Tribal College, Leech Lake Tribal Police Department, etc. may have separate operating policies unique to their needs and success. However, their policies must not be in conflict with established Leech Lake Band of Ojibwe (herein after referred to as the LLBO) General Administration Personnel Policies (herein referred to as the GAPP). (LLRTC will intervene and exert general authority over these components when circumstances dictate or when it is in the best interest of the LLBO)
The LLRTC will act in the best interests of its employees and set forth measures to ensure an environment that promotes and protects the employment interests of the band.
The authority to waive or deviate from established policies and procedures without prior approval lies within the domain and authority of the LLRTC. This authority may be granted to the Leadership team by LLRTC resolution in order to fulfill the requirements and needs of the LLBO.
All external business enterprises that engage in consensual relations with LLBO must have approval of the governing body of the LLBO to conduct activities within the exterior boundaries of the Leech Lake Reservation and practice Indian Preference where applicable.
The LLRTC is the final authority for all transactions occurring within the exterior boundaries of the Leech Lake Reservation as they relate to Tribal employment activities. [Including all entities covered by LLBO TERO (Tribal Employment Rights Ordinance)]
Federal, State and local regulations, required licenses, stipulations and conditions may be used as a guideline in administration of the employees under the domain and authority of the LLRTC. All external stipulations and guidelines must be in compliance with the established procedures and protocols of the LLBO.
The LLRTC reserves the right to modify policies and procedures under their domain and authority, with or without prior notice, and that these policies do not constitute a contract. All employees are considered employees at will.
Furthermore, nothing in the GAPP constitutes or should be interpreted as constituting a waiver of the tribe’s sovereign immunity.
Leech Lake Reservation Tribal Council:
The governing body of the Leech Lake Band of Ojibwe is the Reservation Tribal Council (RTC) and is composed of five (5) members: Chairman, Secretary-Treasurer, and three (3) District Representatives representing each one (1) of the three districts on the reservation.
Leadership Team:
Executive Director
Controller
Human Resources Director
Legal Director (when applicable)
Management Team:
Management Team will comprise of Team leaders from each of the eight functional divisions.
Division Directors:
Division Directors are directly responsible to the Team Leader of their division.
Program Managers:
Program Managers are responsible to their Division Director.
Businesses and other components:
Businesses, Gaming, Bug-o-nay-ge-shig School Board, Tribal College Board of Trustees, Housing Authority Board of Commissioners, Tribal Court and other components are directly responsible to the Executive Director.
Chain of Command:
All employees of the Leech Lake Band of Ojibwe will follow their respective chain of command.
100. General Administration
100.1 Equal Employment Opportunity:
Within the scope of the LLBO Indian Preference, the LLBO will not discriminate in the administration of its employment policies on the basis of sex, race, age, religion, color, creed, political or sexual preference, disability, national origin, or marital status.
100.2 LLBO Fair Employment Standard Policy:
The Leech Lake Band of Ojibwe will follow all applicable federal rules and regulations. The band will also act in the best interest of its employees on a fair and consistent basis per its policies. The Leech Lake Band may apply Federal Fair Labor Standards Act when applicable.
100.3 Employment at will:
The establishment of these policies does not alter the employment-at-will status of this workplace and does not represent a binding employment contract.
100.4 Nepotism:
a. No supervisor shall appoint immediate members of his/her family or be involved, directly, or indirectly, with the vacancy selection process in section 200. Furthermore, no individual in a management or supervisory position will have direct supervisory authority over any immediate family member.
b. The LLBO defines “immediate family” as the employee’s spouse or significant other and will include: parents, children, siblings, aunts, uncles, nieces, nephews, grandparents, and grandchildren. These restrictions apply to Supervisors even if the “immediate family” members are not biologically related but are related through marriage.
100.5 Code of Ethics and Conduct:
a. The LLBO strives to ensure fair and honest treatment of all employees. All employees are expected to treat each other with mutual respect. Employees are encouraged to offer positive and constructive feedback to promote the continued growth and success of the organization.
b. The successful business and administration operations and reputation of the LLBO is built upon the principles of fair dealing and ethical conduct of its employees. Integrity and excellence require careful observation of the spirit and letter of all applicable laws and regulations, as well as scrupulous regard for the highest standards of conduct and personal integrity.
c. The continued success of the LLBO is dependent upon trust and is dedicated to preserving that trust. Employees owe a duty to the LLBO to act in a way that will promote their continued trust and confidence.
d. Employees are expected to conduct themselves in accordance with the letter, spirit, intent of all applicable laws and all codes of conduct pertinent to their Areas of Operations. Any illegal, dishonest or unethical conduct is prohibited.
e. In general, the use of good judgment, based on high ethical principles. Disregarding or failing to comply with this standard of ethics and conduct will lead to disciplinary action, up to, and including termination of employment and prosecution.
f. Any breach of this Code of Ethics and Conduct is subject to immediate termination by a majority vote of the LLRTC. This type of termination cannot be appealed.
100.6 Conflict of Interest:
a. Employees may not accept compensation from, or have financial interest in, or perform work for any other business or organization that supplies or seeks to supply the LLBO with materials or services or receive offers of free services. (see 100.5, LL Code of ethics and conduct). This is also applicable to Board Memberships.
b. Employees will have no affiliation/membership with boards or organizations that are in direct conflict with the ideas/goals of the LLBO
100.7 Receipt of Monetary Value Gifts:
a. All LLBO employees will not solicit or accept anything of monetary value for personal use or benefit from any organization/individuals whose interest may be affected by the employee’s action in the course of performing his/her duties. This includes sales-persons or companies that promise gifts for orders received. Violations of this policy will be immediate termination of employment and, at the discretion of the LLRTC, criminal prosecution.
b. Excluded from this provision are traditional gifts.
PROCEDURE: see appendix
100.8 Bonding:
All employees shall be covered under a blanket fidelity bond to ensure integrity in dealing with money or supplies while employed by the Leech Lake Band of Ojibwe. The companies insuring the Leech Lake Band of Ojibwe will be compelled to prosecute any prohibited actions regarding employee dishonesty. Additionally, any costs or damages incurred/paid by the insurance company would be compensable through an action against the employee in the Leech Lake Band of Ojibwe Tribal Court. All employees will be covered under a blanket of fidelity bond that will protect the LLBO in the event of employee theft.
100.9 Confidential Information:
a. As a condition of employment with the LLBO and it’s vested interests all employees will be required to have a Confidentiality Agreement containing the employee’s signature in their personnel file.
b. Refusal to sign the Confidentiality Agreement will be grounds for disqualification from employment with the LLBO, including the Band’s sub-entities.
100.10 Retaliation:
Any employee who files a complaint or who submits documentation showing a violation of a law or tribal policy will not be subject to any type of retaliation for this conduct. No discipline may be the result of the complaint.
100.11 Reservation Documents:
All documents and information pertaining to the LLRTC are the property of the LLBO. Inappropriate or unauthorized use or release of documents or information relating to activities of the LLBO without full LLRTC approval will result in termination of employment and/or prosecution. The LLRTC will direct legal counsel to pursue such matters for legal resolution.
100.12 Political Activities:
RTC Employees may:
a. Exercise their rights of citizenship by participating in tribal, local, state or national elections and public activities to the extent permitted by law.
b. Be a candidate for an RTC position, provided that such candidacy does not interfere with the performance of his/her assigned duties and/or responsibilities.
RTC Employees will not:
a. Use their authority or influence for the purpose of interfering with an election, nomination or affecting the results thereof.
b. Directly or indirectly coerce, command, or advise subordinates to pay, lend, or contribute anything of value for political purposes to any party, committee, organization, agency, or person:
c. Engage in any political activity outside the scope of assigned duties during scheduled working hours or neglect their assigned duties and/or responsibilities; personal leave must be used if an employee is going to conduct a campaign during his/her regular work hours.
d. Actively participate in a political protest during his/her work hours unless the employee takes personal leave.
100.13 Drug, Alcohol and Substance Abuse:
a. The Leech Lake Band of Ojibwe is committed to providing the utmost safety for all its employees in the work environment and has zero tolerance for drug, alcohol, and substance abuse in the workplace. As a condition of employment, applicants will be required to take a urinalysis prior to employment, within 48 hours of job offer, alcohol and drug prevention coordinator will contact applicant to schedule an appointment. Consideration will be given to extenuating circumstances for rescheduling of appointments. Refusal or failure will disqualify an applicant from employment consideration.
b. Employees convicted of a criminal drug statute violation occurring in the workplace will be terminated from employment.
c. Employees will be required to submit to random drug testing for drug/alcohol usage, or in the event reasonable suspicion exists. Refusal to submit to a test will be immediate termination from employment.
Prohibitions:
The LLBO prohibits the unlawful manufacture, distribution, dispensation, possession, use of controlled substance, or any other thing that could alter job performance adversely or pose a threat to the safety and welfare of the employee, other employees, or the public in the work place. Circumvention of this prohibition will be cause for immediate termination of employment. This includes all LLBO and sub-entity operations.
Failure to immediately report violations, (specific to job requirements), will result in termination of employment.
Refer to Comprehensive Drug and Alcohol Policies and Procedures
PROCEDURE: see appendix
100.14 Background Checks
a. As a condition of employment within certain divisions, applicants will be required to submit to a background check and pass; refusal to submit to a background check will disqualify an applicant from employment consideration. As deemed necessary, other divisions will require a background check.
b. Failure to immediately report violations, (specific to job requirements), will result in termination of employment.
100.15 Anti-harassment and offensive behavior:
a. It is the policy of the Leech Lake Band of Ojibwe that all employees should be able to work in an environment free from discrimination and harassment.
b. This policy refers to, but not limited to, harassment and offensive behavior in the following areas:
1. Age
2. Gender
3. Color
4. National Origin
5. Religion
6. Sexual Orientation
7. Marital Status
8. Handicap
9. Veteran Status
10. Physical Attributes
11. Psychological
c. Harassment includes display or circulation of written materials or pictures degrading to gender or to racial, ethnic, or religious groups; and verbal abuse or insults directed or made in the presence of members of a racial, ethnic, or minority groups.
d. Harassment also refers to behavior that is personally offensive, impairs morale, and interferes with the effectiveness of employees. Any harassment of employees by other employees will not be permitted, regardless of their working relationship.
e. Sexual harassment includes unwelcome sexual advances, requests for sexual favors, and other offensive verbal/non-verbal or physical conduct that is sexual in nature. Sexual harassment undermines the employment relationship by creating an intimidating, hostile, or offensive work environment and will not be tolerated.
f. Psychological harassment includes a pattern of behavior intended to demean, intimidate, coerce, etc. an employee to inhibit their job performance/effectiveness.
g. LLBO employees are expected to immediately report, in writing, any suspected harassment or offensive behavior to their direct supervisor. It is the supervisor’s responsibility to forward the documentation to the HR Employee Relations manager.
h. Anyone engaging in sexual or other unlawful harassment or offensive behavior will be subject to disciplinary action, up to, and including termination of employment.
PROCEDURE: see appendix
100.16 Cash Handling:
a. Where cash handling is involved each division shall have a system of internal controls and written policies and procedures approved by the LLBO Office of Internal Audit.
b. Cash disbursements not accounted for will be considered theft and the LLBO will direct legal counsel to pursue criminal charges against the employee involved with the unaccounted funds. The LLBO Tribal Court will be utilized to recover the misappropriated funds.
100.17 Firearms and Weapons:
a. All employees, except law and conservation enforcement, are forbidden from introducing, possessing, using, buying, or selling weapons, firearms, ammunition, explosives, and other items prohibited by federal, state, and reservation regulations. This prohibition includes all Tribal/Band controlled sites and all Tribal/Band directed activities. Exceptions to this will be employees authorized by the LLRTC when fulfilling the requirements of a permit by LLRTC, and the Counties and State of Minnesota. (Sovereignty)
b. Employees who become aware of a violation of this policy are required to immediately notify the Reservation Police Department or his/her immediate supervisor.
c. Violation of this policy is considered a serious offense that endangers the safety of the Tribal operations and its employees and band members. Therefore, this offense will result in immediate termination.
100.18 Unauthorized use of LLBO Computers and Software
a. Divisions will be responsible for the establishment of usage policies as it relates to each employee’s job duties. Reasonable suspicion will warrant an audit or review of the computer assigned to that employee.
b. Unauthorized use will result in disciplinary action. Pornographic material, political activities, chat rooms, personal activities not job related.
100.19 Use of Internet:
Access to the Internet through the LLBO is a privilege and carries responsibilities reflecting responsible and ethical use.
Personal Use:
Limited personal use of the Internet is allowed. However, the employee-user is reminded that use of any and all LLBO property is primarily for the purpose of LLBO business. Any personal use of the Internet is expected to be on the user’s own time and is not to interfere with the user-employee’s job responsibilities.
In addition, any postings to public forums such as newsgroups, or any transmittal of electronic mail through the Internet for personal use is prohibited (other than generally accepted practices of the LLBO).
Ethical use of Internet;
At any time and without prior notice, the LLBO Management reserves the right to examine e-mail, personal file directories, and other information stored on LLBO computers. This examination helps to ensure compliance with internal policies, supports the performance of internal investigations, and assists the management of information systems. As such, the management information systems director or his/her designee may monitor access to the Internet. Use of the Internet constitutes acceptance of such monitoring.
This policy should be read and interpreted in conjunction with all other LLBO policies including, but not limited to, policies prohibiting harassment, discrimination, offensive conduct or inappropriate behavior. User-employees are prohibited from accessing the Internet for any unethical purposes, including pornography, violence, gambling, racism, harassment, or any illegal activity. User-employees are prohibited from using profanity or vulgarity when posting electronic mail through the Internet.
The LLBO code of ethics strictly prohibits unauthorized release of information through the Internet or through any other means and that LLBO confidential information should not be transmitted over the Internet.
In general, user-employees should exercise the same restraint and caution in drafting and transmitting messages over the Internet as they would when writing a memorandum and should assume that their message will be saved and reviewed by someone other than the intended recipient.
100.20 LLBO Employee Health and Safety:
Divisions, businesses and other components of the LLBO will establish health and safety policies and procedures where applicable. The policies and procedures will contain stipulations, guarantees and certifications in order to protect the health and safety of employees.
Divisions that deal directly with hazardous material/waste shall put into place safety measures, to include training, for handling and storing hazardous material/waste on-site. Training leading to certification will be mandatory.
200. Human Resources
200.1 LLBO Hiring Practices:
The Leech Lake Band of Ojibwe hiring practices will be in accordance with Leech Lake Band preference and shall be defined in the following order:
a. Qualified Leech Lake Band Members
b. Qualified other Minnesota Chippewa Tribe Enrollees
c. Qualified other federally recognized tribal enrollees
d. Qualified Canadian Reserves tribal enrollees
e. Qualified other applicants
200.1 Job Vacancy posting:
When a vacancy occurs, the division management/supervisory staff will immediately contact Human Resources to begin the posting process. The division may hire, on an emergency basis, a qualified replacement until a candidate has filled the position.
200.2 Rating System:
a. Each Division of the LLBO will be responsible for complying with a uniform rating system implemented by the HR Division and is defined in the following order:
5=Excellent Skills |
2=Below Standard Skills |
4= Above Average Skills |
1= Unsatisfactory familiarity of field |
3= Acceptable |
0= No opportunity to rate/no response |
b. Only the whole numbers listed above will be used to rate a candidate as they are defined by a standard, no half number scores (example 4.5) will be allowed.
c. Divisions must take into consideration factors relevant to the position. Examples include, education, experience, knowledge, skills and abilities to perform the job duties of the position successfully and interview skills. Also taken into consideration may be character assessments by the interview committee. Interview notes and extensive documentation of interview responses will need to be part of the hire packet/process that will be returned to Human Resources for review to ensure that division adhered to compliance in the hire process.
200.3 Promote from Within:
It is the policy of the LLBO to hire from within, whenever possible; this is directly applicable to promoting from within the division. If an internal candidate of that division is qualified for a vacancy within the division, then the candidate would be promoted upward to that position with the concurrence of HR. Employees in their introductory period do not qualify for a promotion.
200.4 Application Process:
Applications for employment will be received by the Human Resources Division and the following processes will apply:
a. Hand delivered applications and all required/related documents must be received in the Human Resources Division and officially stamped in by and HR staff member no later than 4:30 pm on the closing date of announcement.
b. Applications can be faxed. Human Resources will not consider late applications/faxes/e-mails that come in after the closing date and time and is not responsible for failed communications.
c. Candidates who have met the qualifications of the position will be notified by the respective division of the interview date and time. The interview schedule will be kept in the sub-file by the respective division and will become part of the official hire packet.
d. Division Directors will be the lead interviewer and team coordinator for direct subordinate positions. Division Directors will excuse themselves if there is a conflict of interest. The Division Director will designate a qualified subordinate. (see nepotism section 100.4)
e. The selection process must be completed in two (2) weeks. Applicants not selected will be notified by the Human Resources division once the selection process has been completed.
f. Rate of pay will be determined by the prevailing wage scale and budgetary constraints. Beginning rate of pay is not absolute; consideration will be given to experience and education, etc. for recruitment and retention purposes.
g. When a candidate is recommended for hire, the respective hiring authority must submit to the Human Resources division the following information:
1. Interview panel information (names, titles, divisions etc.)
2. Scoring method cited and identified (see reference)
3. All candidates listed on interview schedule and rating results of each candidate.
4. Full legal name of candidate recommended for hire and Tribal enrollment affiliation (if applicable)
5. Complete PAF with all the appropriate information filled out.
6. Return sub-file with copies of all applications/resumes that were originally signed out.
7. Copies of letters to all candidates invited to interview.
8. Interview schedule will all candidates listed under consideration for interview, notes should accompany interview schedule.
9. Each interview panel member’s questionnaire sheet on each candidate interviewed, along with written detailed documentation of candidate’s responses and score of each candidate.
No job offers will be extended to the candidate selected until all information has been reviewed by the Human Resources Division to ensure compliance with hiring and compensation guidelines have been met and final approval from the Executive Director and majority of the Tribal Council has been given.
It will be the responsibility of the Human Resources Administrative Manager to notify the selected candidate they have been approved for hire. Human Resources will offer the candidate the position, if the candidate accepts the position, the next step will be referral to the EAP representative to start paperwork process for a mandatory pre-employment drug test which the candidate must successfully pass before they can start work. Notification of the selected candidate will include effective start date, immediate supervisor and rate of pay, as discussed with the hiring authority, per pay period and annum if salaried. If the rate of pay is hourly, the notification will indicate as such.
A selected candidate will not be allowed to report to work until all steps of the selection, hiring and organizational employee orientation have been completed. Failure to adhere to this process by supervisory staff will result in disciplinary action up to and including termination.
200.5 Posting Provision:
Employees with a written warning and/or suspension for any policy violation will not be allowed to apply for other positions in the organization for a period of ninety days from the date the written warning and/or suspension was received.
200.6 Selection Provision:
In the event the selected candidate resigns, is terminated or for whatever reason cannot continue in the position he/she has interviewed for and the position announcement is still within the ninety (90) day probationary period, the division may choose the next candidate from the interviewee list with the second highest score. This will ensure that the position will be filled rather than delayed.
If the position has gone beyond the ninety (90) day probationary period, the division must submit a new employment requisition along with a job description to Human Resources to re-advertise the position. NOTE: This selection provision is only referring to positions that have gone through the normal channels of advertising, interviewing, scoring and hiring processes.
200.7 Internal Hiring Procedures and Promotion:
It is the policy of the LLBO to hire from within, whenever possible. Employees will be considered for transfer or promotion on the basis of qualifications, work quality, demonstrated skills, individual accomplishments, education and years of experience.
Internal positions will be posted within the division for five (5) working days posted on an Internal Employment Requisition with an attached Job Description. Employees that would like to be considered for internal positions may apply directly with the division director by submitting a letter of application, resume and attach any other credentials required for the position. If a hire from within occurs, division director will attach to the PAF, the letter of application, resume, credentials and job description (signed and dated by all parties) the employee will be transferring into. The division director will interview all interested internal qualified candidates and make a selection to hire and promote or continue applicant search.
If no one from the division applies or a qualified candidate from the division is not found, the division director will notify the Employment Specialist, Human Resources Division, to send the internal posting out to all other divisions (Reservation Components) posted on an Internal Division Employment Requisition with attached job description for an additional two (2) week internal posting before it is open to the general public.
If an internal candidate of another division is qualified for a vacancy, the candidate will be promoted upward to that position with the concurrence of the incoming division director and the Human Resources Director.
200.8 Job Descriptions:
a. Division Directors and/or Management Staff are responsible for the development and content of all job descriptions for their individual divisions. This includes current as well as proposed positions.
b. The Human Resources Division is responsible for the structure and content compliance of all job descriptions.
c. The creation and necessity of new positions must be justified and supported by appropriate budget documentation and an Employment Requisition Form must be completed, approved and signed by the division director, then all documentation and forms must be forwarded to the Human Resources Division for processing and approval.
Job descriptions will be changed, revised, or added to in order to meet the needs of the LLBO and its components. All requests will be forwarded to the Human Resources Division by the Division Director. Final approval will come from the Human Resources Director or his/her designee.
300. Employee Relations
300.1 Personnel File Administration:
a. It is the responsibility of Human Resources to establish and maintain the official personnel file for employees of the LLBO.
Each Division will also establish and maintain an individual file for each employee, which will include; copies of time sheets, schedules, investigation reports, personnel action forms, personnel change forms, evaluations and copies of other documents whereby the original was submitted to Human Resources. (see procedure section 300.1a)
All original documentation will be forwarded to Human Resources within 3 business days.
b. All personnel records are confidential and the release of information to external agencies/representatives may occur only under limited circumstances and only under the authorization of the Human Resources director, (or his/her duly appointed representative) or the Leadership team.
300.2 Personnel File Review:
a. Employees or former employees may request to review his/her personnel file by completing and submitting a Personnel File Inspection Request Form. Upon submission of the request, every effort will be made to honor requests at time of submission. In the event that requests cannot be processed immediately, an appointment will be set up to review the file within three business days of the submissio