Can an ALC employee “moonlight” to provide services under direct arrangement with a client, including health services?
A. Yes. Subject to an ALC’s own policy, the law doesn’t prohibit an employee from “moonlighting” to provide services under direct arrangement with a client. However, per the definition of health services in KRS 216B.015, any person providing clinically-related services to two or more people is required to be licensed as a private duty nurse, home health agency or another applicable health care provider. BP. KALFA does not recommend this practice, due to the potential for noncompliance with KRS 194A.700-729 and applicable state/federal labor laws, as well as the need to avoid the appearance of impropriety.
