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Letter

Member Testimony HB7217: Kiernan

Desk Audit Bill
Submitted on: February 5, 2026

Good afternoon Committee members, 

I am asking that you pass House Bill 7217 so all state employees can receive fair and equitable promotions as deserved. 

My name is Eric Kiernan and I have been employed by the State of Rhode Island since July of 2009. I was originally hired as a Fire Safety Inspector with the Office of the State Fire Marshal I transferred to the Department of Health (DOH) in December of 2019 accepting a position as a as an Environmental Health Officer, which is equivalent to a Senior level surveyor’s position, due to my extensive Life Safety experience. 

Approximately 3 years ago, the Center for Health Facilities Regulation developed new job titles and descriptions for the surveyors. Levels 2 through 4 have supervisor responsibilities assigned to them. When I completed my desk audit from my old tile to the new titles, Health Facility Compliance Specialist (HFCS) levels 1-4, I completed my desk audit as an
HFCS level III as I was currently in an acting Principal’s position. I was informed by Human Resources that I was being put into a level 2 position. It was explained to me that the only part of the level 3 job description I did not meet was having supervisor responsibilities. It was further explained to me that there is no formal description of what supervisor responsibilities consist of but that the signing of a subordinates time sheet is something these use to determine if someone meets that requirement. 

I have trained 2 other surveyors to meet National Fire Protection (NFPA) Certified Fire Inspector I as well as certification requirements for Centers for Medicare & Medicaid Services (CMS) as a life safety surveyor. I was an acting Principal level surveyor for over a year overseeing life safety requirements for CHFR as well as other departments in the DOH. I have signed off on DOH regulations regarding life safety. I have conducted (I am certified by NFPA to do so) plan review of a safe injection site in providence to confirm that it meets state standards. I still assist subordinates as to what constitutes a life safety citation for our surveys. 

I’m not just a surveyor. I’m much more than that. The problem is that I am being held back due to some individuals interpretation of what constitutes a supervisor. This is in no way fair and equitable. 

Respectfully,
Eric W. Kiernan

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