Purpose

This program establishes the formal written compliance training plan for Applied Behavioral Analysis Services (ABAS). It defines what compliance training every ABAS employee must complete, when they must complete it, how training is delivered, and how completion is tracked and reported to the Compliance Committee.

Scope

This program applies to all ABAS employees, including behavior technicians, BCBAs and clinical employees, billing and administrative employees, and leadership. Role-specific requirements in Section 3 apply to billing employees, clinical employees, and leadership in addition to the requirements that apply to all employees.

Training requirements specific to the Compliance Officer and Compliance Committee members are set by their charters: the Compliance Officer's initial training and continuing education requirements are defined in POL-001 (Compliance Officer Charter), and Committee member training is defined in POL-002 (Compliance Committee Charter). This program does not change those requirements.

Program Structure and Training Requirements

Onboarding Training (All Employees)

Every new ABAS employee must complete compliance onboarding training within 30 days of hire, and completes the client rights module before any contact with a client, caregiver, or client record. Onboarding consists of two components:

1. Compliance onboarding PDF. The new employee reads and e-signs the onboarding compliance document. The signed acknowledgment is stored in the employee's HR file.
2. Onboarding training modules. The new employee completes each onboarding module on the Company training platform and passes its knowledge check. Completion is tracked and reported.

The onboarding modules and what each covers, at minimum:

1. Compliance onboarding. The ABAS compliance program: the Compliance Officer's role and authority (POL-001) and the Compliance Committee's oversight role (POL-002). How to report a compliance concern: all reporting channels, including the anonymous web form, and the non-retaliation protections in POL-003 (Compliance Reporting, Investigation, and Resolution). Fraud, waste, and abuse prevention: accurate billing and documentation, prohibited conduct, and overpayment obligations (POL-004). An orientation to the healthcare compliance policy suite (POL-005 through POL-013), with emphasis on the policies relevant to the employee's role.
2. Client rights and responsibilities, before first client contact. The rights ABAS prints for every family in the Caregiver Handbook and in Your Rights and How to Raise Concerns (CFM-012): services without discrimination, safety and respect, a say in the learner's care, information, privacy and records, billing, and continuity. The grievance process and its response times: written confirmation within two working days, a written response within ten working days, review of a rights concern within one working day. The non-retaliation standard for families and for workforce members (POL-003), and how a workforce member routes a family's concern. A supervisor releases a new employee to client contact only after this module's completion is recorded.
3. Privacy and security. The employee's HIPAA duties for their role; recognizing a suspected breach and the same-day reporting duty (POL-014); password and credential practices; the rules for personal computers and devices (STD-002); recognizing phishing, impersonation, and synthetic content (POL-016). This module is the HIPAA training and the systems and security training POL-018 requires at hire.
4. Online conduct and artificial intelligence. Recognizing client-identifying information in context and the small-community identification problem; the separation of personal and Company voice online (POL-015); recognizing AI features embedded in devices and software, including capture features; current examples of synthetic-content scams and the verify-through-a-known-channel behavior; the documentation authorship rule for generated content (POL-016, POL-013). The approved AI systems list is maintained on the Company training platform.
5. CORI awareness. The fair-hiring rules in POL-017 Section 5.3 and the confidentiality of criminal offender record information (Section 5.5). Every authorized user also completes the DCJIS training for CORI requestors before requesting or viewing CORI, and any refresher DCJIS requires; Human Resources records each completion in the Credential Tracking Log (REG-001) under Required Trainings.

Annual Refresher Training (All Employees)

All ABAS employees must complete compliance refresher training at least annually. The refresher covers:

1. Changes to the ABAS policy suite (POL-001 through POL-018) since the prior training cycle.
2. Reporting channels and non-retaliation protections (POL-003).
3. Fraud, waste, and abuse prevention (POL-004).
4. Compliance issues or risk areas identified during the year, presented in sanitized form where they derive from actual reports.
5. Client rights and the grievance process (Caregiver Handbook, CFM-012).
6. Privacy and security: breach recognition and same-day reporting (POL-014), devices (STD-002), passwords and credentials, phishing and synthetic content (POL-016).
7. Online conduct and artificial intelligence (POL-015, POL-016), with the year's examples.
8. CORI awareness (POL-017).

The refresher is delivered as the annual refresher module plus the client rights, privacy and security, online conduct and artificial intelligence, and CORI awareness modules, each with its knowledge check.

Role-Specific Training

In addition to onboarding and annual refresher training, the following audiences must complete role-specific training during onboarding and annually thereafter:

1. Billing employees (Billing & Recovery Specialist and any employees who prepare or submit claims): documentation standards, medical necessity, accurate coding and billing practices (POL-004, POL-013), False Claims Acts (POL-006), and exclusion checks (POL-011).
2. BCBAs and clinical employees: medical necessity and treatment plan support for billed services, clinical documentation standards (POL-004), state licensing requirements (POL-010), and improper inducements involving members or families (POL-008).
3. Leadership (Executive Director and Director of Operations): anti-kickback statutes (POL-005), self-referral laws (POL-007), conflicts of interest (POL-009), antitrust and fair business dealings (POL-012), and leadership obligations for consistent enforcement and non-retaliation (POL-003).

Knowledge Checks

Every training module ends with a knowledge check. A module is complete when the employee has reviewed its content and passed the check at the passing standard the Compliance Officer sets. Answer keys are held by the Training Coordinator and are not distributed to employees.

Training on New or Revised Policies

When ABAS adopts a new compliance policy or makes a major revision to an existing one, the change is communicated to all affected employees. Acknowledgment is collected through an e-signature campaign or an SMS/email notification with sent verification, as described in Section 4, and does not wait for the next annual refresher.

Delivery Methods and Completion Tracking

Delivery Channels

ABAS delivers compliance training and awareness content through five channels. No learning management system is required; these channels use tools ABAS already operates.

Deployment Model

1. New employees: onboarding PDF plus onboarding training module, completed within 30 days of hire.
2. Existing employees: e-signature campaign for initial rollout of new or revised policies; SMS/email notifications with sent verification for annual reminders and updates.
3. Continuous: on-site signage runs at all times at in-person facilities.

Completion Tracking and Reporting

The Training Coordinator maintains a training completion record for every employee, covering onboarding, annual refresher, role-specific training, and policy rollout acknowledgments. The record identifies the employee, the training or acknowledgment, the completion date, the version of the material, and the evidence type (e-signature, or module completion record with the knowledge check result). Annual refresher and role-specific training completion is recorded through module completion with the knowledge check result, or through an e-signed acknowledgment where a module has no check; SMS/email delivery logs evidence only that a reminder was sent, not that training was completed.

The Training Coordinator reports completion status to the Compliance Officer, who includes training completion rates and open gaps in the quarterly written reports to the Compliance Committee. The Committee reviews training completion rates and effectiveness as part of its oversight duties under POL-002, Section 5.4. Employees who have not completed required training by the due date are escalated to their supervisor, and persistent non-completion is handled under ABAS's progressive discipline process.

Responsibilities

ABAS assigns training coordination responsibility to Human Resources, which serves as the training coordinator under this program.

Records

ABAS retains the following training records for a minimum of six years, consistent with the retention period for compliance program records:

1. E-signed onboarding acknowledgments, stored in each employee's HR file.
2. Onboarding training module completion records.
3. E-signature campaign records for policy rollouts.
4. SMS/email delivery logs for training notices and reminders.
5. The training completion record maintained by the training coordinator.
6. The version of each training material in use during each training cycle, so that auditors can see what content employees were trained on.
7. Knowledge check results, and the version of each answer key in use.

Training records are available to the Compliance Officer and Compliance Committee on request and are produced during audits, payer reviews, and regulatory inquiries.