Introduction

Welcome to Applied Behavioral Analysis Services. You are joining a team committed to delivering applied behavior analysis with integrity, clinical excellence, and respect for every client and family. ABAS's compliance program safeguards that commitment and keeps our work lawful, ethical, and worthy of the trust clients, families, and funders place in us.

This document summarizes the program and your responsibilities under it. The full policies are in the company policy repository (currently the Trainual app) and from the Compliance Officer, beginning with POL-001, POL-002, and POL-003.

Compliance is a shared responsibility and a condition of working at ABAS. Three commitments matter most: understand how the program works and who leads it, know how to raise a concern, and raise one whenever you have it.

Our Compliance Program

ABAS's compliance program is anchored by two roles.

The Compliance Officer, a senior manager appointed by the Executive Director, runs the program day to day: maintaining policies, overseeing training, keeping confidential reporting channels open, leading investigations, and tracking corrective actions to completion (POL-001). The Compliance Officer is your first point of contact for any compliance question or concern.

The Compliance Committee, a leadership group from across ABAS chaired by the Compliance Officer, provides independent oversight. It meets at least quarterly to review compliance priorities, training completion, investigation summaries, and the annual work plan (POL-002).

How to Report a Concern

Report any compliance concern you observe or suspect through one of three channels:

1. Compliance Officer. In person, by phone, or by email.
2. Anonymous form. Submit at https://anonymous.abaswma.com/; anonymous reports are investigated to the same standard as named ones.
3. Executive Director, if the concern involves the Compliance Officer.

Every report is logged as a compliance ticket under POL-003, reviewed within one to two business days, and shared only on a need-to-know basis; your identity is protected to the extent the law allows. Report in good faith, and the investigation establishes the facts.

Your Obligation to Report

Reporting suspected noncompliance is a requirement of your employment. Every ABAS employee who becomes aware of a potential violation of law, regulation, or ABAS policy must report it promptly through one of the channels above, including concerns about billing and documentation, client care, privacy, and the conduct of coworkers or supervisors at any level.

Report what you observe or suspect, in good faith. Failing to report a known concern, or interfering with an investigation, may result in disciplinary action up to and including termination (POL-003, Section 8).

Non-Retaliation

ABAS prohibits retaliation against anyone who reports a compliance concern in good faith, regardless of whether the concern is confirmed. Retaliation is any adverse action taken against you for making a good-faith report.

If you experience retaliation, notify the Compliance Officer, or the Executive Director if the matter involves the Compliance Officer. Confirmed retaliation results in disciplinary action up to and including termination (POL-003, Section 5.1).

Compliance and Discipline

Confirmed compliance violations are handled through the ABAS disciplinary process (Employee Handbook, Section 20, Progressive Discipline). Depending on severity, corrective action may include retraining, policy or process changes, monitoring, or discipline up to and including termination.

The same standards apply to everyone. The Compliance Officer monitors disciplinary actions for fairness and consistency across roles and levels (POL-001, Section 5.3).

Training Expectations

Compliance training is a requirement of every role and begins at onboarding.

1. Onboarding. Covers the compliance program, how to report a concern, non-retaliation protections, and what happens after a report.
2. Annual refresher. Completed by all employees each year.
3. Role-specific. Additional training for certain roles, such as those who handle investigations.

Completion is tracked and reported to the Compliance Committee, and on-time completion is expected of every role (POL-003, Section 7).

Acknowledgment and Signature

By signing below, I acknowledge that:

1. I have read and understood this Compliance Onboarding Acknowledgment.
2. I know ABAS has a Compliance Officer and a Compliance Committee and what each does.
3. I know how to report a concern, including anonymously at https://anonymous.abaswma.com/, and may report to the Executive Director if it involves the Compliance Officer.
4. I must report suspected noncompliance promptly, and failing to report a known concern may result in disciplinary action.
5. ABAS prohibits retaliation against anyone who reports a concern in good faith.
6. Compliance violations are handled under the ABAS disciplinary process.
7. I will complete compliance training at onboarding and annually.
8. I can review any ABAS compliance policy in the company policy repository (currently the Trainual app) or request it from the Compliance Officer.

This acknowledgment is completed electronically and stored in your HR file.