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Part II · Appendix 10A

Employee Acknowledgement

Policy acknowledgements and attestations signed by employees at hire.

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Employee Acknowledgment With Policies and Procedures

1. Cellphone Use During Therapy Sessions

During therapy sessions and when providing direct services to recipients, therapists and analysts are strictly prohibited from using their personal cellphones or electronic devices for any purpose not directly associated with the CPT code or service being delivered. This includes personal matters, unrelated phone calls, messaging, or any activities that may distract from the therapy session.

2. Dress Code During Therapy Sessions

The Company maintains a professional dress code policy to ensure that analysts and therapists present themselves appropriately while providing services. Approved attire includes any color scrubs and tennis shoes. Therapists are encouraged to wear non-identifiable clothing to promote generalization. Clothing should be comfortable yet professional, avoiding visible lines or provocative elements. Prohibited attire includes shorts, leggings, jeans, sandals, and any shirts outside of approved attire. Analysts and therapists must maintain a professional appearance by keeping fingernails short, ensuring long hair is always pulled back to prevent client injury, and minimizing jewelry. Hanging necklaces, earrings, and bracelets are not permitted for safety reasons. No facial piercings, bone earrings, or earlobe gauges are allowed. All ankle tattoos must be covered with socks or stockings, and arm tattoos must be concealed with long-sleeve black shirts worn under the logo shirt.

3. Session Documentation Requirements and Compliance

All employees must submit daily progress notes, which must be completed, signed, and reviewed to ensure compliance with documentation standards. RBTs should contact their supervisors for guidance and support regarding documentation, while analysts are responsible for reviewing their supervisees’ progress notes on a weekly basis. Only finalized, reviewed, signed, and complete documentation will be billed and processed for payment. All progress notes must be finalized and signed within 48 hours of service delivery to remain compliant with agency and payer guidelines.

Session documentation must comply with the CPT code being billed and must accurately reflect:

  • The behaviors observed during the session.
  • The replacement behaviors taught and interventions implemented.
  • A detailed account of what actually happened during the session, including any deviations from the treatment plan.

Data must be collected during the session and documented accordingly, ensuring alignment with treatment goals and payer requirements. Failure to adhere to these documentation standards may result in delays in payment processing, non-billable sessions, or corrective action as determined by the Company.

4. Gifts and Gratuities Policy

The Company follows U.S. federal law and applicable payer requirements, including Medicaid and Medicare program rules. Engaging in any form of malpractice is strictly incompatible with the Company’s policies and statutes. The primary objective of the agency is to ensure the well-being and progress of the client while maintaining ethical and professional integrity. As an employee of the Company, the employee acknowledges that they will not give or receive any money, reward, or other benefit exceeding ten dollars ($10) to or from the client, their parents, or any other person associated with the client. Violating this policy may result in disciplinary action, up to and including termination of employment.

5. Medication Administration Policy

Many clients served may be under the medical care of a physician and may be prescribed medications to be taken throughout the day. As an employee of the Company, the employee acknowledges that they are not authorized to assist with the delivery, administration, or management of any medication. This includes, but is not limited to, reminding clients to take medication, physically handing medication to clients, or administering any form of medication. All medication-related matters must be handled directly by the client, their caregiver, or an authorized medical professional. Failure to adhere to this policy may result in disciplinary action, up to and including termination of employment.

6. Non-Transportation Policy

The Company prohibits employees from transporting recipients or their relatives in their personal vehicles. Transporting recipients of services or their relatives is not an authorized work activity, and therefore it is not reimbursable and not allowed by the Company. The Company will not be held liable for any misrepresentation or incidents that may occur as a result of personal vehicle transportation. Employees are expressly prohibited from transporting recipients in their personal vehicles.

7. Confidentiality

The Company strictly maintains the confidentiality of records, ensuring that only authorized agency personnel can access client information, whether in electronic or physical form. As the responsible party with access to such information, the employee acknowledges the duty to safeguard it. The employee is not authorized to disclose any information without prior written consent and explicit direction from the organization. The employee has been formally instructed to uphold the confidentiality and privacy of medical records, refraining from discussing patient information with anyone, both within and outside the company, except as necessary for daily business operations.

Medical records should not be removed from the company unless a “Release of Information” form is completed and signed by the patient, and any unauthorized discussion of such release is grounds for dismissal. The employee has received formal instruction on the company’s policies and procedures, ensuring full compliance with all HIPAA regulations.

8. Crisis Management

The nature of the services provided may involve the presence of challenging behaviors that can be difficult to manage. The Behavior Support Plan (BSP) outlines crisis procedures that specify the actions to take when behaviors escalate. As the provider, if the employee is unable to safely manage the behavior, the employee will immediately contact 911 and notify relevant parties. It is the employee’s responsibility to regularly review the updated crisis plan within the recipient’s treatment plan and seek clarification by asking questions when needed.

9. Overlapping of Behavior Analysis Services

Behavior analysis therapy services cannot be provided simultaneously with other services, such as Personal Care Services, Speech Therapy, Occupational Therapy, or any other services or occupations where the provider does not have direct engagement with the recipient. Exceptions may be granted by the Clinical Director in cases where medical necessity for this service is demonstrated.

10. Service Hour Limitations and Scheduling Requirements

As an employee, the employee will be assigned a schedule by the Company and is expected to adhere to it. The employee can work and bill for a maximum of six consecutive days, with one required rest day per week. The employee is limited to providing and billing a maximum of six hours daily per recipient, and assessment units are included within these service hour limitations. Services not provided within a given week cannot be made up later.

A single recipient may receive a maximum of eight hours of services per day from all providers combined, including RBTs and analysts. As a provider, the employee may not exceed ten hours of service provision across all clients in a single day, including clients from other organizations. The standard approved therapy hours for regular scheduling are from 8:00 AM to 8:00 PM, and any therapy sessions scheduled outside this window require pre-approval from the Clinical Director. Approval for hours outside the standard schedule will be determined on a case-by-case basis based on medical necessity.

No provider or combination of providers may exceed 40 hours of services per week per client, including assessment units. The employee is responsible for ensuring that scheduling remains compliant with this limitation.

The employee is expected to be available to provide services during the following holidays, unless otherwise approved by the agency:

  • Martin Luther King Jr. Day
  • Presidents’ Day
  • Good Friday
  • Columbus Day
  • Veterans Day

The employee will not be required to provide services on the following major holidays unless otherwise agreed upon:

  • New Year’s Day
  • Memorial Day
  • Independence Day (July 4th)
  • Labor Day
  • Thanksgiving Day
  • Christmas Day

11. Drug-Free Workplace

The Company is dedicated to maintaining a safe work environment and prioritizing the well-being and health of its employees, contractors, and associates. This commitment is compromised when any individual associated with the Company engages in drug or alcohol use on the job, arrives at work with these substances in their system, or possesses, distributes, or sells drugs in the workplace. Given the nature of the discipline, strict enforcement of this policy is ongoing. The employee acknowledges that random and specific drug testing may be requested at any time.

12. Sexual Harassment Policy

The Company is committed to providing a safe environment for all its employees, contractors, and associates free from discrimination on any ground and from harassment at work including sexual harassment. The Company will operate a zero-tolerance policy for any form of sexual harassment in the workplace, treat all incidents seriously and promptly investigate all allegations of sexual harassment. Any person found to have sexually harassed another will face disciplinary action, up to and including dismissal from employment. The employee has received a full copy of this policy for reference.

13. Non-Exclusion from Medicaid and Medicare

The employee hereby attests that they have not been excluded from participating in the Medicare and Medicaid programs, including the State of Florida as well as any other state(s). The employee also commits to immediately notify the agency if they ever become excluded from participating in the Medicare and Medicaid programs in the future. The employee understands that the Company will verify the information provided with the Office of Inspector General (OIG).

14. Hepatitis B

The federal OSHA requirement, 29 CFR § 1910.1030, mandates that organizations / employers provide the hepatitis B vaccine series to all employees with occupational exposure. The Company ensures that employees in direct contact with recipients have access to the vaccine. The employee attests to being informed that, due to their occupational exposure to blood or other infectious materials, they may be at risk of acquiring Hepatitis B (HBV) infection. The employee has been given the opportunity to receive the Hepatitis B vaccine at no charge. Additionally, the employee retains the option to request vaccination with the Hepatitis B vaccine at no charge at any time.

15. Supervision Documentation and Expectations

Ongoing supervision is a requirement to maintain credentialing with the BACB. RBTs are expected to make themselves available for supervision sessions in coordination with their analyst. Analysts employed by the Company are required to offer and provide supervision to assigned RBTs in accordance with BACB requirements and payer guidelines. RBTs who are out of compliance with supervision expectations will not be allowed to provide behavioral services.

16. Job Description

As an employee, the employee attests that they have received and thoroughly reviewed their job description for their position as an RBT, BCBA, or Administrative staff. The employee understands the detailed assignments and responsibilities outlined in this description and agrees to adhere to the duties and expectations set forth. The employee acknowledges that they have been given the opportunity to ask questions and seek clarification on any aspects of their role. Initials confirm commitment to fulfilling these responsibilities to the best of the employee’s ability.

17. Reporting Abuse, Neglect, and Exploitation of Children and Vulnerable Adults

The employee attests that they have received detailed information and specific instructions on reporting abuse, neglect, and exploitation of children and vulnerable adults. In accordance with Chapter 415, Florida Statutes (F.S.), which mandates the Department of Children and Families to provide protective services for abused or neglected children and vulnerable adults, the employee understands that reports of such abuse must be made to the Florida Abuse Hotline. The Company representative has explained, in the employee’s language of choice, how to recognize physical, behavioral, and environmental indicators of abuse, neglect, and exploitation. The employee has been informed on how to report suspected abuse by calling 1-800-962-2873 or 1-800-96-ABUSE, including the information needed for the report. Additionally, the employee has been informed on how to report life-threatening emergencies to 911. The representative has provided the necessary phone numbers for reporting suspected abuse and emergencies. The employee acknowledges the importance of promptly reporting any suspected abuse, neglect, or exploitation and understands the procedures to follow.

18. Non-Solicitation Agreement

During the term of employment with the Company (hereinafter “Company”) and continuing for one (1) year thereafter, Employee shall not, in any capacity: (a) attempt to persuade any patient, client, vendor, referral source, or business partner of Company to cease or reduce their business with Company; (b) employ or attempt to employ any person who is or was employed by or in a consulting relationship with Company within one (1) year prior to the termination of Employee’s services; (c) remove any property belonging to or within the possession of Company, including all internal manuals, documents, patient information, data, software, and other materials prepared for internal use or used in connection of Company; or (d) provide any healthcare or related services to any patient that Employee served on behalf of Company at any point during the term of their relationship. Employee acknowledges that this Agreement is essential to their relationship with Company and agrees that if any portion is held unreasonable, the remaining provisions will remain in full force. Employee also acknowledges that the provisions are appropriate and reasonable and that a breach would cause irreparable damage to Company, entitling Company to injunctive relief in addition to other legal remedies. Employee agrees to pay all costs and expenses incurred by Company in enforcing this Agreement, including reasonable legal fees. Furthermore, Employee consents to any action under this Agreement being determined by a judge without a jury, waiving any right to a jury trial. The time restrictions applicable to this Agreement shall be tolled during any period of breach.

19. Acknowledgement of Understanding for Electronic Signature

An “Electronic signature” means any letters, characters, or symbols, manifested by electronic or similar means, executed or adopted by a party with an intent to authenticate a writing. A writing is electronically signed if an electronic signature is logically associated with such writing. The employee acknowledges and attests that the signature handwritten below represents their official signature. The employee commits to using this signature on all documents related to the service. The employee has been informed that they should not use initials and that the digital signature will be the representation of the employee’s name. The employee acknowledges that electronic signatures have the same legal force and effect as handwritten signatures.

20. Communication and Meeting Participation Requirement

The employee is expected to actively participate in scheduled meetings. Additionally, the employee must respond to written and phone communications within 6 hours as a condition for maintaining the employment relationship. Failure to meet these communication and participation expectations may be considered non-compliance with job expectations and could result in corrective action, up to and including termination of employment.

21. CAQH Profile Maintenance

The employee is responsible for maintaining and updating their CAQH (Council for Affordable Quality Healthcare) profile as required by payers. Failure to keep CAQH information up to date may result in delayed credentialing, reimbursement issues, or suspension from billing, impacting the employee’s ability to render and bill for services.

22. Incident Reporting Requirement

As a provider, the employee is required to submit a written incident report for any significant event occurring during a session. All incident reports must be submitted in writing and must comply with the reporting requirements outlined by the agency and funding sources. Failure to adhere to these reporting requirements may result in non-compliance with agency policies and payer regulations, potentially affecting service provision and employment standing.

The employee understands that this document is subject to change and may be updated from time to time to reflect modifications in agency policies, payer requirements, or regulatory guidelines. Any updates or modifications to this document will be communicated via email, and the employee acknowledges responsibility to review and adhere to any changes. Updates may or may not require an updated attestation from the employee, depending on the nature of the modifications. Failure to comply with updated policies may impact the employment relationship with the agency.

The Employee Acknowledgement form on the right captures each of these sections again with an initials checkbox per section and a final printed name, signature, and date. It is signed at hire and re-signed when the agency communicates material updates. The signed acknowledgement is filed in the employee’s HR file.