Restraint, Seclusion, and Restrictive Procedures

POLICY: The Company is committed to supporting clients through positive, function-based, and least restrictive procedures. The Company does not use restraint or seclusion as a treatment, behavior change, or programmatic technique, and such procedures are never included as planned interventions in a behavior plan. Restraint and seclusion are never used for discipline, punishment, coercion, retaliation, or staff convenience, and never as a substitute for adequate staffing, supervision, training, or individualized programming. This position is consistent with the services excluded under the Exclusion chapter and with the Company's obligation to use the least restrictive effective procedure and to protect each client's dignity, rights, and physical and psychological safety.

SCOPE: This policy applies to all clinical and contracted staff providing or supervising ABA services, including BCBAs, BCaBAs (when applicable), and RBTs, in every authorized service setting (home, clinic, school, and community).

Definitions

• Physical restraint:any manual method that restricts a client's freedom of movement or normal access to their own body. Physical guidance, prompting, or brief blocking used as part of routine instruction is not restraint.
• Mechanical restraint:any device or equipment used to restrict a client's freedom of movement. This does not include devices prescribed by a licensed medical or therapy professional and used for postural support, positioning, or protection.
• Chemical restraint:any medication used to control behavior or restrict movement that is not a standard treatment or dosage for the client's condition. The Company does not administer medication, and staff never use medication to manage behavior.
• Seclusion: the involuntary confinement of a client alone in a room or area from which they are physically prevented from leaving.
• Restrictive procedure:any practice that limits a client's movement, access, rights, or freedom beyond what is typical for the setting.
• Emergency safety intervention: a brief, last resort physical intervention used only to prevent imminent serious physical harm when less restrictive measures have failed or are clearly inadequate, applied by trained staff and ended as soon as the imminent danger has resolved.

Prohibited Practices

The following are prohibited at all times:

• Prone (face down) or supine (face up) restraint, and any restraint that restricts a client's ability to breathe or communicate.
• Mechanical restraint and chemical restraint by Company staff.
• Seclusion in any form.
• Restraint, seclusion, or any restrictive procedure used as discipline, punishment, coercion, retaliation, or for staff convenience.
• Restraint or seclusion written into or implemented as a planned part of an assessment, behavior plan, or treatment protocol.
• Any physical intervention by a staff member who has not completed the required behavioral safety training described below.

Prevention and Least Restrictive Alternatives

Behavioral safety is achieved primarily through prevention. Before any situation escalates, staff rely on antecedent and environmental strategies, function-based interventions derived from assessment, reinforcement of replacement behaviors, individualized de-escalation supports, and collaboration with caregivers. Each client with known safety risks has an individualized safety and crisis plan developed and monitored by the supervising behavior analyst, as described in the Safety Client Protocol (Crisis Management) chapter. Staff are expected to use the least restrictive effective response in every circumstance.

Emergency Safety Intervention

An emergency safety intervention may be used only when all of the following conditions are met:

1. There is an imminent risk of serious physical harm to the client or to others.
2. Less restrictive measures, including de-escalation, have been attempted and failed, or are clearly inadequate to the immediate danger.
3. The intervention is carried out only by staff trained and currently certified in an approved crisis prevention and behavioral safety curriculum.
4. The intervention uses the minimum contact, force, and duration necessary, the client is continuously monitored for distress and physical wellbeing, and the intervention ends the moment the imminent danger has resolved.

An emergency safety intervention is a protective response to an unforeseen crisis. It is never a planned or recurring strategy. A pattern of emergency interventions for the same client indicates that the behavior plan must be reassessed and revised by the supervising behavior analyst.

Staff Training and Competency

Staff who may be present during a behavioral crisis must complete an approved crisis prevention and behavioral safety training (for example, Safety-Care, CPI, or PCM) before performing any hands-on intervention, and must maintain current certification through periodic renewal. Completion is verified and tracked as part of the Required Documents Checklist. Training emphasizes prevention and de-escalation first, with physical intervention taught only as a last resort.

Caregiver Notification and Consent

The Company's prevention-based approach to behavioral safety is explained to caregivers or legal representatives during intake and consent. When an emergency safety intervention occurs, the caregiver or legal representative is notified as soon as possible on the same day, and the supervising behavior analyst is informed without delay.

Documentation and Reporting

Every emergency safety intervention is documented on an Incident Report within the required timeframe. Documentation includes the antecedents and events leading to the crisis, the less restrictive measures attempted, a description of the intervention used, its duration, the staff involved, any injuries to any person, the notifications made, and the plan for follow-up. The supervising behavior analyst reviews each report. Any event that may constitute abuse, neglect, or injury is also handled under the Abuse Reporting requirements.

Post-Incident Review

Following any emergency safety intervention, the supervising behavior analyst reviews the event, leads a debrief with the staff involved, and determines whether the client's assessment, behavior plan, safety plan, or environment must be modified to prevent recurrence. Support is offered to the client, staff, and any witnesses as appropriate. The client retains all rights throughout, and no client or caregiver is subject to retaliation for any concern raised about a physical intervention.

Policy Review

This policy shall be reviewed annually or when required by regulatory, payer, or clinical changes.