Purpose

This Code of Conduct is the foundational ethics document of the ABAS compliance program. It states, in one place, the standards of conduct ABAS expects of everyone who works for or on behalf of the organization, and it affirms ABAS's commitment to deliver applied behavior analysis services lawfully, ethically, and in the best interest of the clients it serves. It connects those standards to the specific policies of the compliance program, and it is the document ABAS provides to demonstrate, to clients, payers, regulators, and its workforce, the principles that govern how ABAS operates.

Scope

This Code applies to every member of the ABAS workforce: the Executive Director, all employees (clinical, billing, and administrative), Board Certified Behavior Analysts, behavior technicians and Registered Behavior Technicians, supervisors, and interns. It applies to independent contractors and consultants where their contract requires adherence. The Code covers all ABAS services, all interactions with clients and their families, all dealings with payers, and all use of ABAS funds, property, systems, and information. Where a specific policy, the Employee Handbook, or a professional ethics code sets a more detailed or more stringent standard on a topic, that source controls; this Code states the standard and points to it.

Definitions

Standards of Conduct

5.1 Commitment to Legal and Ethical Compliance

ABAS conducts its operations in compliance with all applicable federal law and the law of each state in which ABAS operates (including Massachusetts), MassHealth and other payer requirements, and professional standards. Every member of the workforce is expected to know the requirements that apply to their role and to perform their duties accordingly. No business goal, productivity target, or directive justifies a violation of law, regulation, payer rule, or this Code. When a requirement is unclear, ask the Compliance Officer before acting. [OIG GCPG; USSG 8B2.1]

5.2 Quality of Care and Client Welfare

ABAS exists to benefit the clients it serves. Workforce members who deliver behavior-analytic services embody the four core principles of the profession: they benefit others and do no harm, protecting client welfare and rights above all else; they treat others with compassion, dignity, and respect, and without discrimination; they behave with integrity, remaining honest and accountable; and they ensure their own competence, practicing only within their training and defined scope. They place the interests of clients first and promote client self-determination. [BCBA Core Principles 1-4; RBT 2.01]

5.3 Accurate Documentation, Coding, and Billing

Workforce members who deliver services document each service accurately and at the time it is delivered, recording the client, the rendering provider, the service, and the start and end times, and supporting the medical necessity of the service under the client's authorized treatment plan. ABAS bills only for services actually delivered. Altering, backdating, or falsifying clinical or billing records is prohibited, as is upcoding or billing for missed or cancelled sessions as if delivered. Detailed requirements appear in POL-004 (Fraud, Waste, and Abuse Prevention) and POL-013 (Coding and Billing Practices).

5.4 Prohibition of Fraud, Waste, and Abuse

ABAS prohibits fraud, waste, and abuse in every form, whether intentional or the result of error or neglect. Every claim must be accurate, supported by contemporaneous documentation, and for a medically necessary service that was actually delivered. Anyone who becomes aware of a payment ABAS was not entitled to must report it so it can be investigated and returned. POL-004 governs FWA prevention, overpayments, and enforcement.

5.5 Anti-Kickback, Referrals, and Improper Inducements

ABAS does not offer, pay, solicit, or receive anything of value to induce or reward the referral of MassHealth or other payer business, consistent with the federal Anti-Kickback Statute. ABAS does not offer improper inducements to clients or referral sources. Direct any question about a referral relationship, vendor arrangement, or gift to the Compliance Officer before ABAS enters into it. See POL-005 (Anti-Kickback Statutes) and POL-008 (Improper Inducements).

5.6 Conflicts of Interest

Workforce members avoid actual, potential, and perceived conflicts between their personal interests and their duties to ABAS and its clients, and disclose conflicts when they arise. Those who deliver services also avoid multiple relationships that could impair professional judgment. ABAS manages disclosed conflicts rather than relying on individuals to resolve them alone. See POL-009 (Conflicts of Interest) and its disclosure form, management plan, and log (CFM-002, CFM-003, CFM-004). [RBT 1.06]

5.7 Exclusion Screening and an Eligible Workforce

ABAS does not employ or contract with any individual or entity excluded from participation in federal or state health care programs. Every workforce member must promptly disclose to ABAS any exclusion, debarment, license action, or criminal matter that could affect their eligibility to provide or support services. See POL-011 (Exclusion Checks).

5.8 Confidentiality, Privacy, and HIPAA

Workforce members protect the confidentiality and privacy of clients and use only the minimum identifying information necessary in job-related communications. Confidential information is shared only with those who need it for a legitimate purpose. Records are created, stored, accessed, transferred, and disposed of in accordance with HIPAA, applicable state law, and ABAS policy, and any suspected breach of protected health information is reported immediately to the HIPAA Privacy Officer. Client-identifying information is never shared on social media. Confidential ABAS business information is likewise protected and is not disclosed without authorization. [EH 17.6, 21; RBT 2.05, 2.07-2.10]

5.9 Professional Boundaries and Relationships

Workforce members who deliver services or supervise others maintain appropriate professional boundaries with clients, families, and supervisees. They do not engage in sexual relationships with current clients or supervisors, and refrain from such relationships with former clients or supervisors for at least two years after the professional relationship ends. They do not accept gifts from or give gifts to clients. Where a personal problem or relationship could impair performance or judgment, they disclose it to their supervisor and refrain from providing affected services. [RBT 1.06, 1.07, 1.08, 2.04]

5.10 Respectful, Safe, and Non-Discriminatory Workplace

ABAS is an equal opportunity employer and does not tolerate discrimination or harassment of any kind, in employment or in service delivery, on the basis of any characteristic protected by law. ABAS does not tolerate threats, violence, or weapons on its premises. Everyone treats clients, families, and one another with dignity and respect. Detailed requirements, the complaint procedure, and the standalone sexual-harassment policy required by applicable state law are maintained in the Employee Handbook and the ABAS anti-harassment policy. [EH 2.1, 2.2, 2.4]

5.11 Protection and Proper Use of Resources

ABAS funds, property, systems, and paid time are used only for legitimate ABAS purposes, not for personal benefit. ABAS information systems and devices are ABAS property and are used for ABAS business consistent with ABAS policy. Workforce members return all ABAS property on separation. [EH 2.5, 17.4, 17.6]

5.12 Duty to Report and to Cooperate

Every member of the workforce has an affirmative duty to report conduct they reasonably believe violates this Code, a compliance policy, or the law. Reports are made to the Compliance Officer or through the channels in POL-003, including the anonymous reporting form. Everyone cooperates fully and honestly with compliance reviews, audits, and investigations, and must not conceal, alter, or destroy relevant records. Suspected child abuse or neglect is reported to the Department of Children and Families as required by law. [EH 17.5; RBT 1.05, 2.02]

5.13 Non-Retaliation

ABAS prohibits retaliation against anyone who, in good faith, reports a concern, raises a question, or participates in an investigation, regardless of whether the concern is ultimately substantiated. Anyone who believes they have experienced retaliation should notify the Compliance Officer or, if the concern involves the Compliance Officer, the Executive Director. Confirmed retaliation is itself a violation of this Code and results in disciplinary action. The protections and reporting paths in POL-003 apply to all reports made under this Code.

5.14 Accountability and Consequences

Compliance with this Code is a condition of working for ABAS. A violation may result in corrective action up to and including termination, restitution of any improper payment, and referral to the relevant payer or program, licensing boards, law enforcement, or other authorities where required by law. ABAS applies the Code consistently across all levels of the organization, including leadership. Discipline for violations is administered through the process in the Employee Handbook. [EH 17.10, 20]

Procedures

Responsibilities

Steps

1. Every new member of the workforce receives, reads, and e-signs this Code during onboarding, using the acknowledgment in TRN-002. The signed acknowledgment is stored in the personnel file.
2. The entire workforce re-acknowledges the Code at least annually and whenever a material revision is adopted.
3. Workforce members direct questions about the Code to their supervisor or the Compliance Officer, and direct compliance concerns to the channels in POL-003.
4. The Compliance Officer reviews this Code at least annually, recommends updates to the Compliance Committee, and records changes in the revision history.
5. Confirmed violations are addressed through POL-003 and the disciplinary process in the Employee Handbook.

Training Requirements

Every member of the ABAS workforce is trained on this Code of Conduct during onboarding and at least annually thereafter as part of compliance refresher training. Training covers the standards of conduct, the duty to report, the protection against retaliation, and how to raise a concern. Completion is documented through the acknowledgment in TRN-002 and tracked by the Compliance Officer, who reports completion rates to the Compliance Committee. [OIG GCPG]

Reporting and Enforcement

Any member of the workforce who becomes aware of a suspected violation of this Code must report it to the Compliance Officer, to a supervisor, or through the ABAS anonymous reporting form (https://anonymous.abaswma.com/). Reports are logged and handled under POL-003 (Compliance Reporting, Investigation, and Resolution) and its Compliance Ticket Management SOP. ABAS does not retaliate against anyone who reports a concern in good faith or participates in an investigation. A confirmed violation may result in corrective action up to and including termination, restitution of any improper payment, and referral to the relevant payer or program, licensing authorities, or law enforcement where required by law. Adherence to this Code is acknowledged in writing at hire and annually (TRN-002).