Purpose

This charter establishes the structure, membership, and responsibilities of the ABAS Compliance Committee. The Committee provides organizational oversight of the compliance program and ensures that compliance priorities receive regular attention from leadership.

Scope

This policy applies to all individuals who serve on or interact with the Compliance Committee, including Committee members, the Compliance Officer, and ABAS leadership. It governs how the Committee is formed, how it operates, and what it is accountable for.

Definitions

Policy Statement

5.1 Formation and Membership

The Compliance Committee is appointed by the Executive Director. Given ABAS's size (20 to 50 employees), the Committee should include at minimum:

1. The Compliance Officer, who serves as Committee Chair.
2. The Director of Operations (or equivalent).
3. A representative from clinical operations (BCBA or senior clinician).
4. A representative from billing and administrative functions.

The Executive Director may add members as needed to ensure relevant areas of the organization are represented. Committee members serve at the discretion of the Executive Director.

5.2 Meeting Schedule

The Compliance Committee will meet at least quarterly. Additional meetings may be called by the Chair or the Executive Director when urgent compliance matters arise. The Chair will distribute a written agenda to all members at least five business days before each meeting.

5.3 Meeting Minutes and Follow-Up Tracking

Written minutes will be prepared for every Committee meeting. Minutes must include:

1. Date, time, and attendees.
2. Topics discussed and any decisions reached.
3. Action items assigned, including the responsible person and target completion date.
4. Status updates on previously assigned action items.

The Chair is responsible for preparing or delegating minutes and for filing the finalized minutes in ABAS's compliance program files. The Chair holds the minutes only until they are filed there, so the minutes history remains accessible at a company-owned level and is not kept on any individual's device. Minutes are retained in the compliance program files for a minimum of six years. The Committee will review open action items at the start of each meeting to ensure follow-through.

5.4 Committee Responsibilities

The Compliance Committee is responsible for the following:

1. Set and review compliance priorities and the overall compliance strategy for ABAS.
2. Provide independent oversight of the compliance program, including reviewing reports from the Compliance Officer.
3. Review and recommend updates to compliance-related policies and procedures.
4. Ensure the compliance program is adequately resourced, including budget, staffing, and tools.
5. Review the annual compliance work plan and monitor progress against it.
6. Review reports on compliance training completion rates and effectiveness.
7. Review summary reports on compliance investigations and corrective actions (respecting confidentiality requirements).
8. Escalate matters to the Executive Director when Committee action alone is insufficient.

5.5 Reporting

The Committee, through the Compliance Officer, will provide a written summary of its activities to the Executive Director after each quarterly meeting. This summary should include key discussion topics, decisions, open risks, and the status of action items.

5.6 Conflicts of Interest

If a compliance matter involves a Committee member, that member must disclose the conflict and recuse themselves from discussion and decision-making on that matter. The recusal and reason will be noted in the meeting minutes.

Procedures

Responsibilities

Steps

1. The Executive Director appoints initial Committee members and communicates the appointments to employees.
2. The Chair schedules quarterly meetings for the full calendar year in advance.
3. The Chair distributes the agenda at least five business days before each meeting.
4. Minutes are finalized and distributed to Committee members within five business days after each meeting.
5. The Chair submits a written quarterly summary to the Executive Director within 10 business days of each meeting.
6. The Committee reviews this charter annually and recommends updates as needed.

Training Requirements

All Committee members must complete general compliance training within 30 days of appointment. Members are expected to stay informed on compliance topics relevant to their functional area. The Compliance Officer will provide Committee-specific briefings on regulatory changes or emerging risks as part of quarterly meetings.

Reporting and Enforcement

Committee members who fail to attend meetings or complete assigned action items without reasonable justification may be replaced at the discretion of the Executive Director. Concerns about Committee operations should be raised with the Compliance Officer or, if the concern involves the CO, with the Executive Director directly.