REG-009

Role Responsibility Register

Version 1.1Approved by Compliance Officer · 2026-10-14Review cycle: Annual

Instructions for Use

This register lists the responsibilities the Company's governance assigns to each role, one row per responsibility, each citing the documents that assign it. Each row carries a stable identifier (RSP-NNN) and names its roles by their keys in the role register (REG-008). It serves three uses:

The compliance section of a job description. A role's rows marked as compliance responsibilities are the compliance section its job description cites by this register's identifier and version. The job description stays with Human Resources.
Recurring work. A row with a cadence or a trigger is work the compliance management system schedules for the role. Where the work is already an obligation in the compliance obligations register (REG-005), the row names that obligation and the system schedules it once.
Training coverage. A role's rows are the scope its training must cover.

Who is named. A row names one or more role keys from REG-008. The engagement kind employee names every employee, and the supervisor designation names anyone who supervises another employee. The Compliance Committee's duties stay in its charter (POL-002) and are not rows here.

How to use this register:

Read the row's sources before acting on it. The row is the index; the governing document carries the full requirement.
When a governance document adds, changes, or removes a responsibility, revise this register in the same cycle.
Retired responsibilities keep their identifier with a Retired status. Identifiers are never reused.

Responsibilities

Maintained by: Compliance Officer

One row per responsibility, grouped under the first role it names. A row that names several roles applies to each. The trigger is blank where the event is named in the responsibility itself.

Executive Director

ID	Role	Responsibility	Mode	Cadence	Trigger	Obligation	Compliance	Source
RSP-001	executive-director	Appoint the Compliance Officer and communicate the appointment to all employees.	Trigger				Yes	POL-001
RSP-002	executive-director	Receive the Compliance Officer's quarterly compliance reports.	Cadence	Quarterly			Yes	POL-001
RSP-003	executive-director	Ensure the Compliance Officer has adequate resources and budget.	Standing				Yes	POL-001; PER-001
RSP-004	executive-director	Ensure the compliance program and the functions it relies on are adequately resourced, including fraud, waste, and abuse prevention, overpayment repayment and corrective action, credential verification and tracking, exclusion screening, and billing.	Standing				Yes	COC-001; POL-004; POL-006; POL-010; POL-011; SOP-003; POL-013
RSP-005	executive-director	Support enforcement and corrective action when compliance problems are confirmed.	Trigger				Yes	POL-004; POL-005; POL-008; POL-013
RSP-006	executive-director	Champion the Code of Conduct and support its consistent enforcement, including at the leadership level.	Standing				Yes	COC-001
RSP-007	executive-director	Appoint Compliance Committee members and communicate the appointments to employees.	Trigger				Yes	POL-002
RSP-008	executive-director	Receive the Compliance Committee's quarterly summary reports.	Cadence	Quarterly			Yes	POL-002
RSP-009	executive-director	Act on matters the Compliance Committee escalates.	Trigger				Yes	POL-002
RSP-010	executive-director	Approve the engagement of outside counsel, including on Stark and antitrust questions.	Trigger				Yes	POL-003; POL-006; POL-007; POL-012
RSP-011	executive-director	Serve as the alternate reporting path when a concern involves the Compliance Officer.	Standing				Yes	POL-003
RSP-012	executive-director	Direct all marketing and outreach activity.	Standing				No	POL-005
RSP-013	executive-director	Ensure outreach and marketing practices comply with the improper inducements policy.	Standing				Yes	POL-008
RSP-014	executive-director	Sign vendor and referral-source arrangements only after Compliance Officer review.	Trigger		At engagement		Yes	POL-005
RSP-015	executive-director	Approve physician arrangements only after Compliance Officer review.	Trigger		At engagement		Yes	POL-007
RSP-016	executive-director	Review conflict-of-interest disclosures that involve the Compliance Officer.	Trigger				Yes	POL-009
RSP-017	executive-director	Act on escalated conflicts of interest that a management plan cannot resolve.	Trigger				Yes	POL-009
RSP-018	executive-director	Hold ultimate accountability for organizational licenses and provider enrollment.	Standing				Yes	POL-010
RSP-019	executive-director	Act on confirmed exclusion matches, including the employment or contract decision.	Trigger				Yes	POL-011; SOP-003
RSP-020	executive-director	Set rates, compensation strategy, and market decisions independently of competitors.	Standing				Yes	POL-012
RSP-021	executive-director	Approve benchmarking activity the Compliance Officer recommends, only through aggregated third-party surveys.	Trigger		On a request		Yes	POL-012
RSP-022	executive-director	Designate CORI authorized users.	Standing				Yes	POL-017
RSP-023	executive-director; compliance-officer	Participate in CORI adverse-decision reviews.	Trigger				Yes	POL-017
RSP-024	executive-director	Make final employment decisions, including those arising from CORI results.	Trigger				No	POL-017
RSP-025	executive-director	Receive sexual harassment complaints.	Standing				Yes	HR-001
RSP-026	executive-director	Ensure prompt and impartial investigation of sexual harassment complaints.	Trigger				Yes	HR-001
RSP-027	executive-director	Decide on corrective action for substantiated sexual harassment complaints.	Trigger				Yes	HR-001
RSP-028	executive-director	Oversee consistent enforcement of the sexual harassment policy.	Standing				Yes	HR-001
RSP-029	executive-director	Approve every external breach notice before it is sent.	Trigger				Yes	SOP-002
RSP-030	executive-director	Direct any media notice of a breach.	Trigger				Yes	SOP-002
RSP-031	executive-director	Perform the Privacy & Security Officer's breach response steps when an incident involves that officer or the seat is vacant.	Trigger				Yes	SOP-002
RSP-032	executive-director	Remain accountable for payer revalidation and recredentialing performed by the Director of Operations.	Cadence	Per payer schedule		OBL-029	Yes	POL-010

Director of Operations

ID	Role	Responsibility	Mode	Cadence	Trigger	Obligation	Compliance	Source
RSP-033	operations	Maintain written agreements for vendor and contractor arrangements.	Standing				Yes	POL-005
RSP-034	operations	Keep the current list of active arrangements available for compliance review.	Standing				Yes	POL-005
RSP-035	operations	Identify proposed arrangements with outside providers and referral sources and submit them to the Compliance Officer before any commitment is made.	Trigger		At engagement		Yes	POL-007
RSP-036	operations	Maintain MassHealth provider enrollment, including revalidations, renewals, and required change notices, and complete payer revalidation and recredentialing.	Cadence	Per payer schedule		OBL-029	Yes	POL-010
RSP-037	operations	Run pre-engagement exclusion screening for every vendor.	Trigger		At engagement	OBL-033	Yes	POL-011
RSP-038	operations	Include active vendors in the monthly exclusion re-check.	Cadence	Monthly		OBL-002	Yes	POL-011
RSP-039	operations	Maintain the current vendor list used for exclusion screening.	Standing				Yes	POL-011
RSP-040	operations	Ensure operational decisions on staffing, scheduling, and service areas are made independently of competitors.	Standing				Yes	POL-012
RSP-041	operations	Escalate competitor contact that touches restricted topics.	Trigger				Yes	POL-012
RSP-042	operations	Oversee day-to-day billing operations.	Standing				No	POL-013
RSP-043	operations	Ensure claims are submitted timely and accurately.	Standing				Yes	POL-013
RSP-044	operations	Support resolution of documentation and coding issues.	Standing				No	POL-013
RSP-045	operations	Run the intake packet: send each document set, track and verify execution, file the records, issue the family copy, and clear scheduling.	Trigger		At engagement		No	SOP-001

BCBA

ID	Role	Responsibility	Mode	Trigger	Obligation	Compliance	Source
RSP-046	bcba	Verify that services billed under their oversight are authorized, medically necessary, and consistent with the member's authorized treatment plan.	Standing			Yes	POL-004; POL-006; POL-013
RSP-047	bcba	Confirm that documentation meets clinical and payer standards.	Standing			Yes	POL-004; POL-006
RSP-048	bcba	Complete required documentation reviews and cosignatures.	Standing			Yes	POL-013
RSP-049	bcba	Base every referral to an outside provider solely on the member's clinical needs and document the clinical basis.	Standing			Yes	POL-005
RSP-050	bcba	Report any offer of remuneration tied to referrals.	Trigger			Yes	POL-005
RSP-051	bcba	Select reinforcers based on clinical need and document them in the authorized treatment plan.	Standing			Yes	POL-008
RSP-052	bcba; technician	Maintain license and certification in active status and complete continuing education and supervision requirements.	Standing			Yes	POL-010
RSP-053	bcba; technician	Submit credential renewal evidence before the expiration date.	Trigger	Before expiry	OBL-060	Yes	POL-010
RSP-054	bcba; technician	Report any credential lapse or board action within one business day.	Trigger			Yes	POL-010
RSP-055	bcba	Provide and document the required supervision of behavior technicians and any BCaBA employees.	Standing		OBL-037	Yes	POL-010; POL-013
RSP-056	bcba	Confirm that supervised employees practice within scope.	Standing			Yes	POL-010
RSP-057	bcba	Apply the antitrust policy in professional associations, conferences, and contact with peers at other providers.	Standing			Yes	POL-012
RSP-058	bcba	Report restricted discussions with competitors.	Trigger			Yes	POL-012
RSP-059	bcba	Review the clinical consents with the family before signature: the consent for functional behavior assessment and the service agreement's consent to treatment with its elections.	Trigger	At engagement		Yes	SOP-001

Behavior Technician

ID	Role	Responsibility	Mode	Compliance	Source
RSP-060	technician	Document each session at the time of service, including member, date, start and end times, service delivered, and signature.	Standing	Yes	POL-006; POL-013
RSP-061	technician	Record sessions accurately, including missed or shortened sessions.	Standing	Yes	POL-006; POL-013
RSP-062	technician	Decline gifts beyond nominal value from member families or vendors and report offers to the Compliance Officer.	Standing	Yes	POL-005
RSP-063	technician	Use only the reinforcers documented in the client's treatment plan.	Standing	Yes	POL-008
RSP-064	technician	Do not give personal gifts to clients or families.	Standing	Yes	POL-008

Billing and Recovery Specialist

ID	Role	Responsibility	Mode	Trigger	Compliance	Source
RSP-065	billing	Review claims against supporting documentation, confirming it is complete, before submission, and submit only supported claims.	Standing		Yes	POL-004; POL-006; POL-013
RSP-066	billing	Hold any claim that is not fully supported by documentation and notify the responsible provider.	Standing		Yes	POL-013
RSP-067	billing	Identify, log, and escalate billing irregularities, errors, credit balances, payer takebacks, and suspected overpayments to the Compliance Officer.	Trigger		Yes	POL-004; POL-006; POL-013
RSP-068	billing	Alert the Compliance Officer to billing or referral patterns that suggest an improper arrangement.	Trigger		Yes	POL-005
RSP-069	billing	Flag any claim, payer enrollment, or service change that involves Medicare or a designated health service category and escalate it to the Compliance Officer.	Trigger		Yes	POL-007
RSP-070	billing	Do not waive or reduce any amount a client owes without a written determination approved by the Compliance Officer.	Standing		Yes	POL-008
RSP-071	billing	Escalate financial hardship requests to the Compliance Officer under POL-008 Section 5.5.	Trigger	On a request	Yes	POL-008
RSP-072	billing	Confirm before claim submission that the rendering provider's credential was active on the date of service, and hold any claim that fails this check.	Standing		Yes	POL-010
RSP-073	billing	Keep payer rates, contract terms, and negotiating positions confidential.	Standing		Yes	POL-012
RSP-074	billing	Escalate any competitor request for rate or contract information.	Trigger		Yes	POL-012
RSP-075	billing	Assign codes and units that match the documentation, following the payer's coding and unit rules.	Standing		Yes	POL-013
RSP-076	billing	Reconcile payer remittances against submitted claims.	Standing		Yes	POL-013

Compliance Officer

ID	Role	Responsibility	Mode	Cadence	Trigger	Obligation	Compliance	Source
RSP-077	compliance-officer	Develop, implement, and manage the compliance program, including all related policies and procedures.	Standing				Yes	POL-001; PER-001
RSP-078	compliance-officer	Stay current with changes to federal, state, and local laws and regulations that affect operations, and update policies accordingly.	Standing				Yes	POL-001; PER-001
RSP-079	compliance-officer	Maintain the policies assigned to the Compliance Officer: fraud, waste, and abuse; anti-kickback; improper inducements; state licensing; antitrust and fair dealings; and coding and billing.	Standing				Yes	POL-004; POL-005; POL-008; POL-010; POL-012; POL-013
RSP-080	compliance-officer	Oversee compliance training for all employees, including onboarding training, annual refreshers, and role-specific modules.	Standing				Yes	POL-001; PER-001; TRN-001
RSP-081	compliance-officer	Own the compliance training program and its content.	Standing				Yes	TRN-001
RSP-082	compliance-officer	Approve training content and update it when policies or regulations change.	Trigger		On policy adoption or material revision		Yes	TRN-001
RSP-083	compliance-officer	Maintain confidential channels for employees to report compliance concerns or potential violations without fear of retaliation.	Standing				Yes	POL-001; PER-001
RSP-084	compliance-officer	Coordinate internal audits and monitoring activities as outlined in the annual compliance work plan.	Cadence	Per the annual compliance work plan			Yes	POL-001; PER-001
RSP-085	compliance-officer	Lead or oversee investigations into reported compliance concerns under POL-003, conducting each investigation or assigning an investigator, keep the investigation records, and coordinate corrective actions for confirmed violations.	Trigger				Yes	POL-001; PER-001; POL-004; POL-005; POL-006; POL-010; POL-012; POL-013; COC-001; POL-003; POL-003-SOP
RSP-086	compliance-officer	Provide regular updates on compliance risks, program effectiveness, and open items to the Compliance Committee and Executive Director, in a written report at least quarterly.	Cadence	Quarterly		OBL-006	Yes	POL-001; PER-001
RSP-087	compliance-officer	Monitor disciplinary actions across the organization to verify they are applied fairly and consistently.	Standing				Yes	POL-001; PER-001
RSP-088	compliance-officer	Own the ethics component of the compliance program: the Code of Conduct and its annual acknowledgment, the conflict-of-interest and gift standards, and the ethics reporting channel.	Standing				Yes	POL-001; PER-001
RSP-089	compliance-officer	Chair the Compliance Committee.	Standing				Yes	POL-001; PER-001
RSP-090	compliance-officer	Develop or update the annual compliance work plan within 30 days of appointment and annually thereafter, and maintain it.	Cadence	Annual		OBL-011	Yes	POL-001; PER-001
RSP-091	compliance-officer	Review and update the Compliance Officer Charter annually, or sooner if regulatory changes require it.	Cadence	Annual		OBL-012	Yes	PER-001
RSP-092	compliance-officer	Escalate directly to the Compliance Committee when a concern involves the Executive Director.	Trigger				Yes	PER-001
RSP-093	compliance-officer	Set Compliance Committee meeting agendas and distribute each agenda at least five business days before the meeting.	Cadence	Quarterly			Yes	POL-002
RSP-094	compliance-officer	Prepare, or delegate the preparation of, Compliance Committee minutes.	Cadence	Quarterly		OBL-004	Yes	POL-002
RSP-095	compliance-officer	Present compliance reports at Compliance Committee meetings.	Cadence	Quarterly			Yes	POL-002
RSP-096	compliance-officer	Track Compliance Committee action items.	Standing				Yes	POL-002
RSP-097	compliance-officer	Own the full compliance ticket lifecycle.	Standing				Yes	POL-003; POL-003-SOP
RSP-098	compliance-officer	Triage each compliance ticket.	Trigger				Yes	POL-003; POL-003-SOP
RSP-099	compliance-officer	Assign Case Owners to compliance tickets.	Trigger				Yes	POL-003; POL-003-SOP
RSP-100	compliance-officer	Determine escalation and reporting obligations for each compliance ticket.	Trigger				Yes	POL-003; POL-003-SOP
RSP-101	compliance-officer	Approve compliance ticket closure.	Trigger				Yes	POL-003; POL-003-SOP
RSP-102	compliance-officer	Track corrective action plans.	Standing				Yes	POL-003
RSP-103	compliance-officer	Oversee fraud, waste, and abuse monitoring and conduct periodic coding, billing, and claim documentation audits under the annual compliance work plan.	Cadence	Per the annual compliance work plan		OBL-028	Yes	POL-004; POL-013
RSP-104	compliance-officer	Report fraud, waste, and abuse monitoring and coding and billing audit results to the Compliance Committee.	Cadence	Per the annual compliance work plan			Yes	POL-004; POL-013
RSP-105	compliance-officer	Quantify confirmed overpayments and coordinate their report and return to the payer within 60 days of identification.	Trigger				Yes	POL-004; POL-006
RSP-106	compliance-officer	Maintain the supporting record for each confirmed overpayment.	Trigger				Yes	POL-006
RSP-107	compliance-officer	Report false claims and overpayment matters and their outcomes to the Compliance Committee.	Trigger				Yes	POL-006
RSP-108	compliance-officer	Review proposed arrangements with referral sources and vendors, and document each review and its conclusion.	Trigger		At engagement		Yes	POL-005
RSP-109	compliance-officer	Report anti-kickback review and investigation findings to the Compliance Committee.	Standing				Yes	POL-005
RSP-110	compliance-officer	Review proposed financial relationships with physicians and document the analysis and conclusion.	Trigger		At engagement		Yes	POL-007
RSP-111	compliance-officer	Maintain physician arrangement records.	Standing				Yes	POL-007
RSP-112	compliance-officer	Report physician arrangement review activity to the Compliance Committee.	Standing				Yes	POL-007
RSP-113	compliance-officer	Decide nominal value and financial need questions under the improper inducements policy.	Trigger		On a request		Yes	POL-008
RSP-114	compliance-officer	Review marketing, outreach, and intake materials before use.	Trigger		On each use		Yes	POL-008
RSP-115	compliance-officer	Monitor OIG threshold updates for nominal-value items.	Standing			OBL-015	Yes	POL-008
RSP-116	compliance-officer	Maintain, or assign a designee to maintain, a log of items provided under POL-008 Section 5.3 per client per calendar year.	Standing				Yes	POL-008
RSP-117	compliance-officer	Report inducement approvals, questions, and confirmed issues to the Compliance Committee.	Standing				Yes	POL-008
RSP-118	compliance-officer	Review each conflict-of-interest disclosure, determine whether a conflict exists, and document a written management plan where needed.	Trigger				Yes	POL-009
RSP-119	compliance-officer	Maintain the conflict-of-interest disclosure log.	Standing				Yes	POL-009
RSP-120	compliance-officer	Report a summary of conflict-of-interest disclosures and management plans to the Compliance Committee at least annually.	Cadence	Annual		OBL-019	Yes	POL-009
RSP-121	compliance-officer	Audit credential files and the credential tracking log, with a sample of personnel files, and report results to the Compliance Committee.	Cadence	Annual		OBL-010	Yes	POL-010
RSP-122	compliance-officer	Oversee the exclusion screening program.	Standing				Yes	POL-011
RSP-123	compliance-officer	Verify every potential exclusion match and decide whether it is confirmed.	Trigger				Yes	POL-011; SOP-003
RSP-124	compliance-officer	Direct the response to a confirmed exclusion match.	Trigger				Yes	POL-011; SOP-003
RSP-125	compliance-officer	Coordinate any required disclosure and repayment to the payer arising from a confirmed exclusion match.	Trigger				Yes	POL-011
RSP-126	compliance-officer	Decide on a candidate's disclosure of an exclusion.	Trigger				Yes	SOP-003
RSP-127	compliance-officer	Report exclusion screening completion and results to the Compliance Committee.	Standing				Yes	POL-011; SOP-003
RSP-128	compliance-officer	Advise employees before competitor contact on restricted topics.	Trigger		On a request		Yes	POL-012
RSP-129	compliance-officer	Review benchmarking surveys and trade-association participation, and recommend benchmarking for Executive Director approval.	Trigger		On a request		Yes	POL-012
RSP-130	compliance-officer	Coordinate referral of antitrust matters to outside counsel through the Executive Director.	Trigger				Yes	POL-012
RSP-131	compliance-officer	Oversee the CORI screening program.	Standing				Yes	POL-017
RSP-132	compliance-officer	Confirm that CORI authorized users are registered with DCJIS and trained.	Standing				Yes	POL-017
RSP-133	compliance-officer	Approve any secondary dissemination of CORI before it occurs.	Trigger		On a request		Yes	POL-017
RSP-134	compliance-officer	Report CORI screening completion and outcomes to the Compliance Committee.	Standing				Yes	POL-017
RSP-135	compliance-officer	Maintain the Code of Conduct and answer questions about it.	Standing				Yes	COC-001
RSP-136	compliance-officer	Review the Code of Conduct at least annually.	Cadence	Annual		OBL-014	Yes	COC-001
RSP-137	compliance-officer	Track workforce acknowledgments of the Code of Conduct and the sexual harassment policy.	Standing				Yes	COC-001; HR-001
RSP-138	compliance-officer	Track compliance training completion.	Standing				Yes	COC-001
RSP-139	compliance-officer	Report training completion rates to the Compliance Committee.	Cadence	Quarterly		OBL-006	Yes	TRN-001
RSP-140	compliance-officer	Ensure the sexual harassment policy is distributed at hire and annually.	Cadence	Annual		OBL-020	Yes	HR-001
RSP-141	compliance-officer	Coordinate with the Executive Director where a sexual harassment complaint overlaps a compliance matter.	Trigger				Yes	HR-001
RSP-142	compliance-officer	Handle sexual harassment reports made through the anonymous channel under POL-003.	Trigger				Yes	HR-001
RSP-143	compliance-officer	Open and maintain the compliance ticket for each breach incident under POL-003-SOP.	Trigger				Yes	SOP-002
RSP-144	compliance-officer	Run any sanction or corrective action that follows a breach incident.	Trigger				Yes	SOP-002

Privacy & Security Officer

ID	Role	Responsibility	Mode	Trigger	Compliance	Source
RSP-145	privacy-security-officer	Answer questions about the authorization for use or disclosure and any privacy element of the intake packet.	Trigger	On a request	Yes	SOP-001
RSP-146	privacy-security-officer	Own the response to each suspected breach.	Trigger		Yes	SOP-002
RSP-147	privacy-security-officer	Direct containment of a breach, running electronic containment under the officer's administrative access.	Trigger		Yes	SOP-002
RSP-148	privacy-security-officer	Run the breach risk assessment.	Trigger		Yes	SOP-002
RSP-149	privacy-security-officer	Select the breach notice lanes and prepare every notice.	Trigger		Yes	SOP-002
RSP-150	privacy-security-officer	File the breach response record.	Trigger		Yes	SOP-002

Human Resources

ID	Role	Responsibility	Mode	Cadence	Trigger	Obligation	Compliance	Source
RSP-151	hr	Provide the conflict-of-interest disclosure form during onboarding and forward the completed form to the Compliance Officer.	Trigger		At hire	OBL-032	Yes	POL-009
RSP-152	hr	Collect the conflict-of-interest disclosure form in the annual refresh and forward completed forms to the Compliance Officer.	Cadence	Annual		OBL-019	Yes	POL-009
RSP-153	hr	Perform primary-source verification of each required credential at hire, before the first day of clinical work.	Trigger		At hire		Yes	POL-010
RSP-154	hr	Re-verify each credential by primary source at each renewal and update the record.	Trigger		Before expiry		Yes	POL-010
RSP-155	hr	Maintain the credential tracking log and personnel file records.	Standing				Yes	POL-010
RSP-156	hr	Issue credential renewal reminders to the employee and their supervisor 90 days and 30 days before each expiration date.	Trigger		Before expiry	OBL-060	Yes	POL-010
RSP-157	hr	Run pre-hire exclusion screening for every candidate.	Trigger		At hire	OBL-030	Yes	POL-011; SOP-003
RSP-158	hr	Run pre-engagement exclusion screening for every contractor.	Trigger		At engagement		Yes	POL-011
RSP-159	hr	Build the monthly screening roster and re-screen all current employees and active contractors against the three exclusion lists.	Cadence	Monthly		OBL-001	Yes	POL-011; SOP-003
RSP-160	hr	Record and file each exclusion screening result, saving the evidence, and keep the exclusion screening log.	Standing				Yes	POL-011; SOP-003
RSP-161	hr	Forward every potential exclusion match to the Compliance Officer.	Trigger				Yes	SOP-003
RSP-162	hr	Confirm each month's exclusion screening cycle complete.	Cadence	Monthly			Yes	SOP-003
RSP-163	hr	Set and administer compensation and recruiting practices without coordination with other employers.	Standing				Yes	POL-012
RSP-164	hr	Escalate any outside request to discuss wages, benefits, or hiring.	Trigger				Yes	POL-012
RSP-165	hr	Administer the CORI Acknowledgement Form in the HRIS at onboarding.	Trigger		At hire	OBL-031	Yes	POL-017
RSP-166	hr	Verify each candidate's identity before a CORI check is requested.	Trigger		At hire		Yes	POL-017
RSP-167	hr	Run iCORI checks as an authorized user after the conditional offer.	Trigger		At hire	OBL-031	Yes	POL-017
RSP-168	hr	Run and track the annual CORI cycle: the refreshed acknowledgment form and the re-check for every employee.	Cadence	Annual		OBL-007	Yes	POL-017
RSP-169	hr	File CORI results in secure limited-access storage.	Standing				Yes	POL-017
RSP-170	hr	Maintain the CORI secondary dissemination log.	Standing				Yes	POL-017

Training Coordinator

ID	Role	Responsibility	Mode	Cadence	Trigger	Obligation	Compliance	Source
RSP-171	training-coordinator	Schedule onboarding compliance training.	Trigger		At hire	OBL-032	Yes	TRN-001
RSP-172	training-coordinator	Schedule annual refresher compliance training.	Cadence	Annual		OBL-017	Yes	TRN-001
RSP-173	training-coordinator	Run training e-signature campaigns and SMS and email notifications.	Standing				Yes	TRN-001
RSP-174	training-coordinator	Collect and file training completion evidence.	Standing				Yes	TRN-001
RSP-175	training-coordinator	Maintain the training completion record.	Standing				Yes	TRN-001
RSP-176	training-coordinator	Report training completion status to the Compliance Officer.	Standing				Yes	TRN-001

Supervisor

ID	Role	Responsibility	Mode	Trigger	Compliance	Source
RSP-177	manager; bcba	Model the Code of Conduct standards and reinforce them with the workforce members they supervise.	Standing		Yes	COC-001
RSP-178	manager; bcba	Ensure clinical practice meets the quality, documentation, and boundary standards in the Code of Conduct.	Standing		Yes	COC-001
RSP-179	manager	Ensure direct reports complete required training on time.	Standing		Yes	TRN-001
RSP-180	manager	Release employees' schedules for training.	Standing		Yes	TRN-001
RSP-181	manager	Release a new employee to client contact only after the client rights module completion is recorded.	Trigger	At hire	Yes	TRN-001
RSP-182	manager	Follow up on escalated training non-completion.	Trigger		Yes	TRN-001
RSP-183	manager	Remove a confirmed excluded person from all federally and state-funded work the day the Compliance Officer directs it.	Trigger		Yes	SOP-003
RSP-184	manager	Model and reinforce the sexual harassment policy.	Standing		Yes	HR-001
RSP-185	manager	Report observed or reported sexual harassment to the Executive Director.	Trigger		Yes	HR-001
RSP-186	manager	Protect reporters of sexual harassment from retaliation.	Standing		Yes	HR-001

Every employee

ID	Role	Responsibility	Mode	Cadence	Trigger	Obligation	Compliance	Source
RSP-187	employee	Cooperate with compliance inquiries and investigations.	Standing				Yes	POL-001; POL-003; COC-001; HR-001
RSP-188	employee	Report compliance concerns and suspected violations, including fraud, waste, abuse, false claims, billing errors, and potential overpayments, promptly through established channels.	Trigger				Yes	POL-001; POL-003; POL-004; POL-006; POL-008; POL-012; COC-001
RSP-189	employee	Report sexual harassment experienced or witnessed.	Trigger				Yes	HR-001
RSP-190	employee	Complete onboarding compliance training and the applicable role-specific modules by the due dates.	Trigger		At hire	OBL-032	Yes	TRN-001
RSP-191	employee	Complete required annual refresher compliance training and applicable role-specific modules by the due dates.	Cadence	Annual		OBL-017	Yes	POL-001; POL-004; POL-006; COC-001; TRN-001
RSP-192	employee	Sign required acknowledgments when presented, including the CORI Acknowledgement Form.	Trigger				Yes	TRN-001; POL-017
RSP-193	employee	Read, understand, and follow the Code of Conduct.	Standing				Yes	COC-001
RSP-194	employee	Acknowledge the Code of Conduct at hire.	Trigger		At hire	OBL-032	Yes	COC-001
RSP-195	employee	Re-acknowledge the Code of Conduct annually.	Cadence	Annual		OBL-018	Yes	COC-001
RSP-196	employee	Deliver and document services accurately and at the time of service.	Standing				Yes	POL-004
RSP-197	employee	Provide only truthful, accurate information in records that support claims.	Standing				Yes	POL-006
RSP-198	employee	Decline prohibited gifts and inducements.	Standing				Yes	POL-005; POL-009
RSP-199	employee	Report offers or solicitations of gifts or anything of value, including offers exceeding the gift limits, to the Compliance Officer.	Trigger				Yes	POL-005; POL-009
RSP-200	employee	Route questions about any arrangement to the Compliance Officer before acting.	Trigger		On a request		Yes	POL-005
RSP-201	employee	Do not commit the Company to any arrangement with a physician or referral source.	Standing				Yes	POL-007
RSP-202	employee	Route inquiries from physicians about business or financial arrangements to the Director of Operations or the Compliance Officer.	Trigger		On a request		Yes	POL-007
RSP-203	employee	Do not offer anything of value to clients, families, or prospective clients beyond clinical reinforcers and permitted nominal items, and ask the Compliance Officer before acting when unsure.	Standing				Yes	POL-008
RSP-204	employee	Disclose conflicts of interest at hire.	Trigger		At hire	OBL-032	Yes	POL-009
RSP-205	employee	Disclose conflicts of interest annually, including a signed no-conflicts response.	Cadence	Annual		OBL-019	Yes	POL-009
RSP-206	employee	Disclose a conflict of interest within 10 business days of a change in circumstances.	Trigger		On a change in circumstances	OBL-036	Yes	POL-009
RSP-207	employee	Comply with approved conflict-of-interest management plans.	Standing				Yes	POL-009
RSP-208	employee; contractor	Disclose to the Compliance Officer within one business day any exclusion, suspension, debarment, or pending action that could lead to exclusion.	Trigger		On a change in circumstances		Yes	POL-011; SOP-003
RSP-209	employee	Avoid discussing wages, rates, hiring, or markets with competitors.	Standing				Yes	POL-012
RSP-210	employee	Promptly disclose any criminal matter that could affect eligibility for the role.	Trigger		On a change in circumstances		Yes	POL-017
RSP-211	employee	Refrain from sexual harassment.	Standing				Yes	HR-001
RSP-212	employee	Report a suspected breach to the Privacy & Security Officer the same day it is suspected and take the immediate mitigation within reach.	Trigger				Yes	SOP-002

Form Realization and Fallback

This is the canonical, authoritative version of Form REG-009, maintained in the compliance documentation. It defines the columns and vocabulary that any realization of the role responsibility register must capture.

Field contract. Each row defines: the identifier (RSP-NNN, stable for the life of the responsibility, never reused); the roles it is assigned to, by their keys in REG-008 or the engagement kind employee; the responsibility in one sentence; the mode; the cadence or trigger, when the mode is not standing; the obligation in REG-005 it carries out, where one exists; whether it is a compliance responsibility; the governing sources; and the profile row it derives from, where one exists.

Mode. Standing (held continuously, printed for the role and never scheduled), Cadence (recurring on a calendar cycle), or Trigger (performed when an event occurs). Cadences and triggers use the vocabulary of the compliance obligations register (REG-005).

Derived from. Empty in this version. Where the row is later derived from a shared base register, the column names the base row.

Division of labor with the compliance management system. This register defines the responsibilities. The compliance management system shows each role's rows, schedules cadence and trigger rows for the people who hold the role, and schedules a row that names a REG-005 obligation once, under that obligation. It ingests this register at each approved revision, matching rows by identifier. A row retired here is closed there. Conflicts resolve in favor of this register.

The documented register here is always available as a fallback. It can be printed and used on paper whenever the electronic system is unavailable.

Retention

The register itself is a controlled document. Its revision history is its record. The record of performing a responsibility retains under the governing document the row cites.