Code of Conduct

The purpose of Yes I Can Licensed Behavior Analyst PLLC (“Triumph”) Code of Conduct (hereafter the “Code”) is two-fold: to provide guidance to all employees; and to assist us in carrying out our daily activities within appropriate ethical and legal standards, specifically to prevent the occurrence of fraud, waste, and abuse. These obligations apply to our relationships with clients, affiliated providers, third-party payers, subcontractors, independent contractors, vendors, consultants, and one another.

The Code is a critical component of our overall Compliance Program. We have developed the Code to ensure that we meet our ethical standards and comply with applicable laws and regulations.

Employees

Each staff member will be provided with a copy of the Code at the time of their initial hire and annually.

• Code training will be conducted within ninety (90) days of hire for new staff and all new staff must sign an acknowledgement of the Code at the time that training occurs, indicating their understanding and commitment to follow the Code.
• Annually, each supervisor will review the Code and each employee will be required to re-sign the acknowledgement form.

Supervisors

Supervisors must set an example in following the Code. All supervisory employees are expected to exercise their responsibilities in a manner that is kind, sensitive, thoughtful and respectful, ensure that their employees have sufficient information to comply with the applicable laws and regulations; and the policies and procedures of the organization, including but not limited to the Compliance Plan.

Independent Contractors and Vendors

Independent Contractors and Vendors will be provided with a copy of the Code at the time of entering into a written agreement with the organization. Each independent contractor and Vendor must sign an acknowledgement of the Code at the time of initial contracting, and annually thereafter, as scheduled by Triumph, indicating his/her/its understanding and commitment for him/herself and Vendor personnel to follow the Code.

Mission Statement

Above all else, Triumph is committed to the care and improvement of human life. In recognition of this commitment, we will strive to deliver high quality Applied Behavior Analysis (ABA) services in the communities we serve. At Triumph, we are dedicated to enhancing the lives of individuals and families through the power of ABA. Our mission is to empower individuals with diverse needs to achieve their fullest potential by delivering person-centered, evidence-based, and compassionate ABA services.

Core Values

In pursuit of our mission, we believe the following value statements are essential and timeless:

• We recognize and affirm the unique and intrinsic worth of everyone.
• We treat all those we serve with respect, dignity, compassion, and kindness.
• We act with absolute honesty, integrity, and fairness in the way we conduct our business.
• We trust our colleagues as valuable members of our healthcare team and pledge to treat one another with loyalty, respect, and dignity.

Commitment to Stakeholders

We affirm the following commitments to stakeholders:

• To our clients: We are committed to providing high quality care that is sensitive, compassionate, promptly delivered, and cost-effective.
• To our colleagues: We are committed to a work setting that treats all colleagues with fairness, dignity, and respect, and affords them an opportunity to grow, to develop professionally, and to work in a team environment in which all ideas are considered.
• To our third-party payers: We are committed to dealing with our third-party payers in a way that demonstrates our commitment to contractual obligations and reflects our shared concern for high quality healthcare and bringing efficiency and cost-effectiveness to healthcare.
• To our regulators: We are committed to an environment in which compliance with rules, regulations, and sound business practices is woven into the corporate culture.

Rules of Conduct

Triumph provides applied behavior analysis services. These services may be provided only in accordance with applicable federal, state, and local laws and regulations. Such laws and regulations include Medicaid regulations and may also involve requirements relating to licenses, permits, accreditation, access to services, consent to services, record-keeping, access to service records, confidentiality, clients’ rights, and restrictions relating to the corporate practice of medicine.

We will comply with all applicable laws and regulations. All employees, colleagues, contract service providers, vendors, other service partners, and agents (hereafter “employees”) must: (i) be knowledgeable about and ensure compliance with all laws and regulations; and (ii) must immediately report violations or suspected violations to the Compliance Officer, Faigy (Landau) Tyberg.

As individuals working for and on behalf of Triumph, we have an additional responsibility of following specific rules of conduct, as described below:

• Care and respect for everyone;
• Honesty in all communications;
• To comply with both the letter and spirit of laws and regulations that govern our business;
• To take extra care to ensure your work is accurate and complete;
• To avoid conflict of interest, including the acceptance and giving of gifts;
• To conserve resources of the organization by not engaging in wasteful behavior;
• To keep confidential information related to the organization, its clients, and to respect the privacy of clients and fellow employees;
• To bill individuals and third party payors accurately;
• To complete tasks in a timely manner and meet expectations for the quality of work that the organization strives to achieve;
• To report any compliance issue or potential violation of applicable compliance laws, regulations, and policies, including the Compliance Program, to the Compliance Officer;
• To respect the role of the Governing Body and management and to fully implement their decisions; and
• To consult the organization’s leadership when questions arise as to the conduct permitted under applicable laws, regulations, and policies, including the Compliance Program.