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Code of Conduct

CODE OF BUSINESS CONDUCT

Establishes basic principles which One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral employees, material contractors and subcontractors must follow to ensure full compliance with applicable laws, regulations, and policies.

Dear Patients and Employees,

One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral is committed to the highest ethical standards in the conduct of its business. As healthcare industry professionals, we must use independent judgment to decide the best course of care for clients and their patients. Nonetheless, as the healthcare industry becomes increasingly complex, discerning right from wrong is not always obvious. Because our success is so closely tied to our reputation, it is up to all of us to bolster and protect that reputation. These are the reasons we developed the Code of Business Conduct.

This Code is intended to help you address ethical and compliance issues by providing information, tools, and resources necessary to make good decisions. We want to make it clear for all employees and associates to understand our company’s high ethical standard. Moreover, we strive to always promote open communication and to instill in everyone the importance of raising questions or concerns. The Code expresses expectations and provides you with practical guidance, examples, and references to useful information including detailed policies and procedures as applicable.

The Code is an important part of our ongoing effort to ensure that our workplace is fully committed to honesty, fairness, and integrity. One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s Board of Directors and its senior managers fully support the Code and the policies, procedures, and principles it embodies. Since no code or policy can anticipate every situation that may arise, employees are encouraged to bring questions that may implicate the Code to the attention of any One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral supervisor or manager, the One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral Compliance Officer, the Office of Compliance, or to the Compliance Line.

With your help, we are confident that One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral will continue to deserve the trust that everyone has in us and our reputation for integrity will endure.

Thank you for your continued commitment to One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral, for joining us in this effort, and for incorporating these principles and values into all aspects of your work.

Sincerely,

Chief Executive Officer

Table of Contents

WHO WE ARE

1. Our Story:

One Behavioral Management, LLC is a non-clinical management company that provides logistical support to Texas Behavioral Health, PLLC, dba One Behavioral. One Behavioral offers comprehensive outpatient behavioral health and psychiatric care for adults. Our team of licensed psychiatrists and therapists is skilled in addressing a wide range of psychological concerns with sensitivity and expertise. We focus on early identification and intervention to help prevent the development of more serious psychiatric disorders. Additionally, we specialize in treating various populations, including seniors, women, children, adolescents, and patients with co-existing medical conditions.

One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral operates throughout the Houston area; accordingly, we recognize that we are subject to laws, regulations, and other requirements that may vary across the states in which we operate.

2. Our Mission:

Our mission is to to cultivate and empower self-aware human beings for a better and productive life.

One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral is guided by five principles: client centric, judgment free care, environmental awareness, striving for innovative treatment, commitment to our staff.

Client Centric – We follow our clients throughout their care in all healthcare settings through their individual care team. We are here to find our clients an appropriate healthcare provider, understand their concerns from the type of provider to explaining their insurance benefits. Whatever they need, we are here for them.

Judgement Free Care – We are client focused. We listen to and care for our clients without judgment and provide evidence-based quality care.

Accountability – We take ownership of our solutions. We find a way to work with our clients one way or another. We take it upon ourselves to solve problems by partnering with others when needed.

Learning & Curiosity – We change lives for the better by learning from our peers, clients, and community.

Earning Trust – We act with integrity with our clients, payors, staff. We do what is right and treat every person with mutual respect.

3. Our Purpose:

Our vision is to provide the most comprehensive and accessible behavioral health care anywhere.

4. Our Patients and Consumers:

We are passionate about helping people lead healthy and productive lives. Each day through our work, we can strive to improve individual’s lives and make an impact for the good of society. Caring for people is fundamental to what we do. At One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral, we take this great responsibility as an exceptional privilege.

5. Healthcare Professional Judgment:

Healthcare professionals, e.g., physicians, psychiatrists, psychologists, therapists, depression specialists, and non-physician providers must use their independent professional judgment. As such, based on specialized education, training, and expertise, the healthcare professional can decide the best course of care for the patient. At One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral, we are committed to working with the healthcare professionals by offering best practices and policies, and procedures to allow relevant clinical decisions for the highest quality outcomes and exceptional patient satisfaction. Nonetheless, through this collaborative approach, the mission of the company can be supported.

6. Our Services:

One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral strives to maintain the highest level of quality throughout our business model. This effort starts with our highly skilled staff and the development of various services and continues throughout our locations, operations, marketing, including our business partners. Accordingly, we believe delivering high-quality clinical services is imperative every step of the way. Our commitment to the health and safety of each patient that we deliver services for is always at the forefront of everything we do.

Moreover, we provide our healthcare professionals with the information needed to successfully deliver effective and favorable outcomes. Further, we communicate with regulatory and public health agencies to ensure we comply with all applicable standards and the law.

7. Marketing, Advertising, and Sales Practices:

To fulfill our ethical mandate, One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral associates (including independent contractors) must accurately represent our services, benefits, and prices when engaging in marketing and sales efforts. One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral associates must represent our company with integrity. As such, before distribution of any marketing materials, the materials require company approval to ensure contained information is accurate and more importantly, not misleading. All One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral associates should also follow all specific guidelines established by the company’s Business Development Department and the Office of Compliance.

Any report of a suspected violation of these ethical standards of practice will be promptly investigated. Moreover, if a violation is found, One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral will issue an immediate disciplinary action, up to and including termination of employment. As such, each sales representative must adhere to the Code, all applicable state and federal laws and regulations, and all One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral policies and procedures. It is never acceptable to disregard the Code, the law, or One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s policies and procedures — even if it would result in more sales or business.

OUR CODE IN ACTION

1. Compliance Overview:

For one to be compliant means that everyone’s behavior and business activities are in line with applicable laws, regulations, industry standards, the Code, and One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s policies and procedures.

a. Our Compliance Program

We support all the elements required for a comprehensive compliance program and the program is designed to address the wide range of regulatory requirements that our business lines face.

The Office of Compliance supports our workforce and business partners to promote the integrity of the company’s activities. This ultimately supports compliance with laws, regulations, as well as our internal policies and procedures. The Code of Business Conduct is an important component of One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s Compliance Program.

Every One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral employee and associate is expected to adhere to all laws and One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s policies, procedures, principles, and standards, including this Code. This is a fundamental expectation and condition of employment by, or association with, One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral.

b. Chief Compliance Officer

One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s Chief Compliance Officer is responsible for the Compliance Program. Our Compliance Program’s key components include this Code, other policies and procedures, training, communications, auditing, monitoring, and remediation of wrongdoing. This program is supported by the Compliance Team and designed for our Business Divisions. The Chief Compliance Officer is committed to ensuring the Code is consistently made available and followed throughout One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s Business Divisions. The Chief Compliance Officer also serves as a contact for employees, business partners, customers, and the public on issues relating to the implementation of, and compliance with, the Code.

c. Compliance Policies

The Office of Compliance develops and updates policies and procedures to provide guidelines for complying with the extensive and complicated laws and regulations governing the healthcare industry. Policies are available in the areas of billing, fraud, waste and abuse laws, marketing and sales practices, and the privacy and security of personal information among other critical regulatory areas. Additionally, One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s Business Divisions may issue tailored policies and operating procedures as relevant to identified operations and/or state-specific regulations. All these policies and procedures enable us to detect, correct, and prevent non-compliant activities.

d. Compliance Education

The Compliance Program includes required compliance training (e.g., general, newly hired, and annual courses) for all members of the One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral workforce. Delivery of specialized training for high-risk compliance topics is further developed for certain staff. Independent Contractors are also required to complete specified compliance courses.

One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral has created comprehensive education and awareness programs for employees and contractors. Our education programs may include online modules, live sessions, and periodic communications. The required core compliance training module for our employees and contractors is named “Basic Healthcare Ethics” which contains information related to:

  • 1. Healthcare Fraud, Waste, and Abuse
  • 2. Privacy and Information Security

There will be additional periodic associate trainings that will be made available based on perceived need and specializations.

2. Our Code of Business Conduct:

We believe long-term, trusting business relationships are built by being honest, open, and fair. Our Code reflects this belief. The Code serves as an employee resource to help determine what may or may not be appropriate conduct. The following Code fundamentals are meant to direct integrity within the workplace.

Honesty and Ethical Behavior

Ethical handling of actual or apparent conflicts of interest between personal and professional relationships.

Accurate Documentation

Full, fair, accurate, timely, and understandable disclosure in reports and documents filed with, or submitted to government agencies and/or use in public communications.

Protection of Confidential and Proprietary Information

The protection of One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s confidential and proprietary information, to include patients, employees, customers, contractors, business partners, and vendors.

Compliance with Law and Rules

Compliance with applicable government directives, federal and/or state laws, rules, and regulations; and Company policies and procedures.

Internal Reporting

Prompt internal reporting of any Code violations or any One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral policy or procedure.

Individual Accountability

Accountability for adherence to the Code by every One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral employee or contractor.

The Code applies to all One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral employees, subsidiaries, independent contractors, and the board of directors. Nonetheless, we also seek to do compliant business with patients, customers, suppliers, and resellers who adhere to similar ethical standards. The Code is monitored by the Office of Compliance and is affirmed yearly by every employee through an annual certification process.

As a One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral employee, you are required to read, understand, and abide by the Code. No one has the authority to make you violate the Code and any attempt to do so is unacceptable. You also have the responsibility to observe and promptly report any potential or suspected violations of the Code whether within One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral or through external dealings with our customers or other persons, businesses, or government representatives.

If any employee has an issue with the acknowledgment of or following the Code, one should discuss their concerns with their manager, Human Resources representative, or the Office of Compliance. Even if one fails to acknowledge the Code, one is still obligated to follow the policies and standards contained within.

Managers/supervisors that have a leadership role at One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral are held responsible to:

  • Serve as a role model for ethical behavior
  • Encourage open and honest communication and act when ethical issues are brought forth
  • Ensure those employees or contractors who report to them understand the Code’s requirements
  • Support employees or contractors who, in good faith, raise questions or concerns
  • Address conduct that violates the Code
  • Seek assistance from the Office of Compliance, e.g., if the proper course of action is not clear

While the Code does not address every situation, the use of the Code is intended as a guide. Nonetheless, every employee must exercise sound judgment in decision-making and seek advice in ethical dilemmas and inquire about any concerns not addressed in the Code.

One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral monitors laws and regulations as applicable to our operations locally or nationally. Nonetheless, we trust our employees and contractors to follow the spirit of all laws and act ethically even when a law may not be specific. In some cases, a local business practice may conflict with federal or state law or the Code. When in doubt, ask for guidance.

Other company policies, procedures, and guidelines related to ethical or legal concerns may also be found in One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s Employee Handbook. Any employee may report compliance-related issues directly to the Office of Compliance or the Chief Compliance Officer by phone, or by email.

3. Ethical Decision Making:

One must recognize the importance of determining when to seek advice from managers/supervisors, or the Office of Compliance. The following questions may be used to guide the best pathway for ethical decision-making, facilitate the use of good judgment and avoid the appearance of improper behavior. This tool provides an approach to thinking through the alternatives and ramifications of decisions we may face in the workplace.

When in doubt about a course of conduct, ask the following integrity questions:

  • Is the action, task, or situation consistent with?
    • The Code
    • One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral policies and/or procedures
    • Ethical behavior
    • Laws, rules, or regulations
  • Does the communication or phrase question the Code or Ethical behavior?
    • “Well, maybe just this once”
    • “Nobody will ever know”
    • “It doesn’t matter how it gets done, as long as it gets done”
    • “Everyone does it”
    • “What’s in it for me?”
    • “We always did it this way”
    • “Don’t contact the Compliance line”
    • “Remember, we didn’t have this conversation”
  • Will the conduct reflect well on me and/or One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral?
  • Will the course of action give the appearance of being unethical or illegal?
  • If disclosed to the public, will the course of action discredit me or One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral?
  • If someone treated me the same way, would I be comfortable with the decision or course of action?
  • Am I behaving appropriately in protecting One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s confidential information from disclosure to internal and external parties, e.g., patients, customers, associates, business partners, and vendors?
  • Would I be comfortable if the conduct appeared in the media?

All employees or contractors, no matter their job position is accountable for their actions and behaviors. DO NOT PARTAKE in any activity of MISCONDUCT. When in doubt the best decision would be to report the concern to your manager/supervisor or Office of Compliance.

OUR PEOPLE

1. Work Environment:

At One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral, we take care to ensure workplace safety and appropriate conditions for our employees and others who work with us. Employees should be familiar with and follow, all safety guidelines and promptly report any accidents or unsafe situations to management. Our policies have been developed to safeguard our associates from potential workplace hazards. Employees must become familiar with and understand how these policies apply to their specific job responsibilities or work area. Nonetheless, employees or contractors should seek advice from their manager/supervisor if they have any questions or concerns.

One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral fosters an environment where people should feel safe and are treated with courtesy and professionalism. Accordingly, we promote a workplace that is positive, creative, diverse, and rewarding; an environment that promotes individual expression, innovation, and achievement. Employees are not permitted to use, possess, or be under the influence of alcoholic beverages or illegal drugs on company property including during work hours. Alcohol use at company-sponsored events during work hours may be allowed in special circumstances and with prior approval of the appropriate department leader or the CEO. Violation of this policy will result in disciplinary action, up to and including termination.

2. Fair Treatment:

We strive to ensure everyone working at One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral feels welcome, supported, and inspired to succeed. One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral cares about and is concerned for, the health and wellbeing of its employees. Everyone who works at One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral should encounter a professional environment free from intimidation and harassment. As such, our company defines harassment broadly and prohibits its many forms. For example, harassment may include offensive remarks, unwelcome advances, requests for sexual favors, inappropriate jokes, or ethnic, racist, or sexual slurs.

One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral encourages input from employees on ways to enhance the inclusive and diverse atmosphere of its workplaces. As such, we promote a workplace free from disruptive conduct by employees. We treat everyone with respect and dignity. Our respect for people is demonstrated in what we do and how we act towards everyone we encounter in our work. To meet our commitments to one another and to attract, cultivate and retain talented individuals, it is vital to have a work environment built on mutual trust, respect, and the principles embodied in this Code. We must treat others well and equitably. Moreover, we must not take advantage of others through manipulation, misrepresentation, or concealment.

3. Equal Opportunity:

One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral promotes an equal opportunity environment for all employees. As such, we base employment decisions on business needs, skills, experience, and relative work performance. One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral prohibits discrimination based on race, color, religion, creed, age, sex, national origin, gender identity or expression, sexual orientation, disability, marital status, veteran or military status, genetics or citizenship status, and any other legally protected status. We are committed to working with and providing, reasonable accommodations for employees and applicants with physical or mental disabilities. Disabled employees are encouraged to provide notification from their doctor describing any restrictions on their ability to perform the essential duties or functions of their job. We are committed to following the laws germane to our relationship with our employees. We are proud of our diversity and our commitment to maintaining a diverse workforce

The One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral Employee Handbook contains further information on work environment issues including guidelines on the following: Standards of Conduct; Equal Employment Opportunity; Diversity; Harassment; and Drug-Free Workplace.

Q: WHAT SHOULD I DO IF I BELIEVE I WAS PASSED UP FOR A PROMOTION BECAUSE OF MY AGE?

A: One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral guidelines require that employment decisions be made without regard to the age of the candidate. If you feel you were treated unfairly, contact the Human Resources Department or the Office of Compliance for assistance.

Q: IF I RECEIVED AN EMAIL WITH AN OFFENSIVE JOKE THAT WAS NOT INTENDED FOR ME TO SEE OR READ, IS THAT HARASSMENT?

A: Offensive jokes sent through company email, regardless of the intended recipient, have no place in a workplace that values dignity and respect for every employee. You may respond directly to the coworker, notifying him/her that you found the email offensive. Ask the individual to refrain from sending out such emails in the future and advise you will escalate the matter if it continues. You may also contact Human Resources or the Office of Compliance to discuss the matter. Although the employee may not have intended the offense, it is important to be respectful and considerate of others.

4. Reporting Concerns:

It is up to each employee to ask questions or make a report if we perceive or conclude a business direction or result is unclear. Moreover, each employee should feel comfortable to challenge and report any suspected unethical business conduct, violation of any law or this Code, or violation of the company’s policies or procedures.

Asking questions, reporting concerns, and actively pursuing clarity about choices or actions helps identify and avoid problems more effectively. When in doubt about the right choices, actions, or potential violations, you may seek out advice from a manager/supervisor, or the Office of Compliance. Nonetheless, managers and One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral executives are required to espouse a heightened responsibility for understanding and communicating One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s expectations and must contact the Office of Compliance regarding any potential Code violation.

If you become aware of a situation that violates or may violate the Code, there are several options for reporting. The employee may choose one of the following reporting methods based on comfortability:

  • Discuss the issue with your manager or supervisor
  • Speak with anyone from One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s Compliance staff
  • Email with the attention of One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s Office of Compliance: complinace@texasbehavioral.com
  • Report your concern anonymously to the One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral Compliance Hotline: (281) 727-0039
    • One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral has established a secure third-party Compliance line for reporting potential compliance-related incidents, violations, or misconduct
    • Available 365 days a year, 24 hours a day
    • Every effort is made to protect the confidentiality and anonymity of callers who report issues in good faith
    • There is a non-retaliation policy for reporting concerns in good faith

All Code violations reports will be taken seriously and handled appropriately through follow-up steps such as investigation, remediation, and where necessary, corrective actions. These steps are designed to address issues, learn from mistakes, and avoid the recurrence of problems.

  • The Office of Compliance will direct any investigation of alleged violations of the Code
  • Managers/supervisors should refrain from conducting any independent investigation
  • Each employee is required to cooperate in and maintain the confidentiality of any such investigation
  • Raising a concern regarding noncompliance reinforces the company’s commitment to act ethically in all aspects of our business and fosters a culture of compliance.  Your actions can make a difference.

Q: WHAT IF I REPORT A CONCERN BUT NEVER HEARD ANYTHING FURTHER?

A: Contact the Office of Compliance to confirm the report was received and the issues addressed. Some matters may take longer to resolve, but generally, you should receive some form of update and final resolution. While all matters will be reviewed and evaluated, certain issues due to privacy, confidentiality, and/or severity may not be appropriate for shared details back to the individual who reported.

Q: WHAT HAPPENS IF I AM NOT SATISFIED WITH THE RESOLUTION REGARDING A COMPLAINT I REPORTED?

A: There may be times when the Office of Compliance has investigated and addressed a situation and does not result in a resolution you would have preferred, or where One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral has determined the concern is not contrary to the Code, company policy, or the law. If you continue to have concerns after a resolution has been instituted, please report your concerns back to the Compliance line or Office of Compliance for additional review and response.

Q: WHAT IF SOMEONE DELIBERATELY MAKES A FALSE REPORT AGAINST ME?

A: All investigations are handled professionally and objectively. Intentionally making a false accusation is a serious violation and may lead to disciplinary action, up to and including, termination of employment.

Q: MY MANAGER HAS TOLD ME TO DO SOMETHING THAT I THINK MAYBE ILLEGAL, BUT I AM AFRAID MY MANAGER WILL MAKE MY JOB HARDER, SHOULD I STILL REPORT MY CONCERN?

A: While your manager is generally the person with whom you will discuss any compliance concerns, if your manager’s instruction or request concerns your ethical decision-making, then contacting the Office of Compliance is one option. The Office of Compliance independently reports to the One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral Board of Directors and thereby has the objectivity to evaluate the matter.

Another option is to anonymously call the Compliance line. When reporting concerns through the Compliance line, you will have the assurance of knowing that One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral, through the Office of Compliance, is looking into the situation and retaliation by your manager or others will not be tolerated. Nonetheless, you can always contact the Compliance line if you:

  • Believe the compliance issues are not being resolved, either through the existing managerial chain of command or other reporting options
  • Do not feel comfortable reporting through the normal channels
  • Wish to remain anonymous when filing a report

To assist in the review, those reporting potential violations are encouraged to identify themselves. However, anonymous reports will also be accepted and investigated to the extent possible. Remember that every reasonable effort will be made to keep the identity of anyone reporting a potential violation confidential to the extent possible, consistent with good business practice.

5. Penalties for Violations:

Corrective actions related to Code violations may include disciplinary action (up to and including termination), and/or legal action for:

  • Authorization of, or participation in, a Code violation
  • Refusal to cooperate in the investigation of a reported Code violation
  • Failure by a violator’s manager/supervisor(s) to detect and report a violation, e.g., if such a failure reflects inadequate supervision or lack of oversight on the part of the manager/supervisor(s)
  • Reporting a concern that is knowingly false, or is intended to threaten, intimidate, or retaliate against any person associated with One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral business
  • Retaliation, such as intimidating, threatening, harassing, or maligning any person who has in good faith reported a violation or potential violation

Please refer to the Employee Handbook for more information on One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral processes for disciplinary action.

6. Non-Retaliation Policy:

One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral prohibits retaliating against anyone for raising a legal or ethical concern or cooperating with an investigation. Retaliation can be against the law, leading to potential civil liability and criminal penalties. No one may seek revenge against, or even try to “get even” with any colleague who makes a good faith report, regardless of who is implicated. Retaliation is taken very seriously by the company, and if it occurs, it will result in discipline up to, and including, termination of employment. Alleged retaliation should be reported to the Office of Compliance or Human Resources.

Q: WHAT IF I EXPERIENCE RETALIATION?

A: You should report the matter accordingly, as One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral strictly forbids any retaliation against any person who reports a concern. Reports or complaints made in good faith will not expose you to any sanction, regardless of whether the underlying facts prove to be correct.

Q: SHOULD I REPORT IF I BELIEVE MY SUPERVISOR IS HARASSING ME AND FEEL I MAY LOSE MY JOB?

A: As a valued member of the One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral team, you are entitled to work in an environment free from intimidation, harassment, or hostile or offensive behavior. Contact the Human Resources Department or the Office of Compliance to discuss the matter.

HOW WE OPERATE

1. Avoiding Conflicts of Interest:

A conflict of interest exists whenever a One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral employee’s private interests interfere (or appear to interfere) with One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s interests. Business decisions should be based on One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s needs, rather than your potential personal gain or the interests of your family or friends. Each of us is expected to use good judgment and avoid situations that can lead to a conflict, or the appearance of a conflict Refer to the Employee Handbook for additional information.

You MUST DISCLOSE any activity or relationship that may:

  • Compete with any of One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s business activities
  • Entail providing services to a competitor
  • Interfere with your work duties
  • Otherwise constitutes a conflict of interest regarding One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral

Although it is not possible to list all the circumstances that may signal a potential conflict of interest; consider the following to assist in determining if the activity creates an impending conflict:

  • Do the actions, interests, or relationships make it difficult to perform or give the appearance of interfering with your assigned One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral work duties?
  • Are you or a member of your family receiving improper personal benefits through the activity given your position within the company?
  • Does the activity compete against the interests of One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral?

If you answer “yes” to any of the above questions, the activity may indicate a conflict of interest and you should proceed with the following steps:

  • You must excuse yourself from situations where the conflict could impact your business judgment
  • Disclose any questionable activity(ies) with your immediate manager/supervisor as soon as you become aware of the potential conflict
  • You must contact and disclose the conflict of interest to the Office of Compliance
  • This is an ongoing responsibility for all One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral employees and associates; failure to disclose may result in disciplinary action, up to and including, termination of employment.

Q: IS IT OKAY TO TAKE ON EMPLOYMENT OUTSIDE OF One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral (MOONLIGHT)?

A: Outside employment could pose a conflict of interest; you should disclose all relevant facts to your manager/supervisor or the Office of Compliance. After consultation with your manager/supervisor and the situation has been evaluated, only then will it be determined if the additional activity/job does not affect the performance of your duties for One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral and not be considered a conflict of interest.

Q: WHAT IF I OPERATE A SMALL BUSINESS FROM HOME AND MY MANAGER AND THE OFFICE OF COMPLIANCE HAVE INFORMED ME THAT THE BUSINESS DOES NOT REPRESENT A CONFLICT OF INTEREST, IS IT OKAY FOR MY CUSTOMERS TO LEAVE MESSAGES ON MY COMPANY VOICEMAIL?

A: No. Even though there is no conflict of interest, you must use One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral Company assets (including email and voicemail) only for company-related business. Employees or contractors are not permitted to use any One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral asset to support a second job, self-employment venture, or consulting effort.

Q: WHAT IF I DEVELOP A PRODUCT OR SERVICE THAT I THINK WOULD BE BENEFICIAL FOR One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral AM I PROHIBITED FROM BECOMING SUPPLIERS OR OUTSIDE CONTRACTORS TO One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral?

A: This situation could cause divided loyalty or at least, the appearance of a conflict of interest. One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral does not typically purchase products or services from its employees. Our reputation for impartiality and fair dealing with suppliers could be damaged by routinely acquiring products or services from employees, even with full and open competition. Before considering such an arrangement, seek written permission from the appropriate One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral senior leadership. Nonetheless, most One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral employee’s work product developments, i.e., created while employed by One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral, belongs to One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral. Contact the Office of Compliance for assistance regarding any of these matters.

2. Protection of One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral Assets and Reputation:

Through our work, we are caretakers of One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral. It is our responsibility to protect and use One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s assets from the physical property such as vehicles and computer equipment to intellectual property, trade secrets; and know-how with care to ensure the proper use. We must all use good judgment to ensure that One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s assets are not lost, stolen, misused, or wasted.

Moreover, One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s reputation is one of its greatest assets. We are each responsible for enhancing and protecting One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s reputation. We are each personally accountable for any views or content published or shared with people outside the company.

Additional information may be found in the Employee Handbook. More specific guidance on the appropriate use of company information systems and data may be found in the One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral Acceptable Use Policy maintained by the Information Technology (IT) Department.

3. Use of Internet, Social Media, and Communications Systems:

In external interactions, we need to be mindful of whether we can be identified as affiliated with One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral. Moreover, we must consider how any statements related to our work may reflect on the company. Access to the Internet and all One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral electronic communication systems such as email, and voicemail are made available to employees to carry out legitimate business of the company and incidental use. In the context of social media where interactions are quick and dynamic and can become highly visible, careless communications can pose a significant risk to One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s reputation. As such, we are all responsible for employing careful communication strategies in our communications and protecting One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s confidential information. Refer to the Employee Handbook 6.13 Social Media Policy.Refrain from postings that include unlawful discriminatory remarks, harassment, and threats of violence or other unlawful conduct

Social Media Provisions:

  • Do not comment on trade secrets and proprietary company information (for example, business, financial, or marketing strategies) without the advance approval of your manager/supervisor, Human Resources, or the Office of Compliance
  • Do not make negative comments about our clients on any social media
  • Refrain from postings that include unlawful discriminatory remarks, harassment, and threats of violence or other unlawful conduct
  • You may NOT create a blog or online group related to One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral (not including blogs or discussions involving wages, benefits, or other terms and conditions of employment, or protected concerted activity) without the advance written approval from the Business Development Department, Human Resources, or the Office of Compliance
  • Do not use social media on company equipment during working time unless your use is authorized by the manager for legitimate, pre-approved company business
  • Respect copyright, trademark, and similar laws and use such protected information in compliance with applicable legal standards

Q: CAN I USE MY WORK COMPUTER FOR PERSONAL USE?

A: As a critical corporate asset, we have taken steps to minimize risk and safeguard company information especially our IT Systems. These measures will help maintain confidentiality, provide data integrity, system availability, and user accountability. While certain job responsibilities require access to the Internet and the use of certain software, the inappropriate use of the Internet and email places our company and others at significant risk. Any device or computer provided by the company for your use including, but not limited to, desk phones, cell phones, tablets, laptops, desktop computers, and iPads, etc., are property of the company and should primarily be used for business purposes. Under no circumstances may company-owned computers or other electronic equipment, including personal devices owned by the employee, be used on company time to obtain, view, or reach any questionable or “R” rated material such as pornographic media or web content. Viewing any such material or sending pornographic, inappropriate, or discriminatory jokes or stories via email, is considered harassment, and will be addressed according to our harassment guidelines. Violations of company expectations regarding acceptable use and harassment can lead to disciplinary action up to and including termination of employment. Similarly, any email content that contains derogatory or inflammatory remarks about an individual’s race, age, disability, religion, national origin, physical attributes, or sexual preference is prohibited and can result in disciplinary action that may lead to employment termination.

Q: CAN I DOWNLOAD INTERNET SOFTWARE USING MY COMPANY-ISSUED COMPUTER?

A: Accessing the Internet creates the possibility of viruses, malware, or spyware being introduced to our system, which can lead to breaches in the security of a confidential, company, and patient information, as well as the disruption of network performance that can result in system failures. Any software utilized by an employee on his or her company-owned equipment must be authorized by a supervisor and downloaded or installed by the IT department staff rather than by employees or contractors. Company information should not be routinely maintained on personal devices unless special circumstances apply, and advanced approval is received from your manager/supervisor.

4. Confidential Business Information:

One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral classifies Confidential Information as information that is not publicly available and includes, but is not limited to, research and development projects, trade secrets, business plans, manufacturing formulas and processes, supplier or customer contract terms, pricing, sales figures, bids, quotes, pricing proposals, responses to tenders, and non-public financial results, or any other information that might be of use to One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s competitors or harmful to One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral if disclosed.

One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral has access to information about patient’s medical conditions, history, medications, and family illnesses. We realize the sensitive nature of this information and are committed to maintaining its confidentiality. Each of us must be vigilant to safeguard confidential information and prevent unauthorized disclosure or use.

Confidential information should not be shared with anyone including competitors. Each employee must protect the company’s proprietary information during and after employment, this includes maintaining the confidentiality owed to previous employers’ information.

To prevent inadvertent disclosure of Confidential Information, best practices, include but are not limited to:

  • Adopt a “clean desk” habit by securing confidential protected health information (PHI)
    • In locked offices, desks, or file cabinets when not in use and at the end of each business day
    • Cover PHI in plain view when away from your desk
  • Practice a “clean screen” standard by locking your workstation computer when stepping away from your desk and at the end of each business day
  • Physically secure laptops and other computing equipment out of plain sight when not in use
  • Carry and secure the minimum necessary when physically transporting patient records
  • Confidential information must be physically destroyed beyond the ability to recover the same when no longer needed for legal, regulatory, or business reasons

We must respect the privacy of those who entrust their personal information from unauthorized disclosure and use. When we collect personal information during our routine business functions, we must obtain consent and/or appropriate authorization and inform the persons how their information will be used. We cannot sell personal information or obtain personal information from sources that we do not have authorization.

5. Privacy and Information Security:

The Privacy Officer works closely with IT to address the Health Insurance Portability and Accountability Act (HIPAA) and other privacy and information security requirements. Questions on how to safeguard personal information (PI) and protected health information (PHI) should be directed to the Privacy Officer and IT Departments. Analysis of HIPAA and related regulatory privacy and security risks is an ongoing process. The Office of Compliance responds to privacy complaints and investigates potential breaches of PHI and other sensitive information. Guidance is provided for handling the release of medical information, record subpoenas, and observing record retention requirements including appropriate means of record destruction.

One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral requires all workforce members to understand the risks, and safeguard privacy and security of individually identifiable information of the patients we provide services for pursuant to, among others, the:

Health
Insurance
Portability and
Accountability
Act

a. Personal Information (PI)

Although HIPAA focuses on PHI, we should also be always mindful to protect personal information that can be identifiable to a person, as such data may also be protected under other laws. PI is thus broader than PHI and its definition will vary among state jurisdictions.

b. Protected Health Information (PHI)

PHI is individually identifiable information created, received, or maintained by or on behalf of a covered healthcare provider or other HIPAA-covered entity and regarding any business associate. PHI comprises individually identifiable information (written or oral) that relates to:

  1. An individual’s past, present, or future physical or mental health condition; or
  2. The provision of healthcare to an individual; or
  3. Past, present, or future payment for the provision of healthcare to the individual

PHI is protected under federal and state privacy and security laws. Only health information linked to the specified individual by an identifier is protected health information.

Each employee is expected to:

  • Recognize PHI and PI that requires protection
  • Determine when it is permissible to access, use or disclose PHI
  • Reduce the risk of impermissible access to, use, or disclosure of PHI

Q: WHEN IS IT PERMISSIBLE TO ACCESS OR USE PHI?

  • Does the law allow me to access PHI? 
  • Do I need to know the information to do my job?
  • What is the minimum amount of information necessary to accomplish the task?

Q: WHAT SHOULD I DO IF I EMAILED PHI TO THE WRONG PERSON?

A: If any information that contains patient names and other patient identifiers, such as date of birth, social security number, etc. has been compromised in any way, you must contact the Office of Compliance immediately to report the incident.

Q: WHAT SHOULD I DO IF I SEE AN EMAIL STRING OR TEXT MESSAGE CONTAINING PHI GOING OUT TO PEOPLE WHO ARE UNAUTHORIZED TO RECEIVE IT?

A: Remove the PHI and send the message back informing the offending sender(s) about the error. If PHI was shared with anyone unauthorized including an outside party, the Office of Compliance should be notified immediately.

Q: IF I GENERATE A ROUTINE REPORT THAT CONTAINS PERSONAL AND PROTECTED HEALTH INFORMATION INCLUDING PATIENT NAMES AND SOCIAL SECURITY NUMBERS, HOW SHOULD I DISCARD THE REPORT?

A: Unless management has instructed you to retain all documents (paper and electronic), for example, as required by a government, internal investigation, or litigation, the document(s) should be retained or discarded per One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s document retention policies. Confidential and sensitive documents should be properly shredded or destroyed such that the information contained in the report cannot be reconstructed. Contact the Privacy Officer if you have any questions regarding these policies.

6. Compliance with Laws:

Every One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral employee is expected to adhere to all laws and policies, procedures, principles, and standards, including this Code. This is a fundamental expectation and condition of employment. One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s policies and procedures cover topics related to important aspects of our operations, including healthcare compliance, quality, finance, purchasing, human resources, and information systems. These policies are in place to help ensure that we comply with the many laws and regulations governing our business. Such policies and procedures enable us to detect, correct and prevent non-compliant activities.

a. Accurate Books and Records

We must measure our business activities accurately through our financial books, internal records and documentation, and public statements. When gauging or describing our successes, failures, and routine operations, the facts must be presented in sufficient context and with adequate support to understand the true nature of our activities and/or transactions. Our financial records must conform to applicable accounting standards, laws, regulations, as well as One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s policies, procedures, and controls.

For example, when reporting information related to pricing or payments and items of value provided to physicians and other customers, the data must be complete and accurate. There are strict laws regarding price reporting and reporting of certain payments to healthcare professionals. These laws help protect taxpayers, who ultimately pay for some of or all the purchases within the healthcare system. One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral is committed to ensuring accurate information is evident to allow governments and insurers to make informed decisions.

Q: WHAT SHOULD I DO IF I BECOME AWARE OF A FINANCIAL IRREGULARITY?

A: One should report any financial irregularity to the Finance Department or the Office of Compliance so that the concern can be reviewed.

b. Document Retention

Every employee is responsible for the integrity and accuracy of the organization’s documents and records. This is required not only to comply with regulatory and legal requirements, but also to ensure records are available to support the business practices and actions, and for client and patient access upon request. Any corrections to documents and/or records must include the notation ‘late entry correction’ with the employee’s initials/date and a single line strikethrough through the error. Backdating documentation is not acceptable. Therefore, One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral maintains, retains, and stores accurate medical records and business documents consistently and reliably and per the law.

Medical and business records include paper documents such as letters and memos, computer-based information such as email or computer files on disk or tape, and any other medium that contains information about the company or its business activities.

Under no circumstances may a One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral employee:

  • Alter or falsify information on any record, document, or any business information, e.g., timecard, patient record 
  • Destroy any record or document to deny governmental authorities any information that may be relevant to a government investigation
  • Destroy any records germane to any civil matter to deny a relevant third person or entity the right to the requested information
  • Remove or destroy records before a specified date without first obtaining permission as outlined in the company records management policy
  • Use information of a patient, colleague, or any other individual or entity information to personally benefit themselves (e.g., perpetrate identity theft)

It is important to retain and destroy records only in accordance with the company policy. If you believe or know any sort of improper or unauthorized access, use, or disclosure of any protected health information or personal information has been made, immediately contact the Office of Compliance.

c. Maintaining Eligibility to Participate in Government Healthcare Benefit Programs

One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral will not knowingly employ or contract with any individual or business that is on exclusion lists as debarred, suspended, or otherwise ineligible to participate in the company’s business endeavors. We routinely search the Department of Health and Human Services’ Office of Inspector General, General Services Administration’s lists of such excluded and ineligible persons.

Employees, independent contractors, clients, vendors, and practitioners (among others, any of which are associated with One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral) are required to report to One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral if they become excluded, debarred, or otherwise ineligible to participate in federal healthcare programs or have been convicted of a criminal offense related to the provision of healthcare items or services.

d. Cooperating with Government Surveys and Investigation

Periodically, government agencies and other entities conduct surveys in our facilities and those of our clients. We respond with openness and accurate information. In preparation for, or during a survey or inspection, One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral employees must never conceal, destroy, or alter any relevant documents. Employees must also never lie or make misleading statements to anyone. Also, employees must never attempt to cause another One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral employee to fail in providing accurate information or obstruct, mislead, or delay the communication of information or records relating to a possible violation of the law.

Refer to the One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral policy, Cooperation with Search Warrants, Subpoenas, and Government Investigations, maintained by the Office of Compliance. If a government investigator, agent, or auditor arrives unannounced for a non-routine visit, directly notify your department manager, and immediately contact the Office of Compliance.

7. Fraud, Waste, and Abuse:

The Office of Compliance oversees the performance of data analysis to monitor the integrity of claim submissions and reimbursement and to evaluate other areas of regulatory scrutiny. The Office of Compliance conducts periodic inspections and reviews related to high-risk compliance issues. The Compliance staff will investigate potential fraud, waste, and abuse concerns and any employee misconduct; and will seek collaboration with other departments and subject matter experts as needed.

TEXAS BEHAVIORAL HEALTH HAS ZERO TOLERANCE FOR ANY ACTIVITY THAT CONSTITUTES FRAUD, WASTE, OR ABUSE.

Fraud is knowingly and willfully executing or attempting to execute, a scheme or artifice to defraud any healthcare benefit program to obtain any money or property owned by the healthcare benefit program or under its custody or control.

Fraud includes, but is not limited to:

  • Filing fictitious claims (e.g., medical claims)
  • Using billing codes that reflect a more severe injury than truly existed or a more expensive service/product than was provided (“up-coding”)
  • Knowingly soliciting, paying, and/or accepting remuneration to induce or reward referrals for items or services reimbursed by a government healthcare program

Waste is the overutilization of services or other practices that, directly or indirectly result in unnecessary costs to the healthcare system. Generally, waste is not caused by criminally negligent actions but rather, by the misuse of resources.

Abuse is any action that may, directly or indirectly, result in: (i) unnecessary costs to the healthcare system, or (ii) improper payments for (a) services, (b) services that fail to meet professionally recognized standards of care, or (c) services that are medically unnecessary.

Abuse includes, but is not limited to:

  • Charging in excess for services or supplies
  • Providing and billing for uncovered services
  • Billing for items or services that should not be paid for by Medicare or other governmental payers

There exist are a variety of state and federal laws and regulations related to fraud, waste, and abuse, including:

a. Prohibitions against False and Fraudulent Claims

Federal law and many state laws contain specific prohibitions against the submission of false or fraudulent claims and provide for the imposition of civil, criminal, and administrative penalties.

False Claims Act is a federal statute that imposes liability on any individual who knowingly, recklessly, or with deliberate ignorance:

  • Submits or causes someone else to submit to the government a false or fraudulent claim for approval or payment
  • Makes, uses, or causes someone else to use a false record or statement to get a claim paid or approved by the government
  • Has possession or control of the government’s money or property and delivers or causes someone else to deliver less than all the government’s money or property
  • Makes a false record or statement related to an obligation to pay the government or conceals, avoids, or decreases an obligation to pay or transmit money or property to the government
  • Conspires to do any of the above

b. Anti-Kickback Laws

Federal and State Anti-Kickback law prohibits persons or entities from knowingly and willfully soliciting, receiving, offering, or paying remuneration (including any kickback, bribe, or rebate) for referrals for goods or services that are paid in whole or in part under a government healthcare program.

Refer to the section on Inducements in this Code for restriction and guidelines regarding gifts that may potentially be perceived as improper remuneration.

A claim submitted for payment that arises from violations of anti-kickback laws can also constitute a false claim. Anti-Kickback laws have safe harbors that must be strictly followed to offer protection from prosecution.

c. Anti-Inducement Statute of the Civil Monetary Penalties Law

The Anti-Inducement Statute prohibits anyone from offering or giving remuneration to a Medicare or Medicaid beneficiary that is likely to influence the beneficiary to choose a particular provider for items or services covered under Medicare or Medicaid.

d. Stark Law

This federal statute prohibits a physician from making any referral for certain designated health services (“DHS”) to an entity in which the physician (or a member of his/her family) has an ownership/investment interest or with which he or she has a compensation arrangement. The government has carved out specific exceptions to this prohibition. These exceptions must be strictly followed. Like anti-kickback laws, claims submitted for payment that arises from violations of the Stark Law can also constitute a false claim.

Government and One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral penalties for failing to comply with fraud, waste, and abuse laws may include one or more of the following:

  • Disciplinary action up to, and including, termination where appropriate
  • Criminal convictions/fines (individually and at the company level)
  • Civil monetary penalties
  • Loss of licensure/sanctions
  • Exclusion from participating in federal healthcare programs

8. Inducements:

Patients and consumers should be able to rely on the independent judgments of their healthcare professionals without concern those judgments have been improperly influenced by incentives from companies seeking to promote their products or services.  In our Marketing and Business Development activities, we educate and inform affiliated healthcare professionals, but do not interfere with their independent and professional judgment.

It is never permissible for any One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral employee to:

  • Offer or provide services or products that directly or indirectly benefit a healthcare professional such as a physician, nurse, researcher, facility staff, a government official, or any other person to make, among others, a sale or secure business or a business advantage for One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral
  • To provide anything of value as a “reward” for any past or existing relationship with One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral

Everyone at One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral must proactively manage relationships with service providers (such as distributors, consultants, speakers, or promoters) to ensure services performed on One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s behalf are carried out in accordance with the company’s expectations and in compliance with applicable laws and regulations. Each facility and employee must use due diligence when selecting service providers, paying fair market value for services, and accurately document payments for services, fines, and fees.

a. Gifts, Meals, and Entertainment

The giving and receiving of gifts, meals, and entertainment are a natural part of doing business. However, there is a fine line that should not be crossed; yet it is sometimes not easy to identify. For instance, giving a prospective client or referral source a weeklong vacation to a tropical island is an obvious violation, but other types of hospitality, gifts, and entertainment payments can also run afoul of federal laws without employees realizing that they have committed a violation. Expenses cross the threshold of potential corruption if they exceed normal and socially acceptable levels.

Because anti-corruption principles require that we never offer or provide anything that directly or indirectly benefits any person to secure a business advantage, we set reasonable limits surrounding gifts, meals, and entertainment.

One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s policies and procedures related to limits on and reporting of brand reminders, gifts, cultural courtesies, meals, and hospitality are in place to help ensure employees do not provide any benefit that could interfere with professional judgment. Refer to the Improper Payments and Gifts Policy.

We do not seek, accept, offer, promise, or give (directly or indirectly) anything of value including payments, fees, loans, services, entertainment, favors, or gifts from or to any person or firm as a condition or result of doing business with One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral. Gifts in money or cash equivalent in any amount are always prohibited.

The occasional exchange of favors, gifts, or entertainment of nominal value with employees of other organizations is appropriate unless the recipient’s employer forbids the practice. Remember, any courtesy you extend should always comply with the policies of the recipient’s organization, and those we are doing business with should understand our policy as well.

b. One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral Employees, Material contractors and subcontractors

The Company and management may provide a gift reward or recognition (e.g., a gift card) to an employee or contractor. Gifts provided by One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral to employees or contractors are considered taxable income and must be reported as such. Contact Payroll for guidance.

c. Vendors, Suppliers, Brokers, Agents

One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral employees may accept occasional, unsolicited, and reasonable business meals or entertainment (such as tickets to sporting events) from an actual or prospective supplier of goods and services, agents, brokers, or other third parties (collectively “vendors”) if the following requirements are met:

  • The vendor or prospective vendor providing the meals or entertainment attends the event with the One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral employee
  • The value of the meal or entertainment is modest as judged by local standards
  • The venue is conducive to informational communication and includes or is contiguous to legitimate business discussions

Travel or lodging in connection with a meal or entertainment sponsored by a vendor or prospective vendor is not permitted. The expenses for business meals and entertainment for the employee’s spouse, partner, significant other, or any other guest of the employee is similarly not allowed.

d. Government Officials and Agencies

Stricter and more specific rules apply when business is conducted with governmental entities, employees, officials, and representatives, as well as related public sector entities, which include government-owned organizations (such as public universities or hospitals). Government employees are often prohibited from accepting anything of value and violating their laws and rules can be of serious offense for both the giver and receiver of a prohibited gift.

One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral does not provide any gifts, entertainment, meals, or anything else of value to any government employee, except for minor refreshments in connection with business discussions or promotional items with the One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral logo of nominal value.

e. Potential Referral Sources

When interacting with the medical community, One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral is committed to following the highest ethical standards and complying with applicable laws. Any entertainment, gift, or token of appreciation involving physicians or other persons who can refer patients to a One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral client must be in accordance with all laws and regulations.

Laws governing commercial products and services, and limits on gifts and promotional items, vary by state.

Contact the Office of Compliance for guidance before extending any business courtesy or token of appreciation to a current or potential client referral source.

f. Sales, Promotional, and Other Business Meetings

One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral employees may conduct sales, promotional, and other business meetings with healthcare professionals to discuss company services, products, features, sales terms, or contracts.

  • Appropriate to pay for reasonable travel costs of attendees when necessary (e.g., facility tours or demonstrations of equipment or service products) and/or to provide occasional modest meals and refreshments in connection with such meetings
  • Not appropriate to pay for meals, refreshments, travel, or lodging of guests of healthcare professionals or any other person who does not have a bona fide professional interest in the information being shared at the meeting

A company’s business interactions with healthcare professionals may involve the presentation of scientific, educational, or business information. Such exchanges may be productive and efficient when conducted in conjunction with meals. Accordingly, modest meals may be provided as an occasional business courtesy.

The following guidelines are to be considered with respect to provisions of meals:

  • Purpose: The meal should be incidental to the bona fide presentation of scientific, educational, or business information and provided in a manner conducive to the presentation of such information. The meal should not be part of an entertainment or recreational event.
  • Setting and Location: Meals should be in a setting that is conducive to bona fide scientific, educational, or business discussions.  Meals may occur at the healthcare professional’s place of business.  However, in some cases, the place of business may be a patient care setting that is not available for, or conducive to, such scientific, educational, or business discussions.  In other cases, it may be impractical or inappropriate to provide meals at the healthcare professional’s place of business when it is necessary to discuss confidential service or product development or improvement information, or where a private space cannot be obtained on-site.
  • Participants: One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral will only provide a meal to healthcare professionals who attend a relevant meeting. Meals for an entire office staff where everyone does not attend the meeting are not acceptable. Also, meals for guests of healthcare professionals or for any other person who does not have a bona fide professional interest in the information being shared at the meeting are prohibited.

g. Patients including Medicare or Medicaid Beneficiaries

Gifts or courtesies to governmental patients generally must not exceed $10 per item nor a total more than $50 per year per recipient. There are other circumstances and factors that require additional evaluation, such as subsidized transportation, gift cards, and other incentives to promote the delivery of certain preventative care services. Contact the Office of Compliance for assessing these situations.

Q: CAN I ACCEPT A GIFT FROM A SUPPLIER?

A: This depends on the nature of the gift and its value. If the value of the gift received is expensive or not considered modest, you should not accept the gift. The employee must return the gift to the supplier explaining that the company’s policy does not permit employees to receive expensive gifts. However, if the amount of the gift is modest and considered reasonable, the employee may accept the gift. If the nature of the gift permits, the best approach is to share it with the employees of the department. In both cases, transparency is the key element in such circumstances, therefore, you should notify your manager/supervisor and if you have further questions, you should contact the Office of Compliance.

Q: WHAT SHOULD I DO IF I RECEIVE A GIFT THAT I KNOW IS INAPPROPRIATE?

A: Return the gift to the supplier with a polite explanation that One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s policy prohibits you from accepting the generosity. In some circumstances, other alternatives may be considered, such as displaying the gift in a public area or donating it to a charitable organization. Check with your manager/supervisor or the Office of Compliance for guidance.

Q: CAN I TAKE ADVANTAGE OF AN OFFERED DISCOUNT ON A PRODUCT SOLD BY A One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral SUPPLIER?

A: An employee may accept the discount only if it is available to all One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral employees and approved by the company. A discount offered personally to an employee would be inappropriate.

h. Expense Reimbursement

One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral will reimburse associates for pre-approved, reasonable, and necessary business expenses incurred while traveling on authorized company business or incurred in connection with an authorized company business purpose. Bonafide business expenses are acceptable. These include legitimate expenses during the normal course of business. These expenses must be within reason and on par with general practices and local customs.

For details related to approved travel expenses, and information on submitting expense reports, refer to the 4.1 Business Expense Policy of the Employee Handbook.

If you are aware of any inappropriate expenditures or conduct unbecoming of occurred expenses that are being allocated, gifted, swapped, charged, invoiced, or billed directly to One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral and/or its affiliates, we encourage you to report these instances to the Office of Compliance.

Q: CAN WE PROVIDE A CATERED LUNCH DURING A MEETING WITH A MAJOR One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral CUSTOMER OR A VENDOR?

A: It is acceptable to provide lunch if offered in the spirit of our gift-giving policy and complies with the monetary guidelines for what is considered “acceptable.”

Q: CAN I TAKE A HEALTHCARE PROFESSIONAL OUT FOR A BUSINESS MEAL?

A: Generally, it is permissible to take a healthcare professional for a business meal. Always check with your supervisor or the Office of Compliance for requirements and monetary limits.

Q: IS IT PERMISSIBLE FOR ME TO ACCEPT A VENDOR’S LUNCH OFFER OR SOCIAL OUTING INVITATION?

A: An employee should decline even the smallest of gifts. If declining would be perceived as impolite and may cause harm to a business relationship, the employee may accept the gift, however, should report the same.

Q: MAY I ACCEPT EXPENSE REIMBURSEMENTS IF I SPEAK TO A GROUP OR AT A PROFESSIONAL MEETING?

A: The employee should obtain pre-approval from their manager/supervisor for related engagement expenses. One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral policy requires that all suppliers be treated fairly and impartially. Therefore, do not accept anything from a supplier that could suggest even the appearance of favoritism. Normally, it is inappropriate to accept payment of expenses by vendors to speak to user and customer conferences. On the other hand, you can usually accept reimbursement for expenses from associations and professional groups because they are not vendors and would not be using the speaking invitation to gain favorable treatment.

RESOURCES

1. Contact Information:

  • Manager/Supervisor – The best place to start if you have questions on how our Code of Business Conduct applies to you is with your immediate manager or supervisor.
  • Office of Compliance – The Office of Compliance is a corporate resource available to address your questions or concerns about our Company’s values and standards of conduct.
    • By emailing: compliance@texasbehavioral.com. For a customer support issues, please email us on contact@texasbehavioral.com. Please refrain from entering PHI on any emails.
    • By calling the Compliance Hotline : 1-281-727-0039. Callers can choose be anonymous by dialing *67 before the number and without leaving contact information.
    • By calling the Chief Compliance Officer 713-429-5325 Ext 174
    • Use the anonymous contact form on the employee portal using the
    following link: https://onebehavioralhealth.com/employee-portal/

2. Other Resources:

Policies and Procedures – Refer to One Behavioral Management, LLC and Texas Behavioral Health, PLLC dba One Behavioral’s corporate policies and procedures

Employee-related concerns – Contact Human Resources for concerns involving management and/or other employees

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