## 6. Operations: Policies, Procedures, and Compliance Iliana, now that you’ve set up your legal structure, secured licenses, and figured out where and how you’ll deliver services, you need the **operational backbone** to keep everything running smoothly and within legal/ethical bounds. This section covers your **day-to-day workflows, clinical/administrative guidelines, and the compliance frameworks** that protect your practice. --- ### 6.1 What “Operations” Means for an ABA Practice 1. **Day-to-Day Administration** - This includes scheduling sessions, tracking staff hours, processing payroll, handling client intake forms, and ensuring timely billing. - If you’re small, you might handle many of these tasks yourself or with minimal help. As you grow, you’ll want designated roles (office manager, billing specialist, etc.). 2. **Strategic Coordination** - Operations also means **overseeing how all moving parts fit together**: from staff supervision and data collection to client satisfaction and compliance requirements. - Think of operations as the **central nervous system** of your practice, ensuring everyone is aligned on procedures and goals. 3. **Adaptation for Different Models** - **Clinic-based**: Clear front-desk protocols, facility management, safety checks. - **Telehealth**: Secure video sessions, technology troubleshooting, HIPAA compliance for remote data. - **In-home**: Staff travel logistics, personal safety policies, on-the-go data collection. --- ### 6.2 Clinical Policies & Procedures 1. **Client Intake & Assessment** - Document how you handle new referrals, verify insurance, gather background info, and schedule initial assessments. - Include **assessment tools** (FBAs, VB-MAPP, ABLLS-R, or other standardized methods). 2. **Treatment Planning** - Outline how **BIPs (Behavior Intervention Plans)** or skill-acquisition programs are developed. Specify the **review frequency** (e.g., every 3 or 6 months). - Detail **data collection methods** (trial-by-trial, frequency, partial interval) and how staff should maintain consistency. 3. **Session Structure & Documentation** - Describe **session notes** (e.g., what to include, how to label them, when to submit). - Clarify the **roles** of BCBA vs. RBT during sessions, including who can modify protocols and who must follow them. 4. **Crisis or Emergency Procedures** - Spell out **de-escalation techniques**, crisis management steps, and the chain of command if a serious behavioral incident occurs. - For physical clinics, include **evacuation routes** and **emergency contact lists**. For telehealth, define a protocol if a child becomes unsafe or unresponsive on screen. --- ### 6.3 Administrative Procedures & Staff Guidelines 1. **Scheduling & Cancellations** - Decide if you’ll have **cancellation fees** or a 24-hour notice policy. Provide staff with **scripts** for handling no-shows. - If you use **online scheduling**, ensure staff know how to confirm appointments and handle waitlists. 2. **Billing & Collections** - Outline how claims are filed, who handles denials/appeals, and the timeline for submitting documentation. - If you have a billing specialist, define their responsibilities and who they report to. - **Telehealth vs. In-Person**: Some payers require place-of-service codes or modifiers. Document these in your billing SOP. 3. **Employee Handbooks** - **Clinical Staff**: May need guidelines on supervision hours (BCBA -> RBT), note-taking, ethical standards per BACB. - **Administrative Staff**: Focus on front-desk etiquette, data entry protocols, and HIPAA privacy rules. - For a small team, you might combine these into one **employee handbook** with sections for each role. 4. **Confidentiality & HIPAA Compliance** - Reference your HIPAA privacy policies (who can access records, how to handle PHI securely). - If you store or transfer data electronically, document **encryption methods** and authorized cloud services. --- ### 6.4 Compliance Considerations Beyond HIPAA 1. **OSHA (Occupational Safety and Health Administration)** - If you have a physical clinic, you’re responsible for workplace safety (e.g., slip hazards, fire safety, ergonomic considerations). - Even in-home models need staff safety policies for entering clients’ homes. 2. **State & Local Healthcare Regulations** - Some states require **incident reporting** to a government agency if a serious injury occurs. Others may require an annual facility inspection. - If you’re offering telehealth across state lines, confirm you meet each state’s regulations for remote service delivery. 3. **Risk Management & Incident Reporting** - Have a formal **incident report form** for injuries, property damage, or serious behavioral escalations. - A designated **compliance or risk officer** can review these incidents, identify patterns, and implement preventative changes. --- ### 6.5 Integrating Telehealth & In-Home Procedures 1. **Telehealth Policy Add-Ons** - Consent forms specific to telehealth (client acknowledges potential connectivity issues, privacy in the home environment). - Guidance on verifying client location each session (some states require you to confirm the client’s physical address each time for emergency services). 2. **In-Home Field Protocols** - Dress code (professional but practical for working with children), staff safety check (e.g., never enter a home if unsupervised minors are the only ones present). - Secure transport of materials (reinforcers, data sheets), ensuring no PHI is left in a personal vehicle. - Guidelines if the home environment is unsafe (e.g., severe aggression, hazardous living conditions). --- ### 6.6 Level of Detail & Maintaining Updated SOPs 1. **How Detailed?** - Enough that a new staff member could read them and **clearly understand** day-to-day expectations. Bullet points can work for simple processes, but ensure clarity and consistency. - Some processes (like crisis management) may require more narrative detail, step-by-step instructions. 2. **Version Control** - Policies evolve over time as you learn what works best and as rules change. Keep a **revision history** or a living document in a secure, shared drive. - Notify staff when policies update; have them sign off or acknowledge changes to ensure compliance. 3. **Ongoing Training & Audits** - Schedule **annual or semi-annual reviews** of your policies. This might involve staff feedback: _Are the procedures working in real scenarios?_ - Conduct random audits of session notes or billing processes to confirm staff follow the documented SOPs. --- ### Key Takeaways - **Operations** cover the **nuts and bolts** of running your practice: from daily scheduling to crisis response protocols. - **Administrative & Clinical Procedures** should be **distinct** but complementary, ensuring both the business side and therapeutic side run smoothly. - **Compliance** extends beyond HIPAA: consider OSHA, state health regs, risk management, and telehealth-specific rules if applicable. - **Level of Detail**: Enough that staff aren’t left guessing; keep everything updated as your practice evolves. - **Staff Engagement**: The best policies mean little if staff aren’t trained on them or if they sit unread in a binder. Actively integrate these procedures into orientation, supervision, and team meetings. Next, you’ll tackle **Section 7: Building Your Dream Team**—where we’ll cover how to recruit, hire, and onboard both clinical and administrative staff, plus set up effective training and supervision structures.