Non-Retaliation Policy

SUD Specialty Group -- CA; Mental Health Specialty Group, P.A.; Mental Health Specialty Group NJ, PC; and Mental Health Specialty Group KS, P.A. (collectively, the "Group") contracts with Path CCM, Inc. d/b/a Rula Health ("Rula") for management and administrative support services. This policy applies to the Group and Rula.

Policy Statement

This policy establishes that non-retaliation is an expectation for all team members that covers those who report in good faith, report suspected instances of non-compliance, inappropriate conduct or activities.  

Applicability:

This policy applies to all team members. For purposes of this policy, the Group’s and Rula’s team members include individuals who would be considered part of the workforce such as employees, independent contractors, business team members, and other persons whose work performance is under the direct purview of Rula or the Group’s  business practices. 

Definitions

In good faith: The individual reasonably believes or perceives the information reported to be true. 

Policy

1. There is a commitment to the establishment of a culture that promotes the prevention, detection and resolution of instances of conduct that do not conform to law, regulation, policy, procedure, or the Code of Conduct. To encourage the development and maintenance of this culture, a strict non-retaliation policy has been established to protect from retaliation individuals who in good faith report known or suspected inappropriate conduct or non-compliant activities.
   1. Team members have the responsibility to report, in good faith, concerns regarding actual, potential or perceived wrongdoing.
   2. It is understood that team members and others may not report compliance concerns if they feel that that will be subject to retaliation or retribution for reporting the concern.
   3. This policy establishes that timely disclosure of compliance concerns and prohibits any action directed against a team member or other party for making a good faith report of a concern.
   4. Retaliation for good faith reporting of perceived or suspected violations of law, regulation, policy or procedure and the Code of Conduct, or for participation in an investigation of an alleged violation is strictly prohibited. Any team member who commits or condones any form of retaliation, retribution or harassment against a reporting person shall be subject to appropriate discipline up to and including termination in accordance with applicable civil service rules.
   5. Individuals cannot exempt themselves from the consequences of their own misconduct by self-reporting, although self-reporting may be taken into account in determining the appropriate course of action.
   6. Any person who intentionally provides false information may be subject to disciplinary action up to and including termination.
2. Leadership Responsibilities
   1. Support and encourage team members and contractors to report concerns as soon as possible.
   2. Ensure team members and contractors are aware they can report concerns directly to the Compliance Officer and that they are not required to first report to their supervisor. 
   3. If a team member reports a concern, report the concern immediately to the Compliance Officer
   4. Handle all reported concerns with the strictest confidentiality possible. 

3. Compliance Officer Responsibilities
   1. Develop and maintain a system to document and track reported instances of retaliation
   2. Fully investigate and resolve reports of retaliation

Attachments: None