Section 1: Professional Conduct
1.0 Our Door is Always Open
The Company has an “open-door policy” which means that employees are invited to voice their concerns and ideas, which will be taken seriously. The Company values each employee and strives to provide a positive, comfortable work environment and experience.
Employees are encouraged to bring any workplace concerns or problems that they might have or know about to their direct supervisor or any member of the leadership team with whom they feel comfortable. Leaders will respond in a timely manner to all employee concerns and problems.
1.1 Professional Conduct
Successful teams are a result of combined effort and collaboration. The way that employees treat one another, clients, and the public plays a critical role in our success.
Each employee has an obligation to observe and follow the Company's policies and to maintain proper standards of conduct at all times. Failure to adhere to the Company's policies may result in disciplinary action, which may include a verbal warning, written warning, suspension with or without pay, and/or termination. Appropriate disciplinary action taken will be determined by the Company on a case-by-case basis and careful review of each unique situation. The Company does not guarantee that one form of action will necessarily precede another.
The following may result in disciplinary action, up to and including termination (this is not an all-inclusive listing and is simply meant to serve as a general guideline for decision-making):
Violation of the Company's policies or safety rules
Failure to work in a cooperative manner with leadership, co-workers, clients, and others who do business with the Company
Reckless or willful damage to company property or to the property of coworkers, customers, or any other person
Use of abusive or threatening language or gestures
Wearing clothing that is abusive, threatening, discriminatory, violent, or otherwise not respectful / in line with the values of the Company.
Unauthorized or illegal possession, use, or sale of alcohol or controlled substances on work premises or during working hours, while engaged in Company activities, or in Company vehicles
Unauthorized possession, use, or sale of weapons, firearms, or explosives on work premises
Theft of Company property or information
Inappropriate or violent physical contact
Harassment, discrimination, or retaliation in violation of company policies
Performing outside work while using Company property, equipment, or facilities or while on Company time
Poor attendance or poor performance
Falsifying employment applications, other employment records, or any other Company document, including, but not limited to licensure documents, client information or records, accounting forms, and personnel records
Failing to maintain the confidentiality of client information
Nothing in this policy is designed to limit an employee's rights under Section 7 of the National Labor Relations Act. Employees have a right to express concerns about the workplace, including concerns about the conduct of others.
1.2 Dress Code
The River Rock Behavioral Health dress code policy is designed to help us all provide a consistent professional appearance to our clients and colleagues, while still maintaining a sense of individuality and autonomy for each of us. The ultimate goal is to be sure that all employees are comfortable and able to feel safe in their work environment. Because River Rock is ever-evolving, please consider this policy part of an ongoing conversation about how to best support employees and clients. The dress code specifically applies to administrative staff, as well as therapists on days when they will be seeing clients in the office.
Employees are allowed and encouraged to dress in casual attire which includes jeans and athleisure wear and excludes shorts, unless the day’s tasks require otherwise.
Employees are expected to present a clean, professional appearance. This includes wearing clean clothing, free of tears or other obvious signs of wear.
Clothing with offensive or inappropriate designs or stamps are not permitted nor tolerated.
Clothing and grooming styles dictated by religion or ethnicity are exempt and should be discussed with the company owner.
Therapists providing telehealth services are expected to be mindful of their appearance and surroundings when providing services. This includes maintaining a clean, confidential, and appropriate setting for telehealth services and maintaining appropriate visible apparel.
1.3 Client Service
Our goal is to create a safe and welcoming environment for all. We are a group practice known for genuinely caring about others and their well-being. Promptly assisting all clients, potential clients, the public, visitors, and co-workers in a courteous, friendly, and helpful manner must be every employee’s first priority.
Handling Complaints
From time to time, clients, visitors, co-workers, or others may wish to discuss problems or difficulties with the Company. The following steps outline the general procedures that employees should follow to resolve problems:
Listen attentively to the concern.
Empathize with the other person.
Express genuine concern for the patient’s complaint. When they feel you are sincere, you are in a much better position to settle the complaint.
Express appreciation. Thank them for bringing the concerns and complaints to your attention.
Take action. When possible, employees should find and implement an immediate solution to the problem. This action may include contacting a supervisor or other member of leadership.
Get the facts. Write them down using the prescribed patient contact, incident, or problem-solving form. Make sure to ask the following in any complaint situation, where applicable:
Name
Address
Home and work phone number
Other pertinent information regarding the complaint
Conflict Management
If a client, visitor, co-worker, or any other person becomes confrontational, employees must continue to conduct themselves in a professional manner. If an employee is unable to quickly resolve an issue or feels threatened by another person, the employee should immediately enlist the help of their supervisor or another member of the leadership team. However, if an employee feels that they are in danger, they should contact the proper authorities and immediately take whatever action they deem appropriate to keep themselves and others safe.
Employees should not engage in verbal and/or physical disputes or arguments with any other person. If a verbal or physical dispute should arise, disciplinary action up to and including termination may result. All complaints, including complaints of alleged discrimination or harassment should be reported immediately to your supervisor or another member of the leadership team.
Client Policies and Procedures
Your ongoing relationship with each of your clients is important, and is yours to maintain. There are times when policies are put into place in order to protect both the relationship as well as maintain important boundaries with clients.
Late Cancellation Policy
The official cancellation policy of River Rock Behavioral Health is that clients are expected to contact the office to cancel no less than 24 hours prior to their scheduled appointment. If notice is received less than 24 hours in advance but still prior to the appointment time, there is a $50 late cancellation fee that applies. In the event that a client does not show up and does not contact the office before the scheduled start of their appointment, the fee increases to the full reimbursement rate for their insurance / the full out of pocket fee. Similarly, any client who is more than 15-minutes late for their appointment is also subject to the full reimbursement rate or full out of pocket fee for the appointment. River Rock understands and expects that there may be scenarios in which clients are unable to contact the office in advance (or at all), and that some exceptions would need to be made. Any exceptions to the late cancellation policy should be discussed and approved with the Company owner prior to discussing them with the client.
Standard exceptions to the late cancellation fee policy are included here, and in these limited cases, an exception does not need to be discussed in advance with the Company owner.
If inclement weather results in the cancellation of school in the zip code of River Rock Behavioral Health and/or the zip code of the client, and such inclement weather renders it impossible for a client to attend therapy services due to traffic conditions, loss or ongoing lack of access to telehealth technology, or loss of childcare, the the late cancellation fee is waived.
If there is a documented emergency, such as a client or close family member requiring emergency care or the unexpected loss of a family member, the late cancellation fee may be waived. Policy is to apply the late cancellation fee and request the client provide documentation. Once documentation is received, the late cancellation fee can be removed from the client’s account. If a client is unable to provide documentation, please discuss with the owner to request approval for the fee to be waived without documentation.
1.4 Officials and Visitors
Visitors to our business locations should be greeted professionally, and an inquiry made as to what type of assistance the Company may provide them.
Procedure for Greeting Officials and Visitors:
Professionally inquire as to the nature of their visit.
Never answer questions to which you do not know the answer. Instead, tell the visitor that you will get them any information they need and will forward it to them.
Any request to speak to the owner should be forwarded to Dr. Harvath as soon as possible.
1.5 Whistleblower Policy
The Company does not permit retaliation of any kind against employees who: report possible misconduct, raise a concern regarding a violation of company policy, regulation, or applicable law, who participate in an investigation, or otherwise engage in legally protected activity. Anyone who retaliates against an employee engaged in raising a concern will be subject to disciplinary action, up to and including termination of employment.
Any employee who feels that they have been subject to retaliation should immediately contact their supervisor or another member of the leadership team. Any leadership team member who receives such a report must immediately report it to their supervisor or a senior member of the leadership team with whom they are comfortable.
1.6 HIPAA Expectations
All employees of the Company are expected to understand and follow HIPAA rules within the scope of their practice. Employees are required to take a HIPAA training in order to familiarize themselves with HIPAA and Privacy and Security. All staff are required to complete a HIPAA training every two years.
Employees will adhere to HIPAA standards regarding the use and disclosure of protected health information of current and former clients. In addition, employees will take the necessary precautions in using technology that is HIPAA compliant. Employees may not use their company email to communicate directly with clients. Rather, all clients will be instructed to contact info@riverrockbehavioralhealth.com to communicate about scheduling or billing. Employees will make client calls privately.
All staff must abide by HIPAA when it comes to using their personal electronics (computers, iPads, phones, etc.) to access PHI. All electronics used for work purposes must be password protected. Staff must use secure Wi-Fi when accessing PHI (i.e., TherapyNotes). Furthermore, staff must maintain clients’ privacy when accessing their PHI (i.e., working from home around others in the home). Additionally, all staff must delete any PHI that is downloaded onto their electronics immediately (i.e., downloading a client’s statement or files). Staff’s personal electronics may not contain client PHI. Lastly, staff must not use auto log in features on their electronics as it violates HIPAA. Any files containing clients’ PHI must be shredded and not stored in desks, mailboxes or any other non-secure space. Please upload all client files into TherapyNotes, or give them to the Office Manager to be uploaded and shredded. Additionally, please do not take physical client files home, as it is a HIPAA violation.
1.7 Protecting Private & Sensitive Information
Data breaches and identity theft pose a risk to the Company, its employees and customers. These are of significant concern to the Company and can only be reduced through the combined efforts of every employee and contractor working for the Company.
This privacy policy enables the team to protect clients and employees, reducing risk from identity fraud and minimizing potential damage to the Company from fraudulent activity. Please note that this policy is supplemental to the HIPAA-related policy found in this Handbook.
The goals of this Policy are to:
Identify risks that signify potentially fraudulent activity within new or existing covered accounts
Detect risks when they occur in covered accounts
Respond to risks to determine if fraudulent activity has occurred and act if fraud has been attempted or committed
Definition of Private & Sensitive Information
Sensitive information includes a variety of items whether stored in electronic or printed format. A non-exhaustive list of some of these items follows.
Credit Card Information
Credit Card Number (in part or whole)
Credit Card Expiration Date
Cardholder Name
Cardholder Address
Tax Identification Numbers
Social Security Number
Insurance Number
Business Identification Number
Employer Identification Numbers
Payroll information
Paychecks
Pay stubs
Pay rates
Medical Information for any Employees or Clients
Insurance claims
Prescriptions
Any related personal medical information
Doctors’ names and claims
Other Personal Information belonging to Clients, Employees, and Contractors
Date of Birth
Address
Phone Numbers
Maiden Name
Names
Customer Number
Corporate Information
Sensitive corporate information includes, but is not limited to: Company, employee, customer, vendor, and supplier confidential proprietary information or trade secrets. This includes psychological testing kits and forms.
Employees are encouraged to use common sense and good judgment in securing confidential information to the proper extent. If an employee is uncertain of the sensitivity of a particular piece of information, they should contact their supervisor.
Employees who have questions about this policy or related procedures should contact their supervisor or another member of the leadership team.
1.8 Employee Privacy
As required by law, and for business necessity, the Company collects and stores personal information of its employees. The confidentiality and privacy of employees and their information is of the utmost importance to the Company. As such, all employees and contractors are required to secure and protect employees’ personal, private, and protected information at all times.
If an employee’s personal, private, or protected information is disclosed to an unauthorized party, the employee may be notified in order to ensure understanding and in compliance with applicable local, state or federal laws.
