Code of Ethical Conduct

Dawn Farm Code of Ethical Conduct (Professional Responsibilities)

1. As a member of the Dawn Farm professional staff or member of its Board of Trustees, I will place the welfare of our clients and their families in matters affecting them above all other concerns.

2. To this end, I will deliver kind and humane treatment to all in my care regardless of race, creed, reproductive status, sex, disability, age, or sexual orientation.

3. I will not deliberately do harm to a client, either physically or psychologically. I will not verbally assault, ridicule, attempt to subjugate, or endanger a client, nor will I allow other clients or staff to do so.

4. I will urge changes in the lives of clients only in their behalf and in the interest of promoting recovery from the illness we are charged to treat. I will not otherwise press them to adopt beliefs and behaviors that reflect my value system rather than their own.

5. I will remain aware of my own skills and limitations. Since clients and former clients may perceive me as an authority and hence overvalue my opinions, I will attempt never to counsel or advise them on matters not within my area of expertise. I will be willing to recognize when it is in the best interest of my clients to release or refer them to another program or individual.

6. I will not engage in any activity that could be construed as exploitation of clients for personal gain, be it sexual, financial, or social.

7. I will not attempt to use my authority over a client in a coercive manner to meet my own ends. I will not promote dependence on me, but help clients to empower themselves.

8. I will not name or give information about a client, former client, or family member except to other Dawn Farm staff as required by treatment or when specifically authorized by the client.

9. I understand and agree to defend both the spirit and the letter of Dawn Farm policy on client rights and the client¹s bill of rights, and to respect the rights and views of other professionals.

10. As a caring and care giving person, I understand that a therapeutic relationship does not end with a person’s leaving Dawn Farm programs. I will recognize the need to conduct any subsequent relationships with former clients with the same concern for their well being that is acknowledged above. Sexual involvement with a former client exploits emotions deriving from treatment and is therefore almost always unethical.

11. In my personal use of alcohol and other mood altering drugs, I will serve as a responsible role model for clients, staff, and community. If I have been chemically dependent in the past, I will maintain total abstinence while employed at Dawn Farm.

12. I will exhibit responsible concern for the well being of my peers and the Dawn Farm community by not ignoring manifestations of illness or unethical conduct in colleagues.

13. I will accept responsibility for my continuing education and professional development as part of my commitment to providing quality care for those who seek my help.

Practical Considerations

Introduction

All staff members, board members, volunteers, and other individuals affiliated with Dawn Farm are expected to comply with the Code of Ethical Conduct to ensure that ethical decision-making and conduct are observed in all aspects of the organization’s business. This document should be reviewed in conjunction with relevant policies and procedures and should not be considered to be all inclusive.

Confidentiality

The confidentiality of persons receiving services at any Dawn Farm facility or program is protected by federal and state law. Information concerning clients and/or their treatment will not be revealed or released without the written consent of the client except in the following instances:

• There is a valid court order (42 CFR 2.61-2.67);

• There is evidence to support an allegation of child abuse (42 CFR 2.12c6);

• There is a medical emergency that necessitates disclosure (42 CFR 2.51); or

• There is a threat of direct harm or injury to a specific individual, or any credible threat to others (ARS36-517.02).

Client Rights

The rights of clients are absolute and are based on both law and the philosophy of respect for the fundamental worth of each individual. These rights include the following:

• Services are provided in a language the client understands;

• Clients receive a statement of their rights at time of intake;

• Clients are informed of their right to file a grievance without fear of reprisal;

• Clients participate in development of their treatment plan;

• Clients can refuse to participate in any research project or program;

• Clients receive services in the least restrictive environment possible;

• Clients in level I facilities are free from arbitrary use of seclusion/restraint; and

• Clients can refuse medication (except in cases of court order).

All clients are notified of their rights at time of intake. At that point clients are also made aware of their right to file a complaint or to appeal any decision that is made regarding treatment.

Gratuities/Influence

No employee, board member, volunteer, or other persons affiliated with Dawn Farm, will accept gifts of material value, favors, or remuneration for personal gain from any individual, client agency, corporation, or

program that does business with the organization. Additionally, no employee, board member, volunteer, or other persons affiliated with Dawn Farm will attempt to influence decisions of any funding source through donations of cash, promises of special consideration, or suggestions of any valuable contributions.

Staff Qualifications

Dawn Farm, policy requires that staff members have the requisite experience and education, as mandated by state regulations, for the position(s) they hold within the agency. The human resources office will ensure that staff members are appropriately licensed and certified. Designated professional staff will be required to complete the credentialing process.

Clinical staff members will be required to participate in required training and supervisory sessions, as defined by state regulations and continuing education requirements. Staff members who work with children or who provide services to other vulnerable populations may be required to comply with additional requirements.

Research

Any client who agrees to participate in any research project must understand the extent of his/her participation, including his/her ability to decline to participate. Clients who agree to participate must sign a consent form that has been approved by an Institutional Review Board. Any known or suspected research misconduct must be reported in accordance with federal law.

Charting/Documentation

All clinical staff members will receive training in proper documentation. Clinical charts are audited on a regular basis to ensure appropriateness of entries and to ensure completion of required documentation. Any client can review his/her chart, in accordance with HIPAA rules and regulations.

Governing Authority

Dawn Farm/Dawn, Inc. is governed by a volunteer Board of Trustees. Each Board member receives an orientation to organizational operations that includes review of policies on conflict of interest, ethics, political neutrality, lobbying, anti-kickback, and client advocacy.

Financial

Dawn Farm policy on investment of funds states that “any investment strategy or instrument must be congruent with the stated mission, vision, and values” of the Corporation.

Billing

Dawn Farm, will maintain audit trails to ensure that services billed reflect services provided. Services will be billed at contracted rates only, and where necessary appropriate codes will be used to accurately reflect not only services provided but also the credentials of the service provider. Any intentional misrepresentation of services provided and/or billed will result in disciplinary action.

Contracting

Dawn Farm occasionally subcontracts with service providers to ensure a full continuum of services for its clients. All individual practitioners must be licensed and/or certified to provide the services for which they are subcontracted and must complete privileging/credentialing requirements. Agencies must be appropriately licensed to provide those services for which they are contracted and must carry appropriate levels of professional and general liability insurance.

Marketing

Dawn Farm will provide only true and accurate information in all presentations and materials provided to the public and will in no way willfully mislead the recipients of such information.

Conflict of Interest

An employee, officer, or agent of Dawn Farm, is expected to disclose any business transactions or relationship that might be construed as a conflict of interest. Further, he/she shall not participate in any decision making that has the potential to benefit him/her (See Conflict of Interest statement).

Human Resources

Dawn Farm is an equal opportunity employer and does not discriminate in its hiring practices. Employee files are confidential, and access to them is limited to the individual and his/her supervisory personnel and any other persons who have obtained the employee’s consent. Other access is only as permitted by applicable law and regulation.

Conduct

At time of orientation, all employees read and sign policies related to ethical conduct, conditions of employment, sexual harassment, and drugs and alcohol in the workplace. Failure to adhere to these defined

standards of conduct will result in disciplinary action, which could include termination.

Risk Management

Staff members who observe other staff members behaving in an inappropriate or unprofessional manner in the course of their assigned duties should report such behavior to the appropriate supervisor. If the allegation can be proven immediately, the staff member will be disciplined through their supervisor and/or Human Resources. Any allegation that requires further investigation will be forwarded to the administrative team. In this case involved staff members will be placed on administrative leave with pay pending the team’s decision.

Legal Issues

All legal or potential legal matters are to be directed to the President for resolution. Dawn Farm will respond in a prescribed manner, in adherence with applicable federal and state laws, to all subpoenas, court orders, arrest warrants, and lawsuits. Dawn Farm retains legal counsel for consultation when necessary.

Insurance

Dawn Farm/Dawn, Inc. maintains both professional and general liability insurance. All staff members and contracted personnel are covered under these policies only if their actions are in accordance with internal

policy and procedure and external law and regulation.

Personal Belongings

We encourage employees to be prudent about bringing personal items to work, especially sums of money or other valuable items. Dawn Farm will not be responsible for losses resulting from theft or damage of personal property while staff are away from their desk, work area, or property. Staff should report any loss of property to their supervisor immediately.

Personal Fundraising

Staff will not ask clients to participate in any personal fundraising activities for staff (i.e. food drives, holiday fundraisers, etc.).

Boundaries

Establishing professional boundaries is the responsibility of staff, not clients.

Witnessing Documents

Documents that require witnessing will be witnessed by Dawn Farm staff, following all applicable legal and/or confidentiality requirements.

Waste, Fraud, Abuse, or Wrongdoing

Dawn Farm will continually work to be free of waste, fraud, abuse, or wrongdoing. Dawn Farm staff and other stakeholders will be encouraged to report any cases of waste, fraud, abuse, or wrongdoing. Dawn Farm will not retaliate against or permit reprisals against any individual who reports a potential violation of the waste, fraud, abuse, or wrongdoing policy. The Corporate Compliance Officer, working with the Clinical Director and/or President, will initiate an investigation within five business days. During this time they will be in communication with the staff that made the report. While corrective action will be taken as quickly as possible, it should not exceed 30 days. If an extension is required, a report should be written and submitted to the President, Clinical Director, and Corporate Compliance Officer.

Business

In all business matters, Dawn Farm will follow its Code of Ethics, which includes Corporate Compliance and Waste, Fraud, Abuse, and Wrongdoing. In addition, business partnerships that may involve the encountering of clients or confidential client information must involve the signing of our Business Associate Agreement. The Agreement will be filed on our administrative site.

Practical Steps for Dealing with Ethical Dilemmas

These steps are to be used as a practical guide—in conjunction with the guiding principles of the Dawn Farm Code of Ethics. This guide is not to be used by any employee alone.

The first step when faced with any ethical dilemma is to inform one’s supervisor. This is meant to be used as one tool along with the Dawn Farm Code of Ethics and consultation with supervisors.

1. Inform your supervisor.

2. Gather all of the relevant facts. Keep in mind that this make take a few fact-finding missions. As different people are involved, different questions will be raised.

3. Identify the key stakeholders and their interests. These are likely to be a client, individual staff, the larger organization, the recovering community, the broader community, funding sources, future clients and/or a client’s family.

4. Consult Dawn Farm’s Code of Ethics; the applicable Dawn Farm policies and procedures; applicable local, state and federal laws; and applicable contracts. This step will frequently resolve the issue. It may be a situation that we have confronted before and developed a policy in response.

5. Identify the worst case scenarios. Let your imagination run wild. What if someone involved relapsed? What if someone involved is misrepresenting a pertinent fact? What if the decision works out poorly for those involved and results in ill-will?

6. Brainstorm solutions with the stakeholders involved. Are there ways to address the issue that don’t present any ethical pitfalls? Could a third party be helpful?

7. Put the possible decisions to “the test.”

   • Does it fit comfortably within our mission statement?

   • Would we be proud of this decision? Or, might we be embarrassed?

   • Would we be comfortable defending the decision if we were challenged?

   • Does this decision put people or personalities first?

   • Is this decision based on fear or faith?

   • Does it meet the “front page of the paper” test? What’s the worst headline that could result from this decision? Is it worth the risk?

8. Develop a plan of action to resolve the current dilemma and address future incidents.