Sanctions, acknowledged by every active member

A sanctions policy is a set of decisions, not a document. The test is whether you can say what happens when an RBT shares PHI in a group chat, before it happens rather than after.

The policy is composed from your clinic’s facts

Your sanction policy covers workforce scope, the principle that sanctions run through ordinary discipline rather than a parallel process, a graduated five-tier ladder rendered from your own settings, violation categories mapped to those tiers, adjudication of every event, the protection that reporting in good faith is never sanctionable, the six documentation elements OCR expects, written workforce acknowledgment, referral to authorities, and the duty to report.

What gets tracked after the policy exists

Six requirements:

• A finalized sanction policy exists in the sanctions module.
• The composed policy is adopted, reviewed within twelve months, with facts that have not drifted.
• Every active workforce member has acknowledged the policy in writing.
• No sanction evaluation is sitting open or overdue.

Acknowledgment coverage runs per member against your active roster, so a new hire who never acknowledged shows as a gap rather than being absorbed into a percentage.

What this is, and what it is not

The system tracks that the policy exists, that everyone acknowledged it, and that evaluations resolved. It does not judge whether a sanction was applied appropriately or whether adjudication was fair. Those are decisions your officers make, and the record shows they were made and when.

What an investigator gets

A finalized, adopted policy with a defined ladder. A per-member acknowledgment record. A trail of sanction evaluations with resolution. The documentation elements OCR asks for, on file rather than assembled after a complaint.