1. Purpose

This Vendor Policy outlines the principles and procedures governing the selection, engagement, and ongoing relationships with all therapy providers (vendors) to whom Bereishis Foundation Inc (“the Organization”) refers individuals for services. The primary aim of this policy is to ensure that all referrals are made solely in the best interest of the individuals seeking therapy, based on professional competence, availability, and suitability of services, and free from any actual or perceived conflicts of interest, financial inducements, or improper influence.

2. Scope

This policy applies to all staff, volunteers, board members, and any other individuals acting on behalf of Bereishis Foundation Inc who are involved in the referral process or vendor engagement. It covers all therapy disciplines for which the Organization provides referral services, including but not limited to mental health, Applied Behavior Analysis (ABA), physical therapy, speech therapy, and occupational therapy.

3. Core Principles

• Client-Centered Referrals: All referral decisions shall be made with the sole objective of meeting the individual’s needs and preferences and based on the professional judgment of the Organization’s staff regarding the most appropriate and effective therapeutic services.

• Transparency and Disclosure: The Organization is committed to transparency in its referral practices and will ensure that individuals receiving referrals are aware of this policy and the criteria used for vendor selection.

• Ethical Conduct: All interactions with vendors will be conducted with the highest standards of integrity, professionalism, and ethical conduct.

• Compliance: The Organization will comply with all applicable federal, state, and local laws and regulations governing referral services, non-profit operations, and healthcare ethics.

4. No Compensation for Referrals

4.1 Prohibition of Referral Fees:

The Organization strictly prohibits the acceptance of any form of compensation, financial or otherwise, from therapy providers in exchange for referrals. This includes, but is not limited to:

• Direct payments, fees, or commissions.

• Gifts of significant value (as defined by Bereishis Foundation Inc Gift Policy).

• Discounts or preferential treatment offered to the Organization or its staff in ex- change for referrals.

• Kickbacks or any other remuneration for the referral of individuals for therapy services.

4.2 Prohibition of Inducements:

The Organization will not solicit or accept any inducements from therapy providers that could influence referral decisions or create an appearance of impropriety.

4.3 Vendor Agreements:

All agreements or understandings with therapy providers will explicitly state that no compensation is provided or expected for referrals.

5. Conflicts of Interest: Board of Directors and Staff

5.1 General Prohibition:

To maintain the integrity and impartiality of its referral services, the Organization strictly prohibits any referral arrangements that could create a conflict of interest involving its Board of Directors or staff members.

5.2 Prohibition of Arrangements with Family Members:

The Organization will not enter into any referral arrangements, formal or informal, with therapy providers who are owned, operated, or directly affiliated with:

• Any immediate family member (spouse, partner, child, parent, sibling) of a current Board of Director.

• Any immediate family member (spouse, partner, child, parent, sibling) of a current staff member involved in the referral process.

5.3 Prohibition of Arrangements with Board-Associated Businesses:

The Organization will not enter into any referral arrangements with businesses or entities in which a current Board of Director has a significant financial interest, ownership stake, or holds a leadership position that could be perceived as influencing referral decisions. This includes, but is not limited to, therapy practices, consulting firms, or other entities related to the provision of healthcare services.

5.4 Disclosure of Potential Conflicts:

• Board Members: Each Board Member is required to annually disclose any potential conflicts of interest, including any ownership or significant financial interest in therapy practices or related businesses, and any family members involved in such practices. This disclosure will be reviewed by the Board of Directors or a designated committee.

• Staff Members: Staff members involved in the referral process are required to disclose any potential conflicts of interest, including any family members involved in therapy practices, to their supervisor.

5.5 Management of Disclosed Conflicts:

In the event of a disclosed potential conflict of interest, the Organization will take ap- propriate steps to mitigate or eliminate the conflict, which may include:

• Recusal of the Board Member or staff member from any discussions or decisions related to the conflicted vendor.

• Prohibition of referrals to the conflicted vendor.

• Termination of existing referral arrangements if the conflict cannot be adequately managed.

6. Vendor Selection and Evaluation

6.1 Criteria for Vendor Selection:

The Organization will establish clear, objective, and non-discriminatory criteria for the selection of therapy providers for referral. These criteria may include:

• Licensure and certification in good standing.

• Professional qualifications and experience of therapists.

• Specialization in specific therapy areas or populations.

• Demonstrated effectiveness and positive client outcomes (where measurable). • Accessibility of services (e.g., location, wait times, hours of operation).

• Acceptance of various insurance plans or availability of sliding scale fees.

• Adherence to ethical guidelines and best practices.

• Positive client feedback (where available and verifiable).

6.2 Due Diligence:

The Organization will conduct appropriate due diligence on all potential vendors to verify credentials, ensure compliance with relevant regulations, and assess their suitability for referral.

6.3 Ongoing Monitoring:

The Organization will periodically review the performance and continued suitability of its referred therapy providers to ensure ongoing quality and adherence to this policy.

7. Policy Violations

Any violation of this policy by staff, volunteers, or Board members will be taken seriously and may result in disciplinary action, up to and including termination of employment or removal from the Board, as appropriate. Suspected violations should be reported to Designated Person/Department, e.g., Executive Director, Board Chair, Ethics Committee.

8. Policy Review

This policy will be reviewed annually by the Board of Directors or a designated committee to ensure its continued effectiveness, relevance, and compliance with all applicable laws and regulations.