Non-Discrimination Policy

Aviation ABA Therapy LLC is committed to providing a safe, inclusive environment for both clients and staff members. This policy ensures compliance with Utah Code 26B-2-109 by prohibiting sex and gender-based abuse, discrimination, and harassment, and by establishing procedures for individualized assessments, prevention, reporting, and professional communication.

Scope

This policy applies to:

• All employees, contractors, volunteers, and interns of Aviation ABA Therapy LLC
• All clients, families, and program participants
• All service settings (clinic-based, community-based, and telehealth)

Definitions

Sex-Based Abuse

Any act of harm, intimidation, or mistreatment based on biological sex.

• Client example: Refusing therapy because the client is female.
• Staff example: Denying promotion because the employee is male.

Gender-Based Abuse

Harmful actions based on gender identity or expression.

• Client example: Misgendering a client who identifies as non-binary.
• Staff example: Mocking an employee’s gender identity during meetings.

Discrimination

Unequal treatment based on sex, gender identity, or sexual orientation.

• Client example: Assigning fewer therapy hours because of sexual orientation.
• Staff example: Giving less favorable shifts based on gender identity.

Harassment

Unwelcome conduct that creates a hostile environment.

• Client example: Making jokes about a client’s sexual orientation.
• Staff example: Using slurs or offensive language toward a coworker.

Individualized Assessment

A documented evaluation of client needs, safety, and program suitability.

Professional Communication

Respectful, inclusive language affirming all sexual orientations and gender identities, such as using requested pronouns and gender-neutral greetings.

Policy Statement

• All classification and placement decisions for clients must be based on individualized assessments.
• All staff and clients are entitled to an environment free from sex and gender-based abuse, discrimination, and harassment.
• All employees must complete annual training on professional communication and non-discrimination.

Individualized Assessment Procedures (Clients)

• Document clinical needs, safety risks, and program suitability.
• Review by a licensed clinician and approve placement.
• Store the assessment securely per HIPAA standards.

Prevention and Reporting Procedures

Prevention

• Mandatory annual training for all employees.
• Posted anti-discrimination notices in all facilities.
• Supervisory audits of compliance.

Reporting

• Immediate verbal report to a supervisor or HR.
• Written report within 24 hours using the Incident Form.
• HR review within 48 hours.
• Escalation to the Utah Office of Licensing for severe cases.

Professional Communication Training

Curriculum: Inclusive language, pronoun usage, cultural competency, and role-play scenarios for client and staff interactions.

Frequency: Annual.

Evaluation: Post-training quiz and supervisor observation.

Examples of inclusive language:

• Use “they/them” pronouns when requested.
• Avoid gendered greetings (for example, use “Hello everyone” instead of “Ladies and gentlemen”).

Enforcement and Corrective Action

For staff violations. Progressive steps apply: verbal warning, written warning, suspension, and termination.

For client incidents. Clinical review, followed by a behavior intervention plan, and possible discharge if a safety risk persists. Severe cases are reported to the Utah Office of Licensing.

Monitoring and Compliance

• Quarterly audits of placement decisions and incident reports.
• Policy compliance reviewed within 30 days of hire, with annual review and updates thereafter.

References

• Utah Code 26B-2-109
• BACB Ethics Code
• HIPAA Privacy Rule
• Utah Office of Licensing Guidelines