EASNA Modifies Code of Ethics (reprinted with permission)

In response to increased concerns related to ethical problems in the field’s business practices, the EASNA Board recently approved a new section on Business Ethics to be incorporated into our existing Code of Ethics.

PRICING/BILLING

1. Capitation. EAPs that are priced using "Capitation" or a fixed sum per month or year for each covered employee of a defined workforce, have an ethical obligation to carefully assess the adequacy of a capitation rate to make sure that proposed service levels are not threatened by rates too low to fulfill the EAP's contractual obligation. It is unethical to knowingly put forth a bid that is insufficient to fund the program as proposed. Capitation payments should be calculated primarily on the costs associated with proposed services, projected utilization rates and promotional campaigns, other relevant characteristics of the workforce, and consensus oriented standards of what constitutes or defines an EAP. EAPs should not assume inordinate levels of financial risk and should have a method to ensure that clients are protected from the potential negative effects of budgetary shortfalls in prepaid, capitated plans or “low ball” rates.

2. Fee-for-service. EAPs that are priced on a fee-for-service basis or offer extra cost-added components or features in addition to a capitated rate (e.g. trainings, critical incident debriefing, promotional materials, etc.) need to disclose in proposals and contracts the full price of any purchase for fee-for-service product offerings, including those services that are “carved-out” or separated from the capitated bid.

3. Billings. Billing for EAP services must be accurate and done in a timely and professional fashion in accordance with commonly acceptable accounts receivable standards. EAPs that utilize affiliate providers or subcontractors to render EA services are responsible for paying affiliate claims in a timely and accurate basis.

REPORTING

All reports to employers or client organizations should accurately, honestly, and fairly reflect the activities and utilization of the EAP in reasonable detail, and provide a comprehensive accounting of the program’s services in accordance with EASNA standards and applicable confidentiality laws and regulations. This Code prohibits false or misleading reports for any reason and encourages the EAP to clearly and sufficiently define for the employer how utilization rates are calculated and reported, how a case is defined, along with any specific formulas that are utilized.

MARKETING AND SALES

EA practitioners that market, propose, or sell EA services must be truthful, fair, accurate, complete, and sensitive to the employers’ organizational needs and the employee clients’ personal needs and not raise unrealistic expectations. EA practitioners engaged in marketing, sales, and account management activities shall:

• accurately and honestly market or sell only those services that are deliverable within the professional and technical limits and capabilities of the program;

• avoid false or misleading statements or advertisements;

• promote accurate expectations and understandable information in proposals and marketing materials;

• promote service usage levels reflective of high quality standards of practice;

• protect, in good faith, the independence of ethical evaluations and referral practices;

• reject sales tactics or promotions that use deception or manipulation;

• disclose all substantial risks associated with the usage of the proposed service or particular service components;

• identify any service component substitution or future plan that might materially change the proposed service or impact the buyer’s purchase decision.

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