Revised January 14, 2023

1. Operations Manager (or another CARD team member who is responsible for opening the Center) shall complete the following steps:

  • a) OM arrives to center prior to arrival of first Behavior Technician & patient with enough time to complete appropriate sanitation procedures after thoroughly washing hands.
  • b) OM puts on gloves and keeps them on throughout the center disinfectant protocol.
  • c) OM sprays & wipes down exterior center door handle and surrounding area with
    antibacterial cleaner.
  • d) OM should not enter the center if they have any symptoms of COVID-19, including a fever of 100.4 or higher, shortness of breath, cough, or loss of taste or smell.

2. Behavior Technician Arrival

  • a) BTs should not enter the center if they have any symptoms of COVID-19, including a fever of 100.4 or higher, shortness of breath, cough, or loss of taste or smell.

3. Patient Arrival & Drop-off

  • a) Patients should not enter the center if they have any symptoms of COVID-19, including a fever of 100.4 or higher, shortness of breath, cough, or loss of taste or smell.
  • b) Teammates should monitor all patients for signs and symptoms of respiratory infections.
    – i. Each center should identify an area where Teammates or patients would be isolated if they become symptomatic and cannot immediately leave the center.
    – ii. Patients or Teammates who are symptomatic with respiratory illness should be isolated immediately and be separated from well patients and Teammates until sick patients and Teammates can be sent home.
  • c) Caregivers are allowed to enter the center to pick up their child observe therapy, meet with staff, and participate in caregiver collaboration meetings. However, caregivers should not
    enter the center if they have any symptoms of COVID-19, including a fever of 100.4 or
    higher, shortness of breath, cough, or loss of taste or smell, or after exposure to COVID-19
    unless they are asymptomatic and are wearing face coverings.
  • d) Where face coverings are required, caregivers should wear face coverings when entering the
  1. All Teammates and patients should be excluded from the center if they are sick or are symptomatic.
  2. On a confirmed positive exposure, teammates and patients who have no symptoms should:
    – a. Regardless of vaccination status, employees who test positive can return to work after 5 days if the employee has a negative test, symptoms are improving, and they continue to wear a face covering.
    – b. Individuals who can wear a face covering around others do not need to quarantine or stay home from work unless symptoms start. 
    – c. If symptoms develop, the individual should isolate, get tested, and stay home until test results are received.
  3. On a confirmed positive exposure, teammates and patients who have symptoms should:
    – a. Isolate, test, and stay home until test results are received.
    – b. If test result is positive, isolate for five days since the onset of symptoms.
    Teammates or patients who return to the center after 5 days of quarantine must wear a face covering at the center. If they cannot wear a mask, they must isolate for 10 days from the onset of symptoms.
  4. On a confirmed positive exposure, if you had COVID-19 within the last 90 days:
    – a. You don’t need to test, quarantine, or stay home from work unless symptoms start.
    – b. If symptoms start, isolate and get tested.
  • a) Per existing regulatory requirements, CARD is required to document vaccination status for Teammates using one of the following methods of documentation:
    – i. Teammates can provide proof of vaccination, including a vaccine card or health care document showing vaccination status, and CARD will maintain a copy confidentially in the Concred system.
    – ii. Teammates self-attest to vaccination status and CARD maintains a record of who selfattests.
    **some counties require an employer to maintain a physical copy of a vaccine card and self-attestation is not allowed**
  • b) If a Teammate declines to state their vaccination status, CARD is required under regulatory requirements to treat the Teammate as unvaccinated.
  • c) CARD teammates are not required, and CARD will not disclose (without teammate written authorization) COVID vaccination status with caregivers, patients or other teammates.
  • a) CARD will offer testing at no cost to Teammates under the following circumstances outlined below. In most instances, COVID-19 testing remains free and will be the first referral. This testing protocol is subject to change based on state and federal updated guidance.
    – i. All Teammates in an outbreak defined as at least three suspected, probable, or confirmed COVID-19 cases within a 14-day period among people who are epidemiologically linked in the setting, and are not known to be close contacts of each other in any other case investigation.
  • b) Fully vaccinated Teammates will not be offered testing.
  • a) As of the date of this revision, previously stated physical distancing and barrier requirements are removed regardless of Teammate’s vaccination status, except for locations where unvaccinated Teammates are eating and drinking.
  • b) With respect to patients at the center, unvaccinated and unmasked patients will continue to be required to social distance at the center. Patients that are unvaccinated, yet masked, will be allowed to resume limited interaction using the reasonable judgment of the clinical team based upon the particular surroundings of the Center. 
  • c) Notwithstanding the forgoing, the following are exemptions to the elimination of physical distancing requirement:
    – i. If CARD assesses a workplace hazard and determines that physical distancing is necessary for the workplace.
    – ii. If there is an outbreak (3 or more Teammates testing positive within a 14-day period), CARD will evaluate whether physical distancing or barriers are needed to control transmission.
    – iii. Physical distancing and barriers are mandated in the event of a major outbreak, defined as 20 or more Teammates testing positive.)

a) General Guidelines

  • i. CARD follows CDC guidelines and state and local requirements regarding face coverings. Accordingly, CARD does not require teammates to wear face coverings while working unless face coverings are required by the CDC guidelines, by state or local requirements or unless another preapproved exception applies. As these recommendations and guidelines change frequently, this policy is subject to continued modification.
  • ii. Currently, teammates in the following states are required to wear face coverings when treating patients or providing services: California and Washington. In Colorado, unvaccinated teammates must continue to wear face coverings. An individual is considered vaccinated if they have all initial doses of the vaccine, and if eligible, one booster.
  • iii. In all other states, teammates will not be required wear face coverings except when one of the following applies: 1) when community COVID-19 rates are high as defined by the CDC; 2) following COVID-19 exposure when required to wear face coverings by CARD’s protocols; 3) when requested to do so by a caregiver; 4) when face coverings are required in a specific location in the community that requires face coverings; or (5) as mandated by a particular funding source.
  • iv. Teammates who voluntarily choose to wearing face coverings in locations that do not require wearing face coverings may continue to do so without fear of retaliation.

b) Home Sessions

  • i. Where face coverings are required, teammates should wear face coverings during home sessions, subject to the exceptions below. Where face coverings are not required, teammates should wear face coverings in the home when requested to do so by caregivers.

c) Exceptions to Face Coverings Requirement:

  • i. When Teammates are outside and there is plenty of ventilation.
  • ii. When a Teammate is alone in a room or vehicle.
  • iii. While eating or drinking, but only if teammates are at least six feet apart and outside air has been maximized to the extent feasible. (Note that this one area where physical distancing is still required.)
  • iv. Teammates who cannot wear face coverings due to a medical or mental health condition or disability and have sought a requested accommodation, or who are hearing-impaired or communicating with a hearing-impaired person. In some instances, a teammate may be required to wear an alternative face covering such as a face shield.
  • v. Specific tasks which cannot feasibly be performed with a face covering as it impedes interaction with the patient, hinders a learning protocol, a teaching protocol requires the patient to see the clinician’s mouth or otherwise is not clinically appropriate for the clinician to wear. This exception is limited to the time period in which such tasks are actually being performed. In these situations, Teammates must utilize a face shield as preapprove by their direct supervisor.

d) Patients

  • i. Though not mandatory, it is recommended that patients wear face coverings while in the center.
  • ii. If a patient is resistant to wearing face coverings, consider adding this skill to their treatment program. At no time should a face covering be forced upon a patient against their will. If requested by a caregiver, discuss this with them.
  • iii. Patients 2 and under should not wear face coverings at any time as they have been identified as a suffocation hazard.
  • a) When no people with confirmed or suspected COVID-19 are known to have been in a space, cleaning once a day is usually enough to sufficiently remove virus that may be on surfaces and help maintain a healthy center.
  • b) Where there is a higher level of COVID-19 transmission in a community, where there is a low frequency of face covering or where there is poor hand hygiene, cleaning more frequent than daily and/or disinfecting must be done.
  • c) In the even there are several Teammates test positive for COVID-19 immediately contact the
    CARD COVID-19 help email for a deep cleaning.
  • d) While the CDC indicates that the risk of “catching” COVID from surfaces is extremely low, CARD still requires the following protocols.
  • e) Hand Washing Schedule for Teammates & Patients (warm water with soap for at least 20 seconds).
    – i. Behavior Technicians & patients must wash hands upon entering the center
    – ii. Behavior Technicians must wash their hands between patients
    iii. Behavior Technicians & patients should practice good hygiene which includes regular handwashing.
    • a) Following coughs or sneezes
    • b) Prior to and after preparing or consuming food
    • c) Following toileting
  • f) Hand sanitizer
    – i. May be used if patient or Teammates are unable to implement hand washing schedule as noted above.
    – ii. Patient Stimuli.
      • a. Electronic stimuli should be used whenever possible
      • b. If patient requires physical stimuli, it should be kept in patient storage bin  at center and should only consist of laminated (non-cardboard or paper) and hard surface items that can be safely cleaned with soap and water and/or antibacterial spray. If patient has both home and center-based services, stimuli should travel with the patient and be cleaned before and after use.
      • c. Stimuli should not be shared between patients.
  • g) Toys
    – i. Toys that can safely cleaned with soap and water and/or antibacterial spray should be sanitized daily by OM or their designee prior to Teammates and patient arrival.
    – ii. Following interaction with a toy that will be used by other patients, the Behavior Technician or other clinician should have the patient help with proper sanitation procedures prior to putting it away.
  • h) Physical locations such as kitchens and restroom areas should be properly cleaned at least daily by the assigned cleaning crew. Individual patient workstations should be sanitized upon entry and following hand washing by the patient and clinician. All hard surfaces should continue to be wiped down regularly.
  • i) Food & Mealtimes
    • a. Caregivers are advised to send patient meals in disposable bags.
    • b. Caregivers are advised to send patient meals that do not have to be cooked, heated, or refrigerated.
    • c. Caregivers are advised to package snack items in a container or bag that the patient can access and open independently.
    • d. If a patient has a meal that must be cooked or heated, it is advised that CARD Teammates stagger meal preparation times. The need to heat meals should be an exception, and caregivers should be reminded to send food that adheres to the guidelines.
    • e. Meals should be eaten in the assigned workstation.
    • f. Meals should not be eaten in groups.
  • j) Diapering/Toileting Accidents.
      • a. When it becomes necessary to change a patient, Teammates will ensure they are wearing appropriate PPE which shall include a face covering and wash their hands and wash the patient’s hands before they begin, and wear disposable gloves. Teammates must follow safe diaper changing procedures as follows:
      • i. Prepare (includes putting on disposable gloves)
      • ii. Clean the patient
      • iii. Place wet or soiled closed in a bag
      • iv. Remove trash (soiled diaper and wipes)
      • v. Replace diaper
      • vi. Wash patient’s hands
      • vii. Clean up diapering station
      • viii. Wash hands
    • b. After diapering, Teammates will wash their hands (even if they were wearing gloves) and disinfect the diapering area. If the surface is dirty, it will be cleaned with detergent or soap and water prior to disinfection.

CARD Written COVID-19
Prevention Program

Revised January 14, 2023

This CARD COVID-19 Prevention Program is prepared in compliance with California Occupational Safety and Health Standards Board, Title 8, Division 1, Chapter 4, Subchapter 7, §3205(c) as well as Federal and other various state OSHA requirements. This CARD COVID-19 Prevention Program expressly addresses the following 11 elements:

  • (A) All CARD employees are required to report to CARD, without fear of reprisal, any and all COVID-19 symptoms, possible COVID-19 exposures, and possible COVID-19 hazards at the workplace. All such information shall be reported to the CARD COVID-19 Response Team utilizing the dedicated email .
  • (B) To the extent that any CARD employees have medical or other conditions that put them at increased risk of severe COVID-19 illness, employees are directed to request an accommodation from the Human Resource Department pursuant to the Employee Handbook. The Human Resource department is responsible for implementing this policy, including resolution of reasonable accommodation requests, and should be contacted with any questions.
  • (C) Pursuant to the CARD COVID-19 Response Policy (attached), CARD will engage in a systematic process for clearing employees with confirmed COVID-19 diagnoses to return to work. CARD can require employees to take medical tests that are “job-related and consistent with business necessity to keep infected individuals from spreading the virus to coworkers and patients. CARD may take steps to determine if employees entering the workplace have COVID-19 because an individual with the virus will pose a direct threat to the health of others. This includes electing to administer or directing an employee to obtain a COVID-19 test before they enter the workplace to determine if they have the virus. CARD may require employees who had COVID-19 to submit a clearance from a physician if they wish to return to work.
  • (D) CARD has developed comprehensive policies and procedures to address potential hazards and precautions to protect against the transmission of COVID-19. All policies and procedures are accessible on the CARD Sharepoint intranet site for all employees- In addition, CARD routinely communicates with employees, caregivers, patients and others regarding its ever-evolving COVID-19 policies and procedures. These can take the form of electronic mail and direct letter notification.
  • (A) All CARD employees are actively encouraged to participation in the identification and evaluation of COVID-19 hazards. All such observations shall be reported to the CARD COVID-19 Response Team utilizing the dedicated email hotline:
  • (B) CARD has developed and implemented a process for screening employees for and responding to employees with COVID-19 symptoms. The procedure is set forth in the COVID-19 CBS Protocol. All employees and patients are required to evaluate their own symptoms before reporting to work.
  • (C) CARD has developed comprehensive COVID-19 policies and procedures to respond effectively and immediately to individuals at the workplace who are a COVID-19 case to prevent or reduce the risk of transmission of COVID-19 in the workplace. Once a positive case is reported to the CARD COVID-19 Response Team utilizing the dedicated email hotline:, a series of questions are required to be completed to further analyze the date of testing, the date of the results, symptom tracking, PPE and disinfectant and cleaning protocol adherence, individuals within direct contact, etc. Once this information is provided, letters to individuals who have had direct contact with the positive individual over the last five (5) days are provided. Monthly, a representative from the CARD Legal Department audits each positive case and documents the recovery.
  • (D) CARD routinely conducts workplace-specific identification of all interactions, areas, activities, processes, equipment, and materials that could potentially expose employees to COVID-19 hazards. All such areas are identified in monthly COVID-19 audits and addressed in the COVID-19 CBS Protocol. CARD has evaluated local centers with increased ventilation controls as part of the HVAC system as well as centers that have fans with HEPA filters. CARD has also starting to add portable units for centers to purchase at their discretion. CARD treats all persons, regardless of symptoms or negative COVID-19 test results, as potentially infectious and follows CDC guidance on managing both confirmed and suspected positive cases.
  • (A) CARD has developed an effective procedure pursuant to its CARD COVID-19 Response Policy, to investigate COVID-19 cases in the workplace. This includes procedures for verifying COVID-19 case status, receiving information regarding COVID-19 test results and onset of COVID-19 symptoms, and identifying and recording COVID-19 cases.
  • (B) In accordance with Section 2(c) above, CARD takes the following actions when there has been a COVID-19 case at the place of employment:
    • 1. Determine the day and time the COVID-19 case was last present and, to the extent possible, the date of the positive COVID-19 test(s) and/or diagnosis, and the date the COVID-19 case first had one or more COVID-19 symptoms, if any were experienced.
    • 2. Determine who may have had a COVID-19 exposure. This requires an evaluation of the activities of the COVID-19 case and all locations at the workplace which may have been visited by the COVID-19 case during the high-risk exposure period.
    • 3. Give notice of the potential COVID-19 exposure as soon as practical in a way that does not reveal any personal identifying information of the COVID-19 case to all individuals with direct contact to the positive case.
    • 4. Upon request, provide COVID-19 testing at no cost to employees during their working hours to all employees who had direct COVID-19 exposure in the workplace.
    • 5. Investigate whether any workplace conditions could have contributed to the risk of COVID-19 exposure and what could be done to reduce exposure to COVID-19 Hazards.
  • (C) Consistent with the CARD COVID-19 Response Policy, CARD ensures that all personal identifying information of COVID-19 cases or persons with COVID-19 symptoms are kept confidential.
  • (D) CARD ensures that all employee medical records obtained, if any, are kept confidential and are not disclosed or reported without the employee’s express written consent to any person within or outside the workplace, except as otherwise provided by law.

CARD shall implement effective policies and procedures for correcting any unsafe or unhealthy condition, work practices, policies and procedures brought to its attention or upon a COVID-19 audit in a timely manner based on the severity of the hazard. All employees are encouraged to be vigilant and to report any unsafe or unhealthy condition to the CARD COVID-19 Response Team utilizing the dedicated email hotlinecardcovid19@

As part of its CARD Response Policy and consistent with its overall routine infectious disease management and training, CARD provides effective training and instruction to employees that includes the following:

  • (A) CARD’s COVID-19 policies and procedures to protect employees from COVID-19 hazards.
    (B) Information regarding COVID-19-related benefits to which the employee may be entitled under applicable federal, state, or local laws.
  • (C) The fact that COVID-19 is an infectious disease that can be spread through the air when an infectious
    person talks or vocalizes, sneezes, coughs, or exhales; that COVID19 may be transmitted when a person touches a contaminated object and then touches their eyes, nose, or mouth, although that is less common; and that an infectious person may have no symptoms.
  • (D) Methods of physical distancing of at least six feet and the importance of combining physical distancing with the wearing of face coverings.
  • (E) The fact that particles containing the virus can travel more than six feet, especially indoors, so physical distancing must be combined with other controls, including face coverings and hand hygiene, to be effective.
  • (F) The importance of frequent hand washing with soap and water for at least 20 seconds and using hand sanitizer when employees do not have immediate access to a sink or hand washing facility, and that hand sanitizer does not work if the hands are soiled. Employees are directed to instructional posters in each center.
  • (G) Proper use of face coverings as required and the fact that face coverings are not respiratory protective equipment. Employees are directed to instructional posters in each center.
  • (H) COVID-19 symptoms, and the importance of not coming to work and obtaining a COVID-19 test if the employee has COVID-19 symptoms.
  • (A) To the extent practical within inhibiting appropriate therapy, all employees shall maintain appropriate distance from other persons by at least six feet as set forth in the COVID-19 CBS Protocol.
  • (B) When it is not possible to maintain a distance of at least six feet, individuals shall be as far apart as possible.
  • (A) CARD has provided directly or through a reimbursable expense face coverings and face shields and ensures they are worn by employees where required by applicable state law. Where required, all such face coverings and face shields must be worn at all times in accordance with the COVID-19 CBS Protocol.
  • (B) Employees exempted from wearing face coverings due to a medical condition, mental health condition, or disability shall wear an effective non-restrictive alternative, such as a face shield with a drape on the bottom, if their condition or disability permits it.
  • (C) Employees are not allowed to perform and services or be within the center or home therapy session without appropriate face coverings in accordance with the COVID-19 CBS Protocol.
  • (D) CARD shall prevent any employee from wearing a face covering when not required by this section, unless it would create a safety hazard, such as interfering with the safe operation of equipment.
  • (E) CARD has implemented measures to communicate to non-employees the importance of face coverings requirements on their premises.
  • (F) CARD has developed COVID-19 policies and procedures to minimize employee exposure to COVID-19 hazards originating from any person not wearing a face covering, including a member of the public. This does not include any patient who cannot wear a face covering by virtue of their autism or related disorder or which otherwise would interfere with a patients essential mental health therapy.
  • (A) At various fixed work locations, CARD has, in some instances, provided plexiglass partitions that effectively reduce aerosol transmission between the employee and other persons. In other instances, CARD has recommended therapy sessions occur in separate office or treatment areas of the center.
  • (B) In accordance with Section 2(d) above, CARD has evaluated local centers with increased ventilation controls as part of the HVAC system as well as centers that have fans with HEPA filters.
  • (C) CARD has implemented comprehensive cleaning and disinfecting procedures as thoroughly set forth in the COVID-19 CBS Protocol.
  • (D) CARD has implemented comprehensive hand-washing and hand hygiene protocols as thoroughly set forth in the COVID-19 CBS Protocol and explained in posters throughout the centers.
  • (E) CARD has provided all appropriate personal protective equipment, including face coverings, face shields, reusable and disposable rubber gloves, and safety googles (when required as a medical accommodation).
  • (A) CARD will report information about COVID-19 cases at the workplace to the local health department whenever required by law, and shall provide any related information requested by the local health department.
  • (B) CARD will report immediately to the appropriate regulatory agency any COVID-19-related serious illnesses or death of an employee occurring in a place of employment or in connection with any employment.
  • (C) CARD will maintain records of the steps taken to implement this written COVID-19 Prevention Program.
  • (D) This written COVID-19 Prevention Program is available at the workplace to employees through the CARD Sharepoint intranet site as well as to authorized employee representatives, and to representatives of Cal/OSHA immediately upon request.
  • (E) CARD will keep a record of and track all COVID-19 cases with the employee’s name, contact information, occupation, location where the employee worked, the date of the last day at the workplace, and the date of a positive COVID-19 test. Medical information shall be kept confidential. Upon formal request to the CARD Legal Department, the information shall be made available to employees, authorized employee representatives, or as otherwise required by law, with personal identifying information removed.
  • (A) CARD will ensure that COVID-19 cases are excluded from the workplace until the return to work requirements of the COVID-19 CBS Protocol are met.
  • (B) CARD will exclude employees with COVID-19 exposure from the workplace for 5 days after the last known COVID-19 exposure to a COVID-19 case and after recovery of symptoms.
  • (C) For employees excluded from work by CARD and otherwise able and available to work, CARD will continue and maintain an employee’s seniority, and all other employee rights and benefits, including the employee’s right to their former job status, as if the employee had not been removed from their job. This may also include sick pay as required under applicable law.
  • (A) COVID-19 cases with COVID-19 symptoms shall not return to work until the return to work requirements of the COVID-19 CBS Protocol are met.
  • (B) COVID-19 cases who tested positive but never developed COVID-19 symptoms shall not return to work until a minimum of 5 days have passed since the date of specimen collection of their first positive COVID-19 test.
  • (C) A negative COVID-19 test shall not be required for an employee to return to work.
  • (D) If an order to isolate or quarantine an employee is issued by a local or state health official, the employee shall not return to work until the period of isolation or quarantine is completed or the order is lifted. If no period was specified, then the period shall be 5 days from the time the order to isolate was effective, or 5 days from the time the order to quarantine was effective.