An Employee Handbook for a Behavioral Health Practice: What to Include

Keep two documents, and name them differently on purpose.

The employee handbook holds your employment rules: how and when people are paid, how time off works, what conduct the practice expects, and how complaints are handled.

It speaks to everyone on payroll — clinicians, behavior technicians, the front desk and billing alike.

The policies and procedures manual holds your clinical rules: how clients are assessed, how treatment plans are built and reviewed, what happens in a crisis, and how records are documented.

It is written for clinical staff rather than the whole payroll, and it is the document to reach for when a payer, accreditor or state board asks how your clinical care works.

Separating them matters legally.

A handbook rule gets judged under employment law, including the National Labor Relations Act standard covered below.

A clinical procedure is checked against clinical standards instead — your state board's rules, your payer contracts, your accreditation standards.

When a dress code and a suicide-risk protocol live in the same book, the dress code drags the protocol into an employment-law argument neither one needs.

Where the two genuinely overlap — confidentiality, boundaries, social media — put the employment expectation in the handbook and point to the clinical source for the detail: the profession's ethics code or your clinical manual.

The next section covers what those codes say.

A generic employee handbook template can cover the employment-law basics; it will not contain your clinical rules.

Start with the policies every employer needs, then add the ones that exist only because your staff treat clients.

• Equal opportunity and anti-harassment. State that employment decisions are made without regard to protected characteristics, name exactly who receives harassment complaints, and commit in writing that no one is penalized for raising a concern in good faith. Employers covered by Title VII, the ADA, GINA or the PWFA must also post and keep posted the EEOC's required notice in conspicuous places (29 CFR 1601.30) — the poster supplements the policy, it does not replace it.
• Pay and timekeeping. How employees record time, how overtime is approved, the pay schedule, and who fixes a paycheck error.
• Leave and time off. Holidays, PTO and sick leave rules, notice requirements, and how absence interacts with your scheduling — PTO and sick leave covers how to draft those rules.
• At-will statement. A short statement that employment is voluntary, kept consistent with your state's default rule — at-will employment explains what that disclaimer can and cannot do.
• Accommodations. EEOC guidance suggests explaining the ADA accommodation process and its confidentiality protections to all staff, and names employee handbooks and orientation materials as places to do it.
• Client confidentiality. Who may access client records, what staff may say outside work, and what happens after an accidental disclosure — written to match your clinical documentation rules.
• Required trainings. License and certification requirements plus the harassment training specific states mandate — required trainings sorts them by source.
• Conduct basics. Attendance and no-show handling, phone use during sessions, gifts, incident reporting, and the escalation path when a client situation goes wrong.

Two of these deserve more than a bullet in a behavioral health practice: the boundary and social media policies, which come next, and the harassment policy, which specific states regulate in detail.

And if you are still building the team this handbook governs, the behavioral health hiring hub collects the role-by-role guides.

This is where a behavioral health handbook has to be more careful than a generic one.

Your clinicians already answer to their professions' ethics codes on boundaries and social media, and those codes are not identical.

Write your dual-relationship policy to mirror the code each role follows, or set a house rule at least as strict as the strictest code on your staff — and say in the policy which approach you took.

For counselors, the ACA's 2014 Code of Ethics is the current version as of this writing; ACA says a revision is under way and the 2014 code applies until its board adopts a new one.

Standard A.5.c prohibits sexual or romantic relationships with former clients, their romantic partners or family members for 5 years after the last professional contact, in person or electronically.

Standard A.6.b, though, does not ban every boundary extension: counselors weigh the risks and benefits of extending the relationship beyond conventional limits — attending a client's wedding or graduation, visiting an ill family member.

A handbook that flatly bans all out-of-session contact goes further than the code; if you want that stricter house rule, write it deliberately and say it applies on top of the code.

The NASW Code of Ethics (1.06(c)) tells social workers not to engage in dual or multiple relationships with clients or former clients where there is a risk of exploitation or potential harm, and to set clear boundaries when such relationships are unavoidable.

The APA Ethics Code (Standard 3.05) defines a multiple relationship — a psychologist in a professional role with a person while also in another role with that person or someone close to them — and the version in force is the 2002 code as amended effective June 1, 2010 and January 1, 2017.

The BACB's code is the most concrete of the four, which makes it the easiest to operationalize: behavior analysts avoid multiple relationships with clients and colleagues and document how they resolved any that arise (1.11); romantic or sexual relationships with current clients, stakeholders, trainees or supervisees are barred, as are those with former clients or stakeholders for at least two years (1.14); and gifts to or from clients, stakeholders, supervisees or trainees are capped at $10 (US) (1.12).

Put the $10 cap straight into your gift policy so the limit reaches the whole treatment team, not just the certificants.

Your social media policy should be the employment-side twin of those boundary rules.

The ACA code (H.6.a) says counselors who keep both a professional and a personal presence create separate professional and personal pages and profiles, and (H.6.c) says counselors respect the privacy of clients' social media unless the client consents to their viewing it.

The BACB code (5.10) goes further: behavior analysts do not publish client information or digital content on personal social media accounts or websites, and need informed consent plus a disclaimer for each post on professional accounts.

Drawing on those codes — and filling the gaps they leave to you as the employer — your social media policy should do four things:

• separate personal and professional accounts;
• bar client information and content from personal accounts;
• address following, friending and messaging current and former clients;
• forbid viewing a client's social media without their consent.

The codes differ on former-client relationships — 5 years under the ACA code, at least two years under the BACB's.

If your staff include both counselors and behavior analysts, either adopt the ACA's 5-year rule as a house rule or state clearly whose code governs whom.

Leaving it silent guarantees an inconsistency you will adjudicate mid-case.

Which policies have to be written down, and what they must say, depends on the states where your staff work.

Start with how thin the federal floor is: the FMLA covers private employers with 50 or more employees for each working day in 20 or more calendar workweeks in the current or preceding calendar year, so a practice under that size is not covered by the FMLA at all, though state leave laws may still apply.

Our FMLA guide walks through who is covered and what the leave requires.

Harassment policy and training are where specific states impose detailed written requirements.

Three examples, each from the state's own law: California requires employers with five or more employees to give supervisors at least two hours and nonsupervisory employees at least one hour of sexual harassment training (Government Code 12950.1).

New York requires every employer to adopt the state's model sexual harassment prevention policy — or a policy that equals or exceeds it — and to use the state model training program or an equivalent (Labor Law 201-g).

Illinois requires sexual harassment prevention training at least once a year to all employees (775 ILCS 5/2-109).

We verified those three states here; for every other state where you employ staff, check that state's labor department before you finalize the policy.

If you operate in more than one state, do not write one national leave or harassment policy and call it done: build the handbook around a federal core and attach a state appendix per location.

New York shows why the appendix matters — a harassment policy copied from a generic template may not meet the "equals or exceeds" standard.

The rules in your handbook — conduct, confidentiality, social media — can all be judged under federal labor law, not only against your state board's rules.

On August 2, 2023, in Stericycle, Inc., the NLRB adopted a new standard for judging whether employer work rules, including handbook rules, violate the National Labor Relations Act, overruling its 2017 Boeing decision.

Under Stericycle, a work rule that has a reasonable tendency to chill employees from exercising their NLRA rights is presumptively unlawful.

You can rebut that presumption only by proving the rule advances a legitimate and substantial business interest that a more narrowly tailored rule could not.

And Section 7 of the Act — the right to engage in concerted activities for mutual aid or protection — is written for employees generally, not only union members.

That is why the social media, confidentiality and pay-discussion rules in a non-union practice's handbook can still be challenged.

For drafting, that pushes every rule toward narrowness.

A confidentiality policy is easier to defend when it names what it protects — client health information — than when it broadly forbids discussing the practice's business.

A no-phones-during-sessions rule is narrower than a blanket ban on personal phones.

An outright ban on employees discussing wages is the example the NLRB's own enforcement guidance names: General Counsel memo GC 26-03 (February 27, 2026) tells regional offices to focus work-rule cases on rules alleged to present clear, facial violations, "such as outright bans on discussing wages among employees."

The memo is enforcement guidance — it does not change the Stericycle standard, which still applies as of this writing, though the Board could revisit it.

Have employment counsel read the handbook before you distribute it, and again whenever you add a rule touching what staff may say to each other.

Close the handbook with an acknowledgment page: a short statement that the employee received the handbook, had the chance to read it and ask questions, and agrees to follow the policies.

Keep the signed page in the personnel file.

Treat it as a receipt, not a shield — an acknowledgment shows staff received the rules, but it does not fix a rule that fails the NLRA standard above or contradicts an ethics code.

On the same page, state that the handbook is not an employment contract and does not change the at-will relationship, and keep that language consistent with the at-will statement at the front.

Version the document.

Date every revision, archive the superseded version, and re-collect acknowledgments when a change is material — a rewritten social media policy, a new harassment training cadence, a revised leave policy.

Review the whole handbook at least once a year, and immediately when a trigger hits: a new state location, a new profession (each imports its own ethics code), or new accreditor or payer requirements.

The ACA revision is a live example — when ACA's board adopts its new code, the boundary and social media sections need a pass.

Put the annual review on the same calendar as the rest of your compliance work — license verifications, required trainings, the posted EEOC notice — so none of it depends on someone remembering.