Policy on Private Practice Boundaries, Non-Solicitation, and Compliance with Maryland Regulations

1. Purpose and Scope

This policy establishes binding standards governing the conduct of all staff, clinicians, contractors, and interns at Lartey Wellness Group (LWG) who maintain or intend to maintain private practice activities outside the organization. The primary objective of this policy is to prevent conflicts of interest, eliminate the risk of soliciting LWG clients for private business, protect client welfare, and ensure complete compliance with Maryland’s regulatory and ethical requirements. It applies to all employees and contractors regardless of license level, including licensed clinicians, provisionally licensed clinicians, graduate-level trainees, interns, and administrative personnel whose roles involve direct or indirect interaction with LWG clients.

2. Professional Growth and Organizational Liability Protection

LWG recognizes and supports the professional development of its staff and acknowledges that private practice work may be an important component of their long-term career growth. The organization values advancement, additional clinical experience, and professional independence. However, such private activities must at all times remain clearly separated from the staff member’s employment with LWG. LWG has an obligation to protect itself from legal, ethical, and regulatory liabilities that may arise when staff engage in private business that overlaps with or appears connected to their organizational role.

Therefore, while LWG affirms its support for professional growth, this support does not extend to any conduct that may expose the organization to regulatory complaints, conflicts of interest, insurance confusion, or violations of the Code of Maryland Regulations (COMAR). Staff must maintain unmistakable boundaries between their external professional pursuits and the work they perform under the LWG umbrella. Any private activity must be conducted in a manner that preserves the integrity, reputation, and operational stability of LWG.

3. Legal and Regulatory Framework

This policy is grounded in specific legal requirements and ethical standards established by the Maryland Board of Professional Counselors and Therapists. COMAR 10.58.03.05 prohibits counselors from engaging in dual relationships that may impair professional judgment or exploit client trust or dependency. COMAR 10.58.03.04 requires practitioners to disclose conflicts of interest, avoid misleading clients about the nature of the counseling relationship, maintain the confidentiality of all client information, and clearly distinguish the roles they hold in any professional capacity. Additionally, COMAR 10.58.03.02 outlines the ethical obligation to uphold professional integrity and avoid actions that may cause confusion or result in conflicting professional responsibilities. These legal mandates form the foundation of this policy and serve as enforceable standards for all LWG-affiliated staff.

4. Non-Solicitation of LWG Clients

LWG strictly prohibits any form of solicitation of clients for private practice purposes. Staff may not approach, encourage, persuade, or imply to any LWG client that they should pursue services outside the organization through the staff member’s private practice. This prohibition applies to all forms of communication, including verbal discussions, text messages, emails, social media interactions, or any informal conversation that could be interpreted as promoting private services.

Furthermore, staff may not reference differences in availability, cost, insurance coverage, scheduling, or therapeutic modality in a manner that directs a client to consider services offered outside of LWG. Any expression that might steer a client toward private treatment undermines ethical boundaries, violates COMAR regulations on dual relationships, and places LWG at risk of liability. All client care decisions must remain within the scope of LWG services unless formally transitioned through established procedures approved by LWG leadership.

5. Insurance, Billing, and Representation Standards

Clear separation between LWG services and private practice services is essential to maintaining compliance with legal and ethical standards. Staff must not create confusion regarding insurance acceptance, billing procedures, or provider credentials. LWG’s insurance relationships, credentialing arrangements, and billing practices are solely for the services delivered under the LWG umbrella and cannot be represented as available through any external private practice.

Staff must ensure that clients do not misinterpret private practice services as extensions of LWG services. All communication with clients must clearly identify the context in which services are being provided. Private practice billing systems, fee arrangements, and insurance networks must remain entirely distinct from those used by LWG. Any blending or misrepresentation of these systems may constitute a violation of COMAR’s ethical requirements and may expose LWG to regulatory review, insurance audits, or legal claims.

6. Confidentiality and Prohibition on Using LWG Information

All client information obtained through LWG is confidential, protected, and owned exclusively by LWG. Staff may not use or reference any LWG client information for the purpose of advancing or benefiting their private practice. This includes contact information, treatment history, scheduling details, insurance information, clinical notes, and any information stored within LWG’s internal systems.

Using LWG information to benefit a private practice constitutes a breach of HIPAA, a violation of COMAR confidentiality standards, and a misuse of organizational property. Such conduct undermines client trust, compromises the integrity of the organization, and exposes LWG to regulatory and legal liability. Staff must maintain strict confidentiality at all times and ensure that no private practice activity utilizes or benefits from LWG client information, relationships, or data.

7. Conflicts of Interest and Reporting Obligations

Staff are responsible for identifying and reporting any actual or potential conflict of interest arising from their involvement in private practice. Situations requiring disclosure include instances where a client independently contacts a staff member’s private practice, where a prospective LWG client already has a relationship with the staff member in their private setting, or where a staff member believes a client may be confused about the distinction between LWG services and private practice services.

Upon disclosure, LWG leadership or the Compliance Department will review the situation to determine whether continued engagement is permissible. This evaluation will be documented and may include restrictions, recommendations, or directives designed to preserve compliance with COMAR standards and protect LWG’s legal and ethical responsibilities.

8. Separation of Employment Duties and Private Practice Activities

All private practice activities must occur entirely separate from LWG employment duties. Staff may not conduct private practice work during LWG work hours, nor may they use LWG equipment, communication systems, email addresses, telehealth platforms, or office resources for private practice purposes. Additionally, staff must refrain from presenting themselves as representing LWG while operating their private practice.

Marketing, promotional materials, websites, professional profiles, or public listings associated with the staff member’s private practice must not give the appearance that LWG endorses, sponsors, or is affiliated with the private practice in any way. Any description of the staff member’s employment with LWG that appears in private practice materials must be factual, neutral, and non-promotional.

9. Enforcement and Consequences

Compliance with this policy is mandatory for all staff and contractors. Violations of this policy—including solicitation, misrepresentation, dual-relationship conflicts, insurance confusion, or confidentiality breaches—constitute grounds for disciplinary action, up to and including termination of employment or contract. Because many of the prohibitions in this policy are rooted in COMAR and professional licensure obligations, LWG reserves the right to report substantiated violations to the Maryland Board of Professional Counselors and Therapists or other regulatory authorities when required to protect clients or the organization.

10. Conclusion

This policy ensures that LWG staff may pursue professional growth, including independent private practice opportunities, while maintaining the highest level of legal, ethical, and organizational compliance. By upholding COMAR standards and maintaining clear boundaries between LWG operations and external private practice activities, staff safeguard client well-being, protect the integrity of LWG, and preserve their own professional standing. Strict adherence to this policy is essential to preventing conflicts of interest, avoiding liability, and maintaining trust in the therapeutic relationships established under the LWG umbrella.