Compliance & Scope Disclosure

Pre-Operational Scope Limitation

ADB Consulting Group, LLC provides consulting services exclusively during the pre-operational and pre-enrollment phase of a behavioral health agency's development. This means:

• All consulting services begin and occur before the client agency is enrolled with Medicaid or Medicare as a provider.
• ADB's consulting work covers areas such as entity structure guidance, state licensure preparation, accreditation readiness, policy and procedure development, staffing frameworks, training curriculum, financial modeling, and investor education documents.
• ADB Consulting Group does not assist with, manage, facilitate, or participate in any Medicaid or Medicare enrollment applications or processes.
• ADB Consulting Group does not provide services to agencies that are already enrolled as Medicaid or Medicare providers.

Automatic Contract Termination Upon Enrollment

All consulting agreements between ADB Consulting Group, LLC and any client agency include an automatic termination clause. Specifically:

• Any contract or consulting agreement with ADB Consulting Group, LLC terminates automatically and immediately upon the client agency's receipt of a Medicaid provider number, Medicare provider number, or the commencement of the Medicaid or Medicare enrollment process — whichever occurs first.
• This termination is not subject to override, waiver, or modification by either party.
• Upon termination, all deliverables produced during the engagement are transferred to the client and become the exclusive property of the client agency's owner(s).
• No refund, penalty, or additional fee is associated with this automatic termination.

This structure exists to protect clients, maintain regulatory compliance, and ensure that ADB Consulting Group never operates outside its permitted scope.

OIG Exclusion Disclosure — Principal Alfonzo D. Bailey

In the interest of full transparency, ADB Consulting Group, LLC hereby discloses that its principal consultant, Alfonzo D. Bailey, is listed on the U.S. Department of Health and Human Services Office of Inspector General (OIG) List of Excluded Individuals and Entities (LEIE).

This exclusion means that:

• Alfonzo D. Bailey is prohibited from receiving payment from, working for, or being involved in any capacity with any entity that bills or receives reimbursement from Medicare or Medicaid.
• Alfonzo D. Bailey may not serve as an owner, officer, director, employee, or contractor of any Medicare- or Medicaid-enrolled agency — directly or indirectly.
• Any agency that knowingly employs or contracts with an excluded individual in a capacity that involves Medicaid or Medicare billing risk may face significant civil monetary penalties.

The consulting services provided by ADB Consulting Group are structured entirely around pre-enrollment, pre-operational guidance. No ADB consulting activity involves any Medicaid- or Medicare-enrolled entity, any billing activity, or any post-enrollment agency operations.

Prospective clients are encouraged to independently verify this disclosure and consult their own legal counsel if they have questions about the implications of engaging ADB Consulting Group, LLC.

No Management, Ownership, or Operational Control

Engaging ADB Consulting Group, LLC for CMHC startup consulting — including the comprehensive "A-to-Z" package — does not constitute, imply, or create any of the following:

• Any direct management role or authority over the client agency
• Any indirect management, operational oversight, or decision-making authority
• Any ownership interest — partial or whole — in the client agency
• Any employment relationship between ADB Consulting Group (or its principal) and the client agency
• Any ongoing operational involvement following the conclusion of the consulting engagement

All information gathered, documents produced, and frameworks developed during an ADB consulting engagement are provided exclusively to the agency's owner(s) for their independent use. This information is intended to support owners in making healthy, informed decisions that benefit the clients and communities they are called to serve.

The owner(s) of each client agency retain full and exclusive authority over all operational, clinical, financial, and administrative decisions at all times.

Purpose and Nature of Consulting Engagement

The purpose of ADB Consulting Group's engagement with any CMHC startup client is exclusively:

• To provide information, guidance, and documentation tools that support the owner's own decision-making during the pre-operational phase
• To assist owners in building a compliant, well-organized agency structure before they begin serving clients and billing insurance
• To educate founders on regulatory requirements, accreditation standards, and operational best practices — so they can make informed choices
• To develop documentation — policies, procedures, forms, financial models — that owners independently review, adopt, and implement

ADB Consulting Group operates as an advisory and document-development partner only. At no point does ADB Consulting Group assume responsibility for regulatory outcomes, business performance, or clinical operations of any client agency.

Independent Legal and Compliance Review Recommended

ADB Consulting Group strongly recommends that all prospective clients:

• Consult with a licensed attorney experienced in healthcare law and Medicaid regulations before entering into any consulting agreement
• Independently verify the OIG exclusion status of ADB's principal through the official HHS OIG LEIE search tool at oig.hhs.gov/exclusions
• Review this disclosure with their own legal counsel if they have any questions about the scope, implications, or compliance considerations of engaging ADB Consulting Group
• Conduct their own due diligence on all regulatory requirements applicable to their specific agency type and state of operation

This disclosure is provided in the spirit of complete transparency. ADB Consulting Group is committed to operating with integrity — and that starts with making sure every client knows exactly who they're working with and what the scope of that work is.