“The client’s programs have not been updated, the [BCBA] also has too many clients under [her] and she has not supervised her clients.”
Committee Input (e.g., considerations for pathways forward, potential barriers, potential solutions):
In accordance with Ethics Codes 2.01, 3.01, 3.03, 4.01, and 4.06, as well as Arizona Revised Statutes 32-2091 12, the committee recommends that the author continue to advocate for a client caseload that is commensurate for the time required to perform the duties of behavior analysts successfully and ethically. The committee would encourage the author to explore the following steps as option, noting this should not be considered legal employment advice.
- Write a formal letter to your supervisor and to the executive administration, including HR, educating them on and outlining our ethical codes of conduct surrounding supervision, caseload size, etc. Provide suggestions to them on ways in which they can support BCBAs in your agency that are more conducive to best practices in supervision and quality care for clients.
- It should be noted that the writer noted that administration had been notified, but the BCBA is an executive of the company. Additional written feedback is suggested as documentation of concerns can provide protection against wrongful termination and provides a clear statement for follow-up.
- If meaningful change is not made to satisfy the ethical code of conduct, the BCBA could send their letter to the ethics committee at the BACB for further feedback.
- The BACB advises first discussing a potential complaint with the potential offender and providing this letter in writing to the clinician and administration would serve as appropriate documentation for the complaint as well as documentation that may protect from retaliation.
- In the event that a BCBA has neglected to supervise a case over the course of many months, we advise the submitter to report this to the Arizona Board of Psychologist Examiner’s and/or Behavior Analyst Certification Board immediately. As requested, the process for the submitter is to gather as much information as possible to go with the formal complaint. Once a complaint has been filed, the board will complete a full investigation of the licensed BCBA and their work as indicated in said complaint. Depending on the findings of the committee, consequent actions could vary between mandated education, censure, or in rarer cases revocation of license.
Considerations for exploration:.
- The committee acknowledges that any breach in the BACB Ethics Code is reportable to the Arizona State Licensure Board.The Committee would encourage the reportee to explore filing a complaint with the licensure board, against the party in the organization who is inappropriately supervising a client, if mediation using other, more informal methods does not yield an improved result.
- Information on the complaint process can be found here: https://psychboard.az.gov/investigations
- If resolution cannot be achieved, the author may need to explore ethical and values-aligned employment opportunities.
- While the BCBA has a responsibility to provide adequate supervision for a client, they are also responsible for providing adequate supervision for the RBTs they oversee. If this BCBA is overseeing RBTs, it is advised that the RBT ensure appropriate documentation of supervision is available to them.
Ethics Codes (specific standards that could apply to support/oppose):
- 2.01 Providing Effective Treatment
- 2.18 Continual Evaluation of the Behavior-Change Intervention
- 3.01 Responsibility to Clients
- 3.03 Accepting Clients
- 4.01 Compliance with Supervision Requirements
- 4.04 Accountability in Supervision
- 4.06 Providing Supervision and Training
- 4.10 Evaluating Effects of Supervision and Training
- A.R.S. 32-2091 12(a)/12(e)/12(o)/12(v)