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Urgent – Unsupervised RBT

07 Aug 2023 6:03 PM | Anonymous


“If a BCBA didn’t supervise me with a certain client for 8 months and goals didn’t change due to this, what would happen to this BCBA?  Goals for this client had met mastery for over 4 months of services without setting the next phase change.”

Committee Input (e.g., considerations for pathways forward, potential barriers, potential solutions):

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.

We also recommend, if possible, to immediately reach out for another BCBA within the organization to provide emergent supervision for a client who has not received supervision, but this does not remove burden from the original supervising BCBA.  The committee advises that this information be brought to the leadership of the agency for support with facilitation for the current client.  While the BACB does not provide a direct percentage of supervision that must be done with each client, it is suggested that clients receive between 10-20% supervision on a monthly basis depending on the level of need.  Supervision may include updating goals and assessments, analyzing data, collaborating and training stakeholders, and should also include face to face (or telehealth) supervision of the client with their technicians.  While circumstances may warrant structural changes to supervision, technicians and stakeholders should be notified of any changes and if a case is being transferred, that contact information should be provided to all parties.

Additional considerations:

  • While the original BCBA should be contacted to address any concerns of negligence, the previous months of non-treatment constitute a complaint to the Arizona Board of Psychologist Examiners. The BCBA should make every attempt to change their supervision practices moving forward, but the past 8 months need to be accounted for. 
  • If the BCBA is currently billing for supervision and not supervising, that would be a violation of state and funder contracts and constitute billing fraud. This is covered under A.R.S. 32-2091 12 (a), obtaining a fee by fraud or misrepresentation and Ethics Code 2.06 Accuracy in Service Billing and Reporting. 
  • If the client is engaging in dangerous behavior and/or staff has not had in-person training with a supervisor, in addition to an Ethics Code violation, this could be considered gross negligence in the practice of a behavior analyst [A.R.S. 32-2091 12(e)] 
  • 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:

Ethics Codes (specific standards that could apply to support/oppose):

  • 1.04, 2.01, 2.13, 2.14, 2.15, 2.17, 2.18, 3.01, 3.03, 4.01, 4.04, 4.06
  • A.R.S. 23-2091 12(a)/12(e)/12(o)/12(v)

Arizona Association for Behavior Analysis
1800 E. Ray Road, Suite 106, Chandler, AZ 85225 | 480-893-6110 |

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