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Withholding Fieldwork Hours

07 Aug 2023 6:16 PM | Anonymous


“Last October, I had two individuals resign with less than 24 hours’ notice, who were collecting BACB supervision hours towards their BCBA application with me as their primary supervisor. After resigning, they left their monthly verification forms with me to sign. Since their last day, I have not signed their hours and have been thinking over if they would competently and ethically work in the field. I cannot in good conscious sign off on their hours with the thought they might leave other clients overnight without a transition plan. Previously, the supervisees were in breach of the supervision contract because they were not sending in their verification hours on time.  Prior to leaving, their supervision hours log had multiple errors, as they failed to maintain feedback for their logs; but 3 weeks after resigning they sent me their most updated logs which matched with the hours on their monthly forms dropped off day after resignation.” 

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

The codes in question listed by the submitter were: 3.01 Responsibility to Clients and 3.16 Appropriately Transitioning Services.  These code violations appear to be concerns only after the supervision was terminated, so may not apply to the question of signing off on monthly verification forms.

Per BACB Fieldwork Requirements, all monthly fieldwork verification forms are required to be signed by the end of the following calendar month (linked below).  Any hours accrued by the supervisees in question that have not been signed off will be considered forfeited.

  • If there are breaches in contract, or inappropriate behavior exhibited during the supervisory period, the BACB requires the supervisor to provide feedback as well as documentation of training and/or re-training during the supervision period. 
  • There does not seem to be an instance in which the BACB approves withholding signatures from monthly verification forms for breaches in administrative duties (turning paperwork in late). 
  • If some forms were signed (even when turned in late) prior to resignation, this failure to sign verification forms gathered after resignation may be seen as retaliatory in nature. 
  • If the supervisee(s) engaged in dangerous behavior during the supervision period that required mandated reporting (abuse, neglect, etc), a police report and/or report to the BACB for misconduct is required and refusal to sign monthly verification forms may be considered appropriate. 
As far as lack of timeliness transitioning case(s), the BACB does not consider RBTs or supervisees to be independent practitioners that are responsible for their own caseloads. Therefore, although this may be an employment contract violation, it is not considered to be an ethics violation of client abandonment.  Without knowledge of what the exact role of the supervisees were in, they may or may not be in a position to be in violation of the ethics code. 

If there is concern, the committee encourages the submitter to look through the BACB’s guidance on considerations for filing a complaint (linked below). If there is a concern about the overall performance of the supervisee(s) after documented training and feedback occurred OR if violations are found after the supervisee(s) left the facility, the BCBA can also follow guidance to contest the Final Verification Form outlined in the August 2019 newsletter (linked below).

Considerations for exploration:

  • If the BCBA did not respond to requests to sign off on verification forms in a timely manner, they may be in violation of Ethics Code 1.15 Responding to Requests, 4.01 Compliance with Supervision Requirements, 4.04 Accountability in Supervision, and 05 Maintaining Supervision Documentation.
  • 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 themselves under the guidance of 1.16 Self-Reporting Critical Information. 
  • If the supervisees did commit a violation of the Ethics code, it is suggested that the BCBA first reaches out to the party responsible before filing a complaint with the Behavior Analyst Certification Board. 

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

  • 1.15 
  • 1.16 
  • 3.15 
  • 3.16 
  • 4.01 
  • 4.04 
  • 4.05 
  • 4.08 
  • A.R.S. 32-2091 12(e)/12(q)/12(v) 
Additional Resources:

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

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