Potential Violation of Ethics Code: 1.03 - Accountability, 1.15 -Responding to Requests, 4.04- Accountability in Supervision, and 4.11 - Facilitating Continuity of Supervision

Relevant background: According to my records through an online fieldwork tracker I have completed the necessary supervised hours to be eligible to request sitting for my BCBA exam. I have completed my hours with two different employers. I contacted the initial employer l had started my hours with and was put in contact with the BCBA who completed supervision.  This BCBA reported they would happily sign off on my hours once I submit my final verification form to them. I informed the BCBA I would follow up in a few days with the completed form. 

I sent the verification form to the BCBA 7 working days ago and I have not received a response. I followed up the next working day to ensure it was sent correctly. The response I received to this second contact was an out of office reply with no context or end date reported. I waited 5 working days and followed up with the BCBA and the company they are employed with, to request a response. I have not received a response to this third request. I would like to know if this is a complaint which I should bring to the BACB.

Possible solutions: I have made three attempts to contact the BCBA and the company they work at.

Credentialing: Reporter is an RBT, supervisor is an LBA

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

Note: Before considering if a potential violation exists, it must be noted that it does not appear the reportee contacted the supervisor in a verifiable manner. It is encouraged that BCBAs are contacted  through the official BACB® portal. The BACB®s requires all certified individuals to register a contact method that is consistently monitored and required to be responded to.  Steps for using the portal are outlined below. 

The committee suggests that there is no official definition of "timely" in Arizona statutes or the BACB® policies, therefore, a timeframe of 30 days is often implied for submitting paperwork, including monthly verification forms (2024, pg. 22). Throughout the BCBA® Handbook, the BACB® suggests a reasonable timeframe across various response requirements: response can range from 14 to 45 days depending on potential risks (2024).

In order to determine if a complaint is warranted, the reportee should first take the following steps:

1.      Review the supervision contract for any agreed-upon stipulations regarding final verification hours including how and when final forms will be provided. It is recommended that all final verification forms be completed at the end of a supervised experience but required that the documentation is retained for at least seven years (2024, pg. 21-22).

2.      Reach out to the supervisor through the BACB® directly using the “Find a BCBA®” tool and document that attempt. It is important to use the supervisor’s BACB®-registered email through the portal as that is the email address the BACB® expects to be checked on a regular basis  (2024, pg. 41). Because it is unknown the status of the BCBA even having access to the email address of the agency, the email through the BACB® may likely count as the onset (i.e. day one) of attempting to retrieve a signature. 

3.      Where possible, provide the supervisor additional time (i.e up to 30 days) to respond. During this time, sending reminders would be appropriate. This demonstrates the reportees ability to provide compassionate and responsive considerations to the context and circumstances of the supervisor’s needs as a core principle of professional ethics.  Reminders should also be sent through the BACB® email tool directly as well and must also be clearly documented.

4.      Gather all supervision documentation, including monthly verification forms, as the online tracker alone is not sufficient evidence of completed supervision (2024, pg. 21). This documentation will be needed if the situation is escalated to step 5.

If there is still no response or signed verification after the above steps, it is encouraged that the reportee documents communication outlining both the ethical concerns and also requests for remedy to avoid reporting the potential ethical violation. If the situation has not resolved, proceed to step 5:

5.      Complete and submit a Contested Fieldwork Form to the BACB® (2024, pg. 2024).

 

At this point, the reportee may consider reporting concerns to the Arizona Board of Psychologist Examiners for possible violation of 32-2091 (12) (dd).

Considerations for exploration:

The BACB® suggests that speaking to the alleged violator of the ethics code before filing a complaint in an attempt to remedy the grievance.  It is important to try to work on issues together, where appropriate.  Because this supervisor appeared to be willing to complete forms, it is assumed that the supervisor is not intentionally withholding verification and may instead not have access to their work email. 

The committee suggests that when completing fieldwork hours, it is necessary to have a supervision contract that outlines expectations for all parties involved in how hours will be collected, verified and approved.  Per the BACB® Handbook (2024), each monthly verification form “...must be signed by the last day of the calendar month following the month of supervision,” while the Final Verification Form should “..be signed at the end of a specific fieldwork experience” (p 22).  Since the reportee notes that supervision was completed with a previous employer, the Final Verification Form should have been completed prior to or immediately following employment departure.  While records should be maintained for at least seven years, the supervisor and supervisee should prioritize getting verification forms signed before one of the parties terminates their supervision and/or employment relationship with their employer..

As a note: when looking for an appropriate supervisor, it is important to openly review process concerns and also have a way to contact each other outside of work emails in the event that one of the parties discontinues their employment. 

Although timeliness is of the utmost importance, especially with regard to Arizona’s immediate need for licensed and credentialed Behavior Analysts, it does not appear that the supervisor meets the threshold of an ethical violation.  Per the anonymous submission, it appears that the original request for signed forms had gone without response for only 7 working days - of which 6 of those days it is believed the supervisor did not have access to the company email. 

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

●       1.15 Responding to Requests

●       ARS 32-2091 (12) (dd)

Additional Resources:

●       BACB® Handbook:

Behavior Analyst Certification Board. (2024). Board Certified Behavior Analyst Handbook. https://www.bacb.com/wp-content/uploads/2022/01/BCBAHandbook_240426-a.pdf

●       Reporting to the Ethics Department Guidelines: https://www.bacb.com/ethics-information/reporting-to-ethics-department/

●       Contested Fieldwork Form: https://www.bacb.com/contested-experience-fieldwork-form/