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Withholding Supervision Hours Based on Inappropriate Behavior

21 Oct 2025 11:15 AM | Anonymous

Portal Submission:

Relevant background: I have a BA trainee that I am supervising that recently was reported for making inappropriate comments and trying to pursue their direct supervisee/RBT. HR was involved and evidence showed that the BA trainee used their position of power against to RBT to attempt to pursue a relationship. The RBT reported that the BA trainee mentioned their position of power when the RBT rejected their advances (e.g., “You’re turning down your supervisor?… I’m embarrassed my RBT rejected me”). Due to this ethical violation, I feel uncomfortable signing off on the BA Trainee supervision hours as the licensed BCBA.

I wanted to check in to see if I have the right to refuse to sign off on structured supervision hours due to them violating our ethical code and conducting inappropriate behavior during some of the hours that they logged.

HR was involved and the BA trainee was demoted to a RBT within the company due to this incident. 

Possible solutions: I reviewed the BACB guidelines regarding what to do if supervision guidelines does not go as planned. The board says “Address ethics concerns immediately. If unethical behavior has occurred, clearly explain to the supervisee that the associated hours cannot be counted toward supervised fieldwork. Be sure to document both the behavior and your conversation.” I sought guidance from my Clinical Director and she supports my concerns but is unsure if I can only refuse to sign hours for the hours where the RBT that was affected by the harassment was present/the hours the BA trainee was supervising the victim.

Credentialing: Reporter is an LBA

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

Disclaimer: This guidance is not intended as legal advice.

Based on the information provided, this situation raises significant ethical concerns related to harassment, misuse of supervisory power, and failure to uphold professional boundaries. The committee acknowledges the serious implications of a supervisee using their role to pursue a romantic relationship with someone they directly oversee. This conduct may constitute a coercive or exploitative relationship, as well as a violation of professional integrity and accountability (1.01, 1.03, 1.13).

The BACB provides clear guidance in the BCBA Handbook and Fieldwork Standards that supervisors may withhold verification of supervised fieldwork hours when there is evidence that the trainee violated the Ethics Code. Supervisors are expected to use professional judgment, maintain documentation of the event, and refer to the supervision contract for any conditions outlined related to conduct and verification (see BCBA Handbook: Supervision Contracts & Monthly/Final Verification).

In this case, if the supervisor determines that the supervisee’s conduct represents a substantial breach of ethics, they may refuse to sign all or any supervision hours for the affected period, including hours accrued during appropriate activities. If the trainee disputes this, they bear the responsibility of demonstrating that the denial was not aligned with BACB standards and that they attempted informal resolution first.

Because the individual described in this scenario is a BA trainee and does not yet hold BCBA or BCaBA certification, the BACB does not currently have jurisdiction over their behavior in the role of a trainee. Therefore, if reported to the BACB, this behavior would likely fall outside the BACB’s enforcement scope.

However, if the individual does currently hold an RBT credential, then they are subject to the RBT Ethics Code 2.0, and their behavior may be reportable under:

  • RBT 1.08 – Nonharassment
  • RBT 1.10 – Avoiding Multiple Relationships
  • RBT 3.04 – Self-Reporting Critical Information

If the individual is no longer credentialed in any capacity, the committee recommends that concerns be addressed through:

  • Employer HR and compliance leadership
  • Documentation of the supervisor’s refusal to sign hours, in alignment with the BACB Fieldwork Standards and supervision contract expectations
  • State licensure complaint if the conduct affected the licensed LBA’s supervisory scope, endangered client services, or contributed to workplace harm (see A.R.S. § 32-2091.12)

The committee affirms that it is appropriate for the supervising LBA to decline signing supervision hours for time periods in which ethical violations occurred, or if the overall pattern of conduct undermines the purpose of supervision. Doing so helps uphold professional standards and safeguards the field from future risk.

Considerations for exploration:

In accordance with the Ethics Code, the committee recommends:

  • Document the behavior and your rationale for withholding hours, referencing the BACB’s supervision guidance.
  • Decline to sign off on any hours you believe were accrued in violation of the Code or in a context that reflects unethical behavior.
  • Review the supervision contract for any provisions that support this action.
  • Report the behavior to the BACB if this has not already been done, particularly under the RBT Ethics Code.
  • Support the affected RBT in accessing appropriate resources, and if needed, encourage them to file a report to the BACB or relevant licensing board.

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

  • BACB Ethics Code:
    • 1.01 – Being Truthful
    • 1.03 – Accountability
    • 1.10 – Awareness of Personal Biases and Challenges
    • 1.13 – Coercive and Exploitative Relationships
    • 1.14 – Romantic and Sexual Relationships
    • 2.19 – Addressing Conditions Interfering with Service Delivery
    • 4.01 – Compliance with Supervision Requirements
    • 4.04 – Accountability in Supervision
    • 4.12 – Appropriately Terminating Supervision
  • RBT Ethics Code:
    • 1.08 – Nonharassment
    • 1.10 – Avoiding Multiple Relationships
    • 3.04 – Self-Reporting Critical Information
  • A.R.S. § 32-2091.12:
    • (a) – Incompetence
    • (b) – Gross negligence

Additional Resources:

        BACB Ethics Code for Behavior Analysts (08/2024)

        Arizona Behavior Analyst Licensure Statute A.R.S. § 32-2091


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