Scenario

“I work for an ABA agency in town, and have been told that I will be switching to a new case in the next few weeks. However, when I found out that the child I was going to be working with was the child of the owner of the company I got very nervous. I tried to remember more about what was discussed in my ethics course, but I am not too sure. I am not sure what I should do. I feel like there is a conflict of interest and I am worried about what would happen to me if I don’t do a good job or if I make a mistake. I have worked for another company in the past, who allowed staff to have their children treated at the company (and that seemed a little unethical too), but never the owner. What should I do?”

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

The ethics committee recognizes the uncomfortable nature of a request to provide services to a family member of a supervisor and will outline specific areas of approach.

• The Ethics committee acknowledges that the owner of said company may not be a Behavior Analyst, in which, the State Licensing Board and Behavior Analyst Certification Board do not have jurisdiction over. In the case that there is an Ethics violation, the board would hold the Licensed Behavior Analyst overseeing the case as the person responsible to answer to the board(s). 
• It is unknown how rural of an area the complainant is in, but with the advent of telehealth being reimbursed, it would be difficult to justify that the owner of the company has no other options than utilizing their own staff. Outside of potential HR breaches, there are a few ethical considerations that may at best make technicians and BCBAs uncomfortable providing services to a supervisor’s child.  The people involved do have a duty as credentialed clinicians to offer alternatives and provide a risk/benefit analysis for provided services to this child.  The potential ethical considerations are outlined below. 
• If this complainant is an RBT, an area to be mindful in the RBT Ethics 2.0 code is area 1.10: “RBTs avoid multiple relationships with clients, coworkers, and supervisors. Multiple relationships occur when there is a mixing of two or more relationships (e.g., friend, family member, employee/employer) that may result in conflicts of interest and risk of harm to the client. If RBTs find that a multiple relationship has developed, they immediately inform their supervisor, work to resolve it, and document these actions. If the multiple relationship involves their supervisor, RBTs should report it to their supervisor’s manager or other appropriate entity (e.g., human resources, BACB) and document this communication.” 

Regardless of the owner’s certification or lack thereof, there is a power dynamic at play between the owner and the RBT providing services to their child.  It would be difficult to move forward with terminations, promotions or any other career delineation once this RBT has spent time with the owner’s child without any HR repercussions, at the very least.  This may be viewed as discrimination, favoritism, or exploitation.  This could also be said if the complainant is a BCBA.

If the owner is a BCBA, this may be a violation of Ethics Codes 1.11 Multiple Relationships and 1.13 Coercive and Exploitative Relationships.

If the complainant is an RBT and the case supervisor is a BCBA, that BCBA may still be accountable for these Code areas toward both the RBT and the BCBA.

If the complainant is a BCBA, it would behoove them to speak to the owner about alternative options for service to avoid any potential ethics violations. The BCBA may want to speak to an HR representative or employment attorney in the event that the owner retaliates the case refusal.  The BCBA also needs to be aware of providing a safe environment for the staff they supervise and eliminate concerns from RBTs about providing services if this is the only option.  BCBAs should be aware of Ethical Code area 4.04 Accountability in Supervision.

Considerations for exploration:

• If telehealth is the appropriate service modality for a client’s level of need, and the funder allows for billing telehealth, consider requesting case consultation from an out of area provider. 
• At minimum, a discussion of options needs to be had between the owner, BCBA, HR and potential technicians and informed consent should be drawn from parties employed. 
• The committee acknowledges that any breach in the BACB Ethics Code is reportable to the Arizona State Licensure Board. 

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

• RBT: 1.10 
• BCBA: 1.10, 1.12, 1.13, 1.14

Scenario

“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: https://psychboard.az.gov/investigations

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)

Scenario

“When maintaining your RBT certificate, is it against ethic code for an RBT to become a “LEAD” RBT within a company that they work for? Job duties would include: The role of the Lead RBT is to assist in the planning, development, implementation, and monitoring of behavioral supports to meet the needs of students diagnosed with Autism Spectrum Disorders (ASD) and/or other behavior, social, and/or communication challenges. Provide Support to fellow RBT’s while still under the direct supervision of a BCBA. To assist in New RBT’s with the 40/hour course, as well as working with a BCBA to complete direct treatment plans? Any insight on this topic would be truly helpful.”

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

More information would be needed in the above submission to provide more explicit pathways for exploration.  We would encourage the person who submitted this concern to flush out the context and provide additional details if additional guidance is needed.

Many agencies may determine that a “Lead RBT” is an appropriate use of an RBT who shows high quality performance and leadership skills.  This role may be used to mentor new staff, assist with assessments and guide fellow technicians on selecting appropriate stimuli for targets.  It should be noted that no client guidance should be done without the explicit training and supervision of the BCBA assigned to the case.

To address the RBT’s concerns, some areas to orient toward in the RBT 2.0 Ethics Code are:

• 1.03 RBTs only provide services under their RBT certification within a clearly defined role under close, ongoing supervision. 
• 1.05 RBTs do not knowingly make false, misleading, or exaggerated statements about their qualifications or behavior technician services. They provide a current and accurate set of relevant credentials to employers and supervisors upon request. 
• 1.06 RBTs provide behavior-technician services only after their supervisor confirms that they have demonstrated competence. They work with their supervisor to continually evaluate their competence. If an RBT identifies that they are being asked to do something that goes beyond the scope of their certification and/or competence, they immediately inform their supervisor or other appropriate individuals at their place of employment and document this communication. 
• 2.02 RBTs follow the direction of their supervisors, accurately implement behavior-technician services, and accurately complete all required documentation (e.g., client data, billing records). 
• 2.04 RBTs do not use unfamiliar interventions or provide services to unfamiliar client populations unless they have received proper training

To consider the BCBA’s role, they should consider the following Ethics Code areas for Behavior Analyst’s when determining how to utilize staff for support:

• 2.01 Providing Effective Treatment 
• 2.13 Selecting, Designing, and Implementing Assessments 
• 2.14 Selecting, Designing, and Implementing Behavior-Change Interventions 
• 2.15 Minimizing Risk of Behavior-Change Interventions 
• 2.16 Describing Behavior-Change Interventions Before Implementation 
• 3.01 Responsibility to Clients 
• 3.11 Documenting Professional Activity 
• 4.04 Accountability in Supervision

Considerations for exploration:

• If an RBT has been asked to be a Lead Technician without explicit training in each area that involves a client, the RBT should reach out to the BCBA to discuss their role. All treatment plans fall under the BCBA’s license and require informed consent from caregivers. 
• If an RBT is asked to progress the goals from the treatment plan, the BCBA should be reviewing and approving changes or updates and providing a training on the next steps of implementation to the Lead and then checking during in-person supervision to ensure everyone on the team is correctly implementing. If the RBT is asked to add new goals or do trainings without explicit oversight, they should refrain to ensure they are not violating the RBT Ethics Code 2.0. 
• Arizona Revised Statutes dictates who can call themselves a Behavior Analyst and what is required of service provision. 

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

• RBT 2.0: 1.03, 1.05, 1.06, 2.02, 2.04 
• BCBA 2020: 2.01, 2.13, 2.14, 2.15, 2.16, 3.01, 3.11, 4.04 
• ARS 32-2091.3, 32-2091.4, 32-2091.5, 32-2091.12(p), 32-2091.12(q)

Scenario

“What are the current AZ State Statutes regarding providing behavior analytic services through Telehealth? As long as the practicing Behavior Analyst holds an Arizona license, is it legal to provide all supervision through telehealth?”

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

More information would be needed in the above submission to provide more explicit pathways for exploration.  That said, various support options are outlined below.  We would encourage the person who submitted this concern to flush out the context and provide additional details if additional guidance is needed.

If the submitter is asking if telehealth is an appropriate method for client supervision, the LBA providing the service must consider the magnitude of any problem behavior, the level of hands-on training provided to the behavior technician, and the initial service requested of the funder.

• If the funder did not specify telehealth as an option for reimbursement, consider A.R.S. 32-2091 12 (a), obtaining a fee by fraud or misrepresentation. The LBA would need to contact the funder to request a change in place of service and may not be in compliance with the Ethics Code 2.06 Accuracy in Service Billing and Reporting, and 3.12 Advocating for Appropriate Services. 
• If the client is engaging in dangerous behavior and/or staff has not had in-person training with a supervisor, this could be a violation of A.R.S. 32-2091 12(e), gross negligence in the practice of a behavior analyst. 
• In addition, they may also consider Ethics Code 2.01 Providing Effective Treatment, 2.19 Addressing Conditions Interfering with Service Delivery, 3.01 Responsibility to Clients, 3.03 Accepting Clients and 3.12 Advocating for Appropriate Services, 4.04 Accountability in Supervision, and 4.06 Providing Supervision and Training. 

In the event that the submitter is asking about funder requirements:

• The LBA will need to refer to their specific contracts about the ability to perform telehealth as a billable service. Billing for a service that is not allowable in the service contract could be a violation of A.R.S. 32-2091 12 (a), obtaining a fee by fraud or misrepresentation and the LBA may be required to reimburse the funder for payment. 

Considerations for exploration:

• If telehealth is the appropriate service modality for a client’s level of need, and the funder allows for billing telehealth, no changes are necessary. 
• If telehealth is the most convenient service modality but does not meet the needs of the client or technician, consider referring to a provider who has the availability to meet the client’s needs within funder requirements. 
• If this is a concern about a BCBA not meeting the needs of the client, first seek out additional information from that BCBA about clinical recommendations for the client. If a needs assessment was not provided for the client and the needs of the client are not being met, it would be appropriate to discuss concerns with the supervising BCBA. 
• 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. 
• Always review your contract for billing allowances and be aware that individual plans may differ within the specific funder.

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

• 2.06, 3.12 
• 2.01, 2.19, 3.03, 3.12, 4.04, 4.06 
• A.R.S. 23-2091 12(a)/12(e)

Scenario

“I am having a disagreement with management at my company and would like some guidance. I believe that stakeholders are entitled to their child’s treatment plan in order to know the goals that are working on and current progress. When I meet with them we discuss the goals and progress together, they sign a copy and keep a copy. My company is telling me that they need a release of information to gain access to their child’s treatment plan and even then I can only give them a summary.”

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

The committee recommends that the reportee review, in accordance with Ethics Code 2.04, Disclosing Confidential Information. The Ethics Code statute states, Behavior Analysts may share confidential information when informed consent is obtained – confidential information may be released about the client and stakeholders, among others.  In this example, the ‘client’ represents The direct recipient of the behavior analyst’s services, while ‘stakeholder’ would represent the legal guardian of the client.

If the stakeholder in question is the client’s legal guardian, they are entitled to a thorough description of the entire scope of treatment including but not limited to client assessment procedures, therapeutic interventions, ongoing data collected, results from progress monitoring and ongoing, detailed documentation of services provided (Codes 2.08, 2.09, 2.14, 3.11).  Failure to provide information in an accessible manner could be considered a breach of these ethical codes on the part of the practitioner as well as a direct violation of Arizona Revised Statute 32-2091 under 12s of unprofessional conduct wherein client records are required to be made available promptly when requested.

Considerations for exploration, 

• the stakeholder is not the client’s legal guardian –  it may be required to obtain additional consents for sharing the information. 
• The same is true if the client is their own legal guardian and has not consented to the sharing of their private medical information. 

Further, the committee acknowledges that any breach in the BACB Ethics Code is also 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 implementing the policy, if mediation using other more informal methods does not yield an improved result.

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

• 2.04, 2.08, 2.09, 2.14, 3.11 
• A.R.S. 32-2091 (12) S

Scenario

“I work in an ABA clinic and a coworker seems to have multiple relationships with a specific RBT. They spend time in the BCBA office on down time, chatting regarding personal information/situations. Other RBT’s spend their time in the designated staff break room and do not have the same access to the BCBA office as the aforementioned RBT."

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

This specific scenario did not outline the role of the BCBA regarding the RBT, so more information is needed to determine if an Ethics violation has potentially occurred.

If the BCBA and RBT are not engaged in a supervisory relationship and do not provide services to the same client, this may be an organizational issue about workplace culture.  If that is the case, we recommend the author speak to their workplace HR representative about the concern, and equity among technicians.  The committee also acknowledges that there is value in speaking to the BCBA directly about the situation in accordance with the Core Principles of the Ethics Codes, “Benefiting Others”.  In this sense, all BCBAs are compelled to protect the welfare of individuals they professionally interact with, consider both the short- and long-term effects of their professional activities, actively identify potential/actual conflicts of interest, and actively identify and address factors that might lead to conflicts of interest, misuse of their position or negative impacts on their professional activities.

If the BCBA is providing case supervision to the RBT, or listed as their responsible supervisor, this may be a breach of the following codes:

1.03 accountability
1.10 Awareness of Personal Biases and Challenges
1.11 Multiple Relationships &
4.04 Accountability in Supervision.

In this case, the committee recommends that the author speak to the BCBA in question to advocate for the level of supervision of technicians that is commensurate with ethical standards.

In alignment with BACB standards, the Board advises that complaints be lodged with the potential offender first to gather more information and provide an opportunity to address the response before bringing it to the level of a formal complaint.  The committee encourages the author to explore the following steps as options; this should not be considered legal employment advice:

1. Discuss responsibilities to abstain from multiple relationships with the BCBA and administration, educating them on and outlining our ethical codes of conduct surrounding supervision standards and ethical requirements.
   1. If there is no supervisory relationship between the two, provide suggestions on organizational procedures to protect from a violation between supervisees and supervisors.
   2. If there is no supervisory relationship between the two, consider providing suggestions about making all spaces available to technicians and not disallowing RBTs from certain areas based only on their credentials.
   3. If a supervisory relationship does exist, document the discussion and concerns and provide a clear statement for follow-up.
2. If meaningful change is not made to satisfy the ethical code of conduct, the BCBA should consider sending their letter to the Arizona Board of Psychologist Examiners and Behavior Analyst Certification Board if the BCBA is identified as the responsible supervisor.

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

If the BCBA is providing case supervision to the RBT, or listed as their responsible supervisor, this may be a breach of the following codes:

• 1.03 accountability 
• 1.10 Awareness of Personal Biases and Challenges 
• 1.11 Multiple Relationships & 
• 4.04 Accountability in Supervision. 

In this case, the committee recommends that the author speak to the BCBA in question to advocate for the level of supervision of technicians that is commensurate with ethical standards

Scenario

A Licensed BCBA was recently charged with a DUI in another state. This was a first offense, no other persons were involved, and no damage to the vehicle occurred. This incident was not related to behavior analytical services, clients, or involved in the profession in any way. This person has notified the AZ Board of Psychologist Examiners and per self-disclosure considerations, has not reported alcohol abuse or mental health/substance abuse condition(s). Per the self-reporting guidance listed by the BACB, the DUI citation did not exceed the $750 fine that must be reported and with the current court date pending, there is not a current conviction. At what point, if any, does this person need to self-report to the BACB?

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

In accordance with the BACB’s BCBA Handbook  (https://www.bacb.com/wpcontent/uploads/2022/01/BCBAHandbook_220713.pdf), the following would apply as reportable to the Board:

1. Public health and safety tickets, citations, or fines greater than $750 (USD or equivalent) or of any amount if the situation involved or occurred in the presence of a client (page 42).
2. Criminal or civil suits in which you have been found guilty, have entered a plea of no contest, or have otherwise been sanctioned related to a misdemeanor or felony involving public health and safety or the delivery of behavior analytic, health-care, educational, or other human services (this must be reported within 30 days of becoming aware of the criminal or civil suit) (page 42). 

Once a decision from the court is made, the individual can follow the BACB’s guidance on whether this is reportable or not to the BACB. 

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

Application of the Code does not extend to behavior analysts’ personal behavior unless it is determined that the behavior clearly poses a potential risk to the health and safety of clients, stakeholders, supervisees, or trainees.  This would not be an ethics violation unless the person continues to practice without following guidance of the state licensing committee.

Scenario

“There has been an uptick in ABA agencies posting that they will diagnose children with Autism if the child does not already have a diagnosis. I’m concerned about the field confusing competence within a scope with receiving some continuing education in another area. There are only a few levels of physicians that can diagnose (normal pediatricians do not have this ability), so for a BCBA to go through a minimal training course and feel they are equipped to perform a diagnostic evaluation without a supervising (diagnosing) physician overseeing the entire process is unethical and does a great disservice to clients. I’ve seen reports from these agencies go out to non-contracted diagnosing physicians hoping for a stamp of approval, but without the diagnostician seeing the actual child, that would be unethical at best and a license revocation at worst. I think these agencies state their purpose as an aid to help alleviate the diagnosis delay, but by using BCBAs to do this, it’s doing nothing more than adding additional charges to clients on top of the diagnostician they will have to go to to get an actual diagnosis. Normal BCBA training does not cover child development, counseling families on receiving diagnoses or any training on diagnostic evaluations.”

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

In accordance with Ethics Code 2.04, the committee recommends that the author reach out to the BCBA(s) sending out confidential test results to advocate for appropriate adherence to HIPAA and protection of clients.

In accordance with Ethics Codes 1.01, 1.05, 1.10, 2.06, 2.12, and 3.01, the committee recommends that the author reach out to the BCBA(s) testing for Autism to advocate for clients to receive only testing directly relevant to providing behavior analytic services that do not require medical and clinical training to perform.  The committee would encourage the author to explore the following steps as options; this should not be considered legal advice:

1. Write a formal letter to the testing BCBA, educating them on and outlining our ethical codes of conduct surrounding client confidentiality, Behavior Analysts’ scope of competency, treatment biases, etc.  Consider providing suggestions to them on ways in which they can support clients getting appropriate diagnoses in the surrounding area to meet best practice standards.
   1. Documentation of concerns can provide a clear statement for follow-up.
2. If meaningful change is not made to satisfy the ethical code of conduct, the BCBA could send their letter along to the Arizona Board of Psychologist Examiners for both Psychologists and BCBAs, the BACB and to state funders for auditing purposes.
   1. If the administration leaders are not behavior analysts, the correction process can still be sent to state licensing boards to ensure that only approved practitioners are providing diagnostic testing to clients. 

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

• 1.01 Being Truthful 
• 1.05 Practicing within Scope of Competence 
• 1.10 Awareness of Personal Biases and Challenges 
• 2.04 Disclosing Confidential Information 
• 2.06 Accuracy in Service Billing and Reporting 
• 2.12 Considering Medical Needs 
• 3.01 Responsibility to Clients

Scenario

“We have been getting numerous ABA Technician applicants who have left a local ABA provider (non BCBA owned). All of them tell similar stories about the lack of supervision and training. All of them report there is only 1 BCBA who works remotely and the clinic goes without a BCBA for 2 weeks at a time. One BT said she was assigned a new client with severe SIB and she wrote programming with the help of the scheduler. She reported the scheduler (not an ABA practitioner) often wrote programming. She also reported that any requests to the owner for ethical supervision were met with hostility and some were fired for bringing up BACB ethical guidelines. All of the BT’s reported that the company will not certify anyone as an RBT because they don’t want to have to adhere to supervision requirements.”

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

In accordance with Ethics Codes 1.02, 1.03, 2.01, 3.01, 4.01, 4.03, 4.04, and 4.06, the committee recommends that the author reach out to the overseeing BCBA in question to advocate for the level of supervision of technicians and clients that is commensurate with ethical standards. The committee would encourage the author to explore the following steps as options; this should not be considered legal employment advice:

1. Write a formal letter to the supervising BCBA and to the executive administration, educating them on and outlining our ethical codes of conduct surrounding supervision, client goal selection, etc.  Consider providing suggestions or resources on ways in which they can support BCBAs in their agency in alignment with best practices in supervision and quality care for clients.
   1. Documentation of concerns can provide a clear statement for follow-up.
2. If meaningful change is not made to satisfy the ethical code of conduct, the BCBA should consider sending their letter to the Arizona Board of Psychologist Examiners, the BACB and to state funders for auditing purposes, if appropriate.
   1. Since it is reported that owners/operators are not behavior analysts, the correction process can still be sent to our licensing board to ensure that services labeled as Applied Behavior Analysis are being examined.

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

• 1.02 Conforming with Legal and Professional Requirements 
• 1.03 Accountability 
• 2.01 Providing Effective Treatment 
• 3.01 Responsibility to Clients 
• 4.01 Compliance with Supervision Requirements 
• 4.03 Supervisory Volume 
• 4.04 Accountability in Supervision 
• 4.06 Providing Supervision and Training

Scenario

“Nap time while in center. Some of our early learner still require naps. The concern is that as the client is napping, the company is not billing during nap time which clinicians believe is consider a dual relationship as it is “babysitting” while the client is sleeping.”

Possible solutions:

• Sending the client home.
• Ending services and fading in/out naps

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

The committee appreciates the diligence to the Ethics Code; based on the information offered we are not able to support a determination that this constitutes a multiple relationship for the client-therapist dyad.

The committee recommends the author contact their leadership for organizational policy guidance on how to best approach related concerns about clinician time.

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

• 2.12 Considering Medical Needs 
• 1.11 Multiple Relationships