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Telehealth Supervision

Ethics Scenario Archive
1. Approaching Former Adult Client
2. Medical Marijuana
3. Pro Bono Work
4. Supervision Has Multiple Relationships with Family Receiving Services
5. Parent Training Concerns
6. Parents Not Implementing Procedures
7. Soliciting Parent Testimonials
8. Retaliation Towards Mandated Reporting
9. Family Rejecting Safety Measures
10. Parental Collaboration
11. Hostile Work Enviornment
12. Creating Protocol to Prevent and Treat Trauma with Limited Functional Language
13. Parent ABA Practice Questions in OT & Speech
14. Potential Gifts From Clients on Social Media
15. Helping Close Relationships With ABA Tips
16. Parent Utilizing CBD & THC
17. Client Pre-Authorization Denied For Much Needed Services
18. Supervisee Slaps Child in School Setting
19. Changing Direction of Treatment from Previous BCBA
20. BCBA Subpoenaed in Family Court
21. Terminate Services Due To Parent Behavior
22. Parents Offering Token Items During Check Out/Transition
23. Family Doesn’t Want Details Released To Funding Source Without Permission
24. Resources for IRB Approval for Independent Researchers
25. Speech Therapist Refusing To Do PECS
26. BCBA Receives Cease & Desist
27. Unlicensed, Certified BCBA Provide Supervision
28. Rapid Prompting Method (RPM)
29. Parent as Witness to Accident
30. Website Testimonials
31. Student Using Social Media Inappropriately
32. Hiring Behavior Analyst Trainees at a School District
33. College Recommendation Letter for Client
34. Connecting Families That Are Clients
35. Employer Requiring Same Number of ABA Hours for All New Clients from New BCaBA
36. Do we have any ethical guidelines regarding shared work spaces among two companies that provide similar ABA services in a private property?
37. Client Assessment & Discontinuation
38. Caseload Concerns
39. Naptime
40. Systemic Supervision Concern – Clients & RBTs
41. BCBA’s Performing Diagnostics
42. Self-Reporting DUI to BACB
43. Multiple Relationship with RBT
44. Refusal to Provide Documentation
45. Telehealth Supervision


“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)
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