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Unlicensed, Certified BCBA Provide Supervision

Post Series: Ethics Scenario Archive


There are currently 3 BCBAs on the staff at my current site. 2 of the BCBAs are licensed and one of us is working on getting licensed, we are all certified. The 2 BCBAs that are licensed are relatively new to this site and have not mastered the work that we do. We have a few supervisees that require supervision. Per the BACB, a supervisee is expected to have 2 client observations supervised as well as individual supervision meetings. Is it ethical to have the unlicensed but certified BCBA who is an expert in session run client observation audits while the other 2 BCBAs provide independent and group supervision on the task list that they are experts in? Currently we are having only the licensed BCBAs provide supervision. However, this is leading to staff burn out and may not be appropriate according to 5.01 and 5.04 ethical compliance codes.


  • Codes to Consider: 5.01, 5.02, 5.03, 5.04, 5.05
  • Steps to Explore: The credentialing LBA vs BCBA doesn’t appear to be an ethics concern as long as the nature of the supervision and consequences of such are disclosed to the supervisee; it would fall under a barrier to licensure. The hours by the unlicensed person would not count pursuant of licensure in AZ. Those hours would have to be accrued under an LBA when acquiring licensure. However, delegation of tasks in relation to supervisor scope of practice and scope of competency should be taken into consideration. Unlicensed BCBA can still support supervisees in areas of expertise (outside of formal supervision). Assess appropriate supervisee volume/capacity- provision of effective supervision.
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