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Frequently Asked Questions Concerning
Licensing of Applied Behavior Analysts

1. Will Licensed Applied Behavior Analysts be required to be supervised by Licensed Psychologists?
   • The answer to this question is “no.”  Neither the ABAI Model Licensing Bill nor the MA Licensing Bill includes such a provision.  This would only become reality if the state licensing bill for Applied Behavior Analysts within a state included such a provision.  It is incumbent on those representing the ABAI state affiliate chapter to work to educate legislators against such a provision.
   • However, if one is to accept the apparent position of APA in this matter and accept the premise that Behavior Analysis is simply a sub-component of the profession of Psychology, Behavior Analysts who are not otherwise licensed as Psychologists should be supervised by Psychologists.  The next question that must be answered is: “is a Licensed Psychologist trained to provide appropriate supervision of a Behavior Analyst”?  In answering this question, several objective facts should be considered:
     • First, in a survey of all of the Doctoral programs in Psychology in the New England area (Dorsey, 2007); there was not a single program which would provide a graduate with the necessary coursework or supervised experience to sit for the BCBA certification examination. 
     • Second, the Examination for Professional Practice in Psychology (EPPP) fails to ensure that licensed Psychologists have the required knowledge or skills in the area of Applied Behavior Analysis.  A review of the Examination for Professional Practice in Psychology Content Areas, published by the ASPPB as a quasi “Task List” for individuals preparing for the Psychology licensing examination reveals the exam covers eight content areas, none of which include Applied Behavior Analysis.
   • The experience in Massachusetts regarding this question was that the Massachusetts Psychological Association initially posed this as a model (i.e., that Licensed Psychologists supervise Applied Behavior Analysts).  However, after many hours of negotiations this request was withdrawn by MPA and they choose to remain neutral (not in opposition) to the bill.  One reason for their decision was all of the hard work that was dedicated to gaining the support of most (if not all) of the state advocacy organizations representing persons with disabilities (ARCMass, the Developmental Disabilities Council, the state association for Autism, etc).
2. Will initiating a movement towards the licensing of Applied Behavior Analysts “awake a sleeping giant (AKA, the American Psychological Association)?”
   • While it is true that the filing of licensing bills in various states may come to the attention of the APA, this will not increase the number of people providing ABA services, nor will it take more money out of the pockets of Psychologists.  It is too late for that issue to be considered, with over 5,000 BCBAs providing services around the world now without licensing.
   • The recent actions of the American Psychological Association in proposing their Model Licensing Act to their state chapters appear to suggest that they have identified – real or not – a need to lay claim to certain areas of service or therapy generally regarded as belonging to the field of Applied Behavior Analysis, which they believe are unique to the profession of Psychology.  The motivation of APA appears to include “guild” (i.e., “an association of persons of the same trade or pursuits, formed to protect the mutual interests and maintain standards” American Heritage Dictionary, 2006) issues in which there is a concern that market share for licensed Psychologists would be impacted negatively by BCBAs or others holding themselves out to the public as being qualified to practice applied behavior analysis (without certification or licensure in any regulated profession within a given state).  While it is true that most of the founders, dating back to Watson and Skinner, of the field of the Experimental Analysis of Behavior – the research aspect of applied behavior analysis – graduated from doctoral programs in Psychology and identified themselves professionally as “Psychologists” (although most would have not qualified to be Licensed Psychologists), the field has seen radical changes in the background and training of those who identify themselves as Behavior Analysts.   Many early practitioners of behavior analysis were psychologists, but many others were speech-language pathologists, special educators, psychiatrists, counselors, school psychologists, and even regular educators.  Some were even classically trained psychoanalysts who became frustrated with psychoanalysis.
   • Complicating matters even more is that fact that when times for behavior modification grew difficult, APA rejected behavior modification, (see APA Monitor, 1983) claiming it was dead.  In accords with such a declaration, in 1986, APA dropped the requirement of course work in behavior analysis and behavior therapy from their model licensing act. Such a declaration would seem to eliminate APA’s claim of legitimacy for exclusive control over behavior analysis.
   • According to Shook (2007), the greatest number of Board Certified Behavior Analysts today graduated with a terminal master’s degree in Special Education, not Psychology.  Additionally, while graduates from programs in Psychology comprise the second greatest cohort, the majority of these hold a terminal Master’s degree and not a doctorate.  A review of the total distribution of professions to which BCBA’s belong as members  (including free standing Behavior Analysis Programs, Interdepartmental behavior analysis programs, Speech and Language Therapists, Occupational Therapists, Nurses, Physicians, Criminal Justice Personnel etc.) demonstrates that the BCBAs trained in psychology departments represents only a portion of the total number.  Thus, the training, experience, and professional impact of practitioners of Applied Behavior Analysis have spread well beyond the original field of Watson and his students. Even Watson left academic psychology and pursued a career in advertising.
   • Finally, the number of Board Certified Behavior Analysts now exceeds 5000 worldwide, serving people within the many diverse professional disciplines noted above.  This is not a new field, nor is it one that, if the creation of a licensed standard were allowed to occur, would have an immediate and detrimental effect on the current practice of Psychology, as seems to be the fear of many in the field.  Strategies will be found to ensure that Behavior Analysts will remain in their current jobs, newly trained Behavior Analysts will continue to graduate from training programs, and the field will continue to grow irrespective of whether or not the licensure of Behavior Analysts ever becomes a reality.  And, as such, the financial and professional impact on those Psychologists who are working to control the field of Behavior Analysis will continue. Nor would the development of behavior analysis damage the science. Indeed, it may rejuvenate it.
3. Do practitioners of applied behavior analysis (ABA) have to be licensed to qualify for payment from third parties, such as health insurance plans and government agencies?
   • Currently, as described by Green (2009), there are a limited number of third-party insurance providers who have chosen to allow non-licensed BCBAs to bill for direct services.  However, according to Eric Billington PhD BCBA, Utilization Manager for Applied Behavior Analysis of AmeriChoice (a division of United health Care), this model is changing and will eventually require that Applied Behavior Analysts be licensed to bill for their services.
4. Does holding a license guarantee that a practitioner can obtain third-party payment for his or her services?
   • Holding a license in any human service profession, including medicine, does not guarantee the professional the right to bill a specific third-party insurance carrier for their services.  Insurance carriers establish a “Provider Panel” for each profession based upon the need within a specific geography.  The carriers work to limit the number of approved providers to the minimum that will meet these needs in a cost saving effort.  Qualified providers are required to apply to become a member of the Provider Panel and may or may not be accepted.  However, if the provider does not meet the standards of the carrier, they surely will not be included on the panel.
5. Will licensing ABA practitioners protect consumers from unethical and incompetent practices?
   • The simple answer to this question is “no.”  There is nothing that can be done that would ensure that any professional does not engage in unethical practices.
   • However, a major reason for professional licensure of Applied Behavior Analysts administered by the states is the fact that state Boards of Professional Licensure within each state have the staff and legal authority to respond to complaints by the general public (or other Behavior Analysts) of unethical practices by those who are licensed that the BACB has chosen not to cover.  As the field now exist, neither the Association for Behavior Analysis International (ABAI), nor the Behavior Analysis Certification Board (BACB) has the money, staff, or time to provide this level of ethical oversight, especially with the literally thousands of BCBAs and/or members of ABAI who practice within the United States.  Such investigations must be conducted at the local level, including taking statements; the collection and review of supporting documentation from the complainant, the accused, as well as any witnesses; and requiring the presence of investigators on-site throughout the process of conducting such staff intensive investigations.  Additionally, once an investigation is completed, there may be a need for a formal hearing, which can take several days and include legal representation for both sides, at which the plaintiff, the accused, and investigator would all present their cases to a hearing panel comprised of licensed Behavior Analysts.  Finally, there is the issue of liability on the part of the investigator as well as the members of the panel hearing the case.  Even in cases where the evidence is overwhelming and clearly supports punitive action against the Behavior Analyst, the accused has the right to sue these individuals personally for Restraint of Trade, among other grounds, and has the potential of prevailing in a court of law and being awarded monetary damages.  Members of State Board of Professional Licensure who sit on such panels are generally indemnified by the individual state, within the very act that establishes the original licensure law, protecting them from such personal attacks.  While it is true, as was described by Dr. Shook in a Panel Discussion on this topic at the ABAI conference in 2006, that the BACB does, from time-to-time, engage in such investigations, it was clear that the BACB has neither the money nor staff time to fully investigate all of the complaints they receive.  Taking such a reactive, as opposed to a proactive position, in the protection of consumers fails to meet the needs of the profession or community at large.  As noted on the BACB web site:

     We are concerned that all BACB certificants provide quality services in an ethical manner, and we enforce adherence to the BACB Professional Disciplinary Standards toward that end. We realize that matters may arise that may be of concern to the consumer but not fall under our Professional Disciplinary Standards (for example, the consumer may believe that a certificant is not adhering to one or more items in the Guidelines for Responsible Conduct). However, for a number of logistical reasons, the BACB can only enforce adherence to the Professional Disciplinary Standards, and it relies heavily on information from local responsible sources in reviewing allegations against certificants.

6. Will licensing applied behavior analysts protect their right to practice?
   • If a bill is passed in a given state that includes a comprehensive “Scope of Practice,” the answer to this question is “Yes.”  Under those circumstances, the Licensed Applied Behavior Analyst is guaranteed by law the right to practice within the defined scope of their profession.
7.  Who should determine the requirements for obtaining and maintaining a license to practice ABA?
   • Clearly, Applied Behavior Analysts should lead the decision making process.  However, since the establishment of a licensing law is a legal process, they cannot accomplish this alone.  It is important that the local ABAI state affiliate chapter take the lead in identifying legislators who are sympathetic to their goals and work to educate them in the drafting of an appropriate bill.
8.  Will the Licensing Model Bill no longer require a person to continue to pay the BACB to maintain their certification status once they are licensed?
   • While this is true, the bill also does not require the licensed Applied Behavior Analyst to be a dues paying member of ABAI.
   • It should be made clear that Dr. Shook, representing the BACB, took an active part in the development of the original MA licensing bill and endorsed the bill as long as there was a provision that required Licensed Applied Behavior Analysts to maintain their BCBA status (pay yearly dues to the BACB).  He has also spoken at several conferences (BABAT, 2008) where he supported the concept of licensing Applied Behavior Analysts.
   • This structure is consistent with other professional licensing laws, none of which mandate “membership” in any professional organization.
   • Furthermore, there is no “functional” reason for a licensed ABA to pay a yearly fee to the BACB.
   • In the field of Psychology, the examination for licensure (i.e., the Examination for Professional Practice in Psychology (EPPP)) was created by the Association for State and Provincial Psychology Boards (ASPPB) and is “used by 63 licensing boards across the United States and Canada, to assess candidates for licensure and certification” in Psychology.  The scope of responsibility for this Board, the ASPPB, is limited to the development, modification and administration of the licensure examinations through the state Boards of Registration of Psychologists.  Because Psychologists are “licensed” by their respective states and not the APA or ASPPB, the responsibilities for monitoring things such as continuing education credits falls to the respective Boards of Registration within each state.  It should be noted that to maintain ones licensed status as a Psychologist, one is neither required to join the APA nor maintain any relationship/membership to the ASPPB. 
9. Does the Model Bill remove the BACB from approving CE providers for Licensed ABA?
   • This was a recommendation of the Practice Board for several reasons, including the fact that the scope of practice of a Licensed ABA, as recommended in the Model Bill far exceeds to scope of the BACB, including many other therapeutic and professional practices.
10. Does the Model Bill remove the BACB from managing CE providers for Licensed ABA?
    • This was a recommendation of the Practice Board for several reasons; including the fact that many Licensed ABAs may choose not to continue to pay dues to the BACB once they are licensed.
    • In addition to the administration of certification examinations, the BACB currently approves the providers for and monitors the accrual of continuing education credits by its members.  Unlike the field of Psychology (and many other  professions), certificants who have passed the BACB examination process are required to maintain their association with the BACB by paying an annual fee and submitting statements that they have attained sufficient continuing credits to maintain their certification.  The BACB currently requires of all certificants a “renewal” of their status during the first and second years of their certification and a “recertification” at the end of the third year.  This is a unique relationship between the “certificants” and the BACB, in that they are not actually “members” of the BACB, which is not technically a professional organization as is ABAI, APA, APBA or other similar organizations.  Once licensure is enacted, the individual state’s Board of Professional Licensure will monitor toe accrual of all Continuing Education Credits.
    • The point here is the potential impact on the BACB if states begin to adopt a licensed status for Behavior Analysts and administer this process in a manner similar to that of Psychologists.  That is, it could likely become reality that the role of the BACB would become much like that of the ASPPB, limited to the administration of what would then be a Licensure examination with no ongoing need for licensed Behavior Analysts to remain affiliated with or pay fees to the BACB.  The respective state licensing board would administer all fees for such renewals and/or re-certifications.
11. Does the Model Bill raise the bar for the educational requirements to become licensed?
    • For practitioners of Applied Behavior Analysis to compete with other recognized human service professions, it is critical that we examine the standards required to be considered as practicing Applied Behavior Analysts and take the steps necessary to ensure that our standards are at least on-par with all of the other professions.  At present, the only recognized standards applicable are those of the Behavior Analysis Certification Board ©, which allows an individual to become board certified with as few as 15 graduate credit hours (225 classroom contact hours) of study in applied behavior analysis.  In comparison, in addition to the typical requirement of the completion of a standard number of hours of fieldwork/internship – ranging from 600 to 1200 hours for Master’s prepared candidates and 2000 hours for Doctoral prepared candidates; two years full-time for a Psychologist – and passing an approved examination, states generally require specific educational requirements be met to in order to provide such professional services to the general public.  For example:
      • Occupational Therapists are required to have “successfully completed an accredited occupational therapist educational program approved by the board;”
      • Physical Therapists must “be a graduate of an accredited educational program leading to professional qualification in physical therapy and approved by the board;”
      • Psychologists are required to have “received a doctoral degree in psychology from a recognized educational institution;”
      • Master’s level Mental Health Counselors, must complete a master’s degree in mental health, Psychology, or a related field, with a “minimum of 60 graduate semester hours;”  
      • Educational Psychologists must also complete a master’s degree in Educational Psychology with “60 credits of approved graduate course work.”
    • While none of us doubts the effectiveness of Applied Behavior Analysis, most especially in the treatment of children diagnosed with Autism, it seems clear that we have a long way to go in creating appropriate credentialing standards prior to joining the ranks of the other recognized human services professions.

Please e-mail us at mail@abainternational.org. We will be happy to answer your question and add it to the FAQ page.

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