By: Gabriella Casale
M.S, BCBA, LBA
Beginning back on January 1, 2022, BCBAs and BCaBAs were required to shift gears and adhere to the new codes set forth by the Behavior Analyst Certification Board, re-named from the Professional and Ethical Compliance Code for Behavior Analysts to the Ethics Code for Behavior Analysts.
“2.02 Timeliness: Behavior analysts deliver services and carry out necessary service-related administrative responsibilities in a timely manner.”
ABS uses an electronic, HIPAA-compliant software that allows staff to track actual start and end times of their sessions. These sessions are then transferred to timesheets used for billing through the same program. Aside from this streamlined process, ABS has established policies and procedures that ensure services and administrative activities are carried out in a timely manner. Documentation policies and billing for service hours policies specify the time requirements for creating appointments, modifying schedules, alerting supervisors and caregivers of any scheduling conflicts, collecting data, creating daily progress notes, and converting the timesheet. Policies and procedures are provided in verbal and written trainings for new employees, and any updates are covered in biweekly trainings with current employees. In order to remain up to current standards, our policy has recently been revised to reflect the changes: employees are now required to convert all timesheets within 24 hours of the session (instead of 48 hours). This will ensure that accurate progress notes will be produced, as the information from the session will be fresh in the program implementer’s mind.
“4.05 Maintaining Supervision Documents: Behavior analysts create, update, store, and dispose of documentation related to their supervisees or trainees by following all applicable requirements, including those related to confidentiality. They ensure that their documentation, and the documentation of their supervisees or trainees, is accurate and complete. They maintain documentation in a manner that allows for the effective transition of supervisory oversight if necessary. They retain their supervision documentation for at least 7 years and as otherwise required by law and other relevant parties and instruct their supervisees or trainees to do the same.”
“4.07 Incorporating and Addressing Diversity: During supervision and training, behavior analysts actively incorporate and address topics related to diversity (e.g., age, disability, ethnicity, gender expression/ identity, immigration status, marital/ relationship status, national origin, race, religion, sexual orientation, socioeconomic status.”
From the beginning of a new hire’s journey with ABS, culture and diversity within our company is emphasized. We recognize that all clients and employees come from different backgrounds, and their beliefs, values, lifestyles, and choices are important for us to recognize, understand, and learn more about as a team. Our vision statement expresses our goal to shape communities that are clinically and culturally empowered by our services, and steps to achieve this objective begins with our team members. Thus, we require cultural competency courses to be taken upon onboarding and annually. The topics of these trainings are sprinkled into supervision meetings as natural teaching opportunities present during sessions. We ensure a treatment process that involves a person-centered approach, which includes identifying personal goals by considering cultural, personal, spiritual needs of the client and/or their families. Spiritual and cultural barriers are always assessed at the beginning of treatment so caregivers can specify variables that may impact treatment, and our intervention plans and scheduling will account for these important parts of their lives. The same is considered for our employees, and accommodations are made for celebrations, holidays, and events. We find that a compassionate approach is essential as a foundation for interactions with those we serve and amongst our staff.
“5.01 Protecting the Rights of Clients, Stakeholders, Supervisees, and Trainees: Behavior analysts take appropriate steps to protect the rights of their clients, stakeholders, supervisees, and trainees in all public statements. Behavior analysts prioritize the rights of their clients in all public statements.”
Similar to the steps we follow to ensure clients’ rights, we also strive to protect our employees’ rights. Our policies and procedures have been developed to reflect the importance of prioritizing the rights, responsibilities, and ethics of all individuals served, including clients, stakeholders, supervisees, and trainees. Some main points of the client Bill of Rights include right to dignity and humane care, right to lawful service, right to communication and self-expression, right to privacy, right to access, right to best service practices, right to support, right to make informed choices and decisions in own life, and right to safety and protection. This Bill of Rights is shared with clients and caregivers at intake and annually. Additionally, employees are to abide by our professional code of ethics, which further emphasizes the importance of defending the spirit of the policy on clients’ and stakeholders’ rights. These rights outlined above are also applicable to our supervisees and trainees, and further employee-specific rights are addressed in contracts for RBTs, BCaBAs, and BCBA trainees.
“5.10 Social Media Channels and Websites: Behavior analysts are knowledgeable about the risks to privacy and confidentiality associated with the use of social media channels and websites, and they use their respective professional and personal accounts accordingly. They do not publish information and/or digital content of clients on their personal social media accounts and websites. When publishing information and/or digital content of clients on their professional social media accounts and websites, behavior analysts ensure that for each publication, they (1) obtain informed consent before publishing, (2) include a disclaimer that informed consent was obtained and that the information should be not captured and reused without express permission, (3) publish on social media channels in a manner that reduces the potential for sharing, and (4) make appropriate efforts to prevent and correct misuse of the shared information, documenting all actions taken and the eventual outcomes. Behavior analysts frequently monitor their social media accounts and websites to ensure the accuracy and appropriateness of shared information.”
Behavior Analyst Certification Board. (2020). Ethics code for behavior analysts. Littleton, CO: Author.