COVID-19 Waivers Retired

In April of 2020, we released two temporary waivers in response to the COVID-19 pandemic:

  • Compassionate Exception Attestation for Experience/Fieldwork: We temporarily waived the observation-with-a-client requirement for trainees accruing experience or supervised fieldwork hours without access to clients.
  • Compassionate Exception Attestation for RBT Initial and Renewal Competency Assessments: We temporarily allowed with-a-client tasks to be assessed in role-play situations with client surrogates.

Now, with the advent of widely available COVID-19 vaccines and evidence that organizations have adapted their policies, these waivers are no longer in effect. Here is what this might mean for you:

  • For those who used the experience/fieldwork waiver, any experience or supervised fieldwork hours accrued on or after January 1, 2022, must meet the observation-with-a-client requirement. Be sure to retain the completed and signed attestation and, if audited, submit the attestation to the BACB.
  • For those who used the RBT Initial and Renewal Competency Assessments waiver, all with-a-client tasks documented on materials submitted on or after January 1, 2022, must be performed as stated in the Competency Assessment instructions.

Thank you for your understanding. If you have any questions or concerns, please visit the Contact Us web page.

COVID-19 Vaccine Considerations for BACB Certificants

March 21, 2022, Update: The following information was based on sections 1.01, 2.02, and 2.05 of the Professional and Ethical Compliance Code for Behavior Analysts and has since been updated to reflect the Ethics Code for Behavior Analysts.


The BACB commends all of its certificants who have endeavored to place the safety and needs of clients and staff at the forefront of their action plans to address the COVID-19 pandemic. The following information is being provided to our certificants as they make critical decisions about accessing COVID-19 vaccines.

The BACB offers the following considerations as certificants begin to move forward in the wake of newly available vaccines for COVID-19. This information does not constitute legal or medical advice, but it is consistent with the following standard from the Ethics Code for Behavior Analysts:

  • 3.01 Responsibility to Clients: “Behavior analysts act in the best interest of clients, taking appropriate steps to support clients’ rights, maximize benefits, and do no harm. They are also knowledgeable about and comply with applicable laws and regulations related to mandated reporting requirements.”

Certificants should also consider the recent guidance provided by the American Medical Association (AMA) Council on Ethical and Judicial Affairs for physicians from the November 2020 AMA Special Meeting. Specifically, the AMA (n.d.) states that:

  • “When … there is an available, safe, and effective vaccine, physicians have a responsibility to accept immunization absent a recognized medical contraindication or when a specific vaccine would pose a significant risk to the physician’s patients.”
  • “Physicians who are not or cannot be immunized have a responsibility to voluntarily take appropriate action to protect patients, fellow health care workers and others … including refraining from direct patient contact when appropriate.”
  • “Physician practices and health care institutions have a further responsibility to limit patient and staff exposure to individuals who are not immunized, which may include requiring unimmunized individuals to refrain from direct patient contact.”

The BACB urges certificants to consider the AMA’s guidance when making personal decisions and creating organization-level policies about accessing COVID-19 vaccines. Should the BACB receive a Notice of Alleged Violation related to this topic, the review committee would likely consider the following questions in determining whether a violation occurred:

  • Was there a vaccine available to reduce the negative impacts of the pandemic?
  • If the certificant could not be safely immunized or refused the vaccine for personal reasons, did they take and follow appropriate actions to protect clients, stakeholders, co-workers, supervisees, trainees, and others from potential exposure?
  • If the certificant was responsible for organization-level practices, did they take appropriate measures to protect clients, stakeholders, co-workers, supervisees, trainees, and others from exposure to nonimmunized individuals?

Reference

RBT Remote Testing Restrictions

When in-person testing was restricted due to the COVID-19 pandemic, the BACB sought approval from its accrediting body to participate in an exception program that offered flexibility for RBT candidates by permitting remote testing, with the understanding that additional data collection and security measures would be required. Remote testing became available for the RBT certification program on April 15, 2020.

On March 1, 2021, in response to typical examination-security concerns associated with remote testing, the BACB began restricting remote testing in select geographic regions as needed. If remote testing does not appear as an option at the time of examination-appointment scheduling, it is due to these restrictions, and in-person testing will still be available.

Frequently Asked Questions

Remote testing was approved in 2020 by the NCCA in response to the COVID-19 pandemic. Maintaining this examination-delivery method requires additional security measures, including restrictions when necessary, to meet the security requirements for the administration of high-stakes examinations.


The BACB continually monitors data from all of our examinations. When suspicious scores in any geographic region reach a particular threshold, we restrict access to remote testing in that region for an undetermined period of time to prevent lapses in examination security.


RBT candidates will be aware of the restriction at the time of scheduling their examination. If remote testing does not appear as an option at the time of examination-appointment scheduling, it is due to these restrictions, and in-person testing will still be available.


As an RBT Supervisor, you will need the help of the RBT candidates under your supervision to determine whether they are in a restricted area. Because restricted areas are updated regularly, the BACB is not able to provide additional information about geographic regions to supervisors or RBT candidates.

 

Online Proctored Testing Now Available for RBT Candidates

March 21, 2022, Update: RBT remote testing restrictions are now in place. See the RBT Remote Testing Restrictions post for details.


On April 15, 2020, live, online proctored testing became available for all RBT candidates via Pearson VUE’s online delivery system, OnVUE.

With advanced features that include ID verification, session monitoring, browser lockdown, and recordings, the OnVUE platform includes security features that are necessary for remote testing. RBT candidates should note the following important information:

  • Once a candidate’s application for certification is approved, they will receive a link to schedule their remote, proctored certification examination with Pearson VUE per the usual examination scheduling process.
  • Candidates who request accommodations for the RBT certification examination must test at in-person Pearson VUE testing centers; the OnVUE platform is unable to provide candidates with testing accommodations other than adjustable font, extra time, and color contrast.
  • Pearson VUE strongly recommends using a high–speed internet connection for online testing and encourages candidates to test during less popular wireless access times. Bandwidth issues greatly affect the delivery of online testing, and such issues are beyond Pearson VUE’s‚ and the BACB’s‚ control.

Guidance for RBTs During COVID-19

The COVID–19 pandemic continues to raise a lot of fear and questions for many people around the world and our RBTs are no exception. First, rest assured that you’re not alone during this challenging and unprecedented time. We’re doing our best to offer guidance that allows you to make sound decisions about your livelihood and enables you to maintain your certification while responding to your questions as quickly as we can. We encourage all RBTs to take a moment to review the following information.

RBTs Who Are Unable to Provide ABA Services

If you’ve been furloughed or lost your job because of the pandemic, you do not need to report this to the BACB. Also, you will not lose your certification just because you’re not working. One of the RBT maintenance requirements is to receive ongoing supervision for 5% of the hours that you provide behavior analysis services. However, if you’re not providing or billing for services, you don’t need supervision for the month and your certification will remain active as long as you still have an RBT Supervisor or Requirements Coordinator on record with us.

RBTs Who Are Providing ABA Services

If you’re currently able to provide services, you must meet the RBT supervision requirements. It’s very important to maintain detailed documentation in case you’re asked to complete a BACB requirements audit. That documentation should include information about how the pandemic has impacted your services, supervision, etc., and the steps you and your supervisor took to try to meet the requirements. While there’s no need to report these details to us right now, you should document them now and report them to us when you submit your annual RBT Renewal Application.

RBTs Who Don’t Anticipate Using Their Certification Soon

If you don’t expect to use your RBT certification any time soon, you can apply for voluntary inactive status. While on voluntary inactive status:

  • your certification is listed as “inactive” on the Certificant Registry
  • you may not practice, bill, or represent yourself as an RBT
  • you don’t need to submit renewal applications
  • you may remain inactive for up to two years
  • you must complete the RBT Request to Return from Voluntary Inactive Status form when you’re ready to reactivate your certification
Please note: You may not reapply for voluntary inactive status until you have completed at least one renewal cycle after returning from voluntary inactive status. Voluntary inactive status is beneficial because it allows you to pause your certification. When you’re ready to reactivate it within the two years you are allotted, you don’t have to meet all of the eligibility requirements again.

RBTs Who Are Due to Renew Their Certification Soon

If your RBT certification renewal is coming up, a process that includes completing the RBT Renewal Competency Assessment, and you are practicing, coordinate with your supervisor/assessor about meeting the renewal requirements.

Have Questions About Providing Services?

If you have questions about how to provide services during this time (e.g., whether you can provide telehealth services), speak with your supervisor, employer, and/or professional associations. As a certification board, the BACB cannot provide specific direction or recommendations on these topics.

BACB to Offer Online Proctored Testing for RBT Candidates

March 21, 2022, Update: RBT remote testing restrictions are now in place. See the RBT Remote Testing Restrictions post for details.


April 14, 2020, Update: Effective April 15, 2020, live, online proctored testing will be available for all RBT candidates via Pearson VUE’s online delivery system.


The BACB will temporarily offer live, online, proctored testing for its RBT candidates through Pearson VUE’s online delivery system, OnVUE. This option will be available for RBT candidates while Pearson VUE’s in–person testing facilities are closed due to the COVID–19 pandemic. The BACB is currently working with Pearson VUE to implement this delivery model and will announce the date it is available in the near future.

The BACB’s decision to offer remote proctored testing for RBT candidates follows the National Commission for Certifying Agencies’ (NCCA) announcement on March 20, 2020 that it will allow the use of remote–proctor testing delivery on a limited basis for organizations with accredited programs such as the BACB. The NCCA’s announcement is in response to an urgent need for credentialing programs to make testing available following the closure of many testing centers worldwide due to the COVID-19 pandemic.

The NCCA recently approved the BACB’s application to offer remote testing for its RBT certification — each certification requires a separate application — on a trial basis. The BACB’s decision to pursue remote testing for the RBT certification while Pearson VUE’s in–person testing centers are closed is because the maximum length of the RBT certification examination — 90 minutes — allows the BACB and Pearson VUE to help ensure a fair testing experience for all candidates. Unfortunately, the BACB cannot guarantee such an experience for candidates taking the BCBA and BCaBA examinations, which, at four hours in length, require heightened security and accessibility at a time when wireless Internet traffic has reached unprecedented levels.

With advanced features that include ID verification, session monitoring, browser lockdown, and recordings, the OnVUE platform includes security features that are necessary for a trial of remote testing for RBT candidates during this challenging and unusual time. Once an RBT candidate’s application for certification is approved, they will receive a link to schedule their remote, proctored certification examination with Pearson VUE per the usual examination scheduling process. As part of this pilot program, BACB psychometricians will closely monitor all data associated with remote testing, which will then be used by the NCCA to determine whether to allow the BACB to continue to offer remote delivery of RBT certification examinations in the future.

PLEASE NOTE: RBT candidates who request accommodations for the RBT certification examination will need to wait until Pearson VUE reopens its physical testing centers; the OnVUE platform is unable to provide candidates with testing accommodations other than adjustable font and color contrast. Additionally, Pearson VUE strongly recommends using a high–speed internet connection for online testing and encourages candidates to test during less popular wireless access times. Bandwidth issues greatly affect the delivery of online testing and such issues are beyond Pearson VUE’s and the BACB’s control.

For further information, listen to our podcast.

Ethics Guidance for ABA Providers During COVID-19 Pandemic

March 21, 2022, Update: The following information was based on the Professional and Ethical Compliance Code for Behavior Analysts and has since been updated to reflect the Ethics Code for Behavior Analysts.


June 10, 2020, Update: Additional resource added from the Michigan Taskforce.


March 20, 2020, Update: We have updated the following information to provide a revised description of individuals who may be at increased risk of becoming very ill during the pandemic. The revised statement also clarifies the guidance provided to support certificants in making decisions around service provision. It is important to remember that the BACB cannot issue a blanket directive to continue or discontinue services due to the complexity of each individual situation and client.


Because the COVID–19 pandemic is particularly impactful on vulnerable populations and their service providers, we offer the following information to our certificants as they make critical decisions about service delivery during this difficult time. Please keep in mind that this information does not constitute legal or medical advice.

First, we extend our gratitude to the many BACB certificants who had contingency plans in place to address service interruptions. We also want to serve as a resource for the many certificants who have contacted us for ethics guidance as they seek to develop and modify contingency plans consistent with the Ethics Code for Behavior Analysts (Code) during the pandemic. The Code is primarily focused on ensuring that high–quality services are delivered in a safe manner. Throughout the Code, it is clear that the primary directive is to do no harm to clients. Standard 3.01, Responsibility to Clients, states: “Behavior analysts act in the best interest of clients, taking appropriate steps to support clients’ rights, maximize benefits, and do no harm. They are also knowledgeable about and comply with applicable laws and regulations related to mandated reporting requirements.”

Standard 1.02 of the Code makes it clear that certificants must comply with legal requirements, including those related to social distancing and service provision. Recent directives regarding social distancing may create scenarios that are not easily addressed under standard 2.19 of the Code. Essentially, the social distancing requirements could be deemed “environmental conditions (e.g., the behavior of others, hazards to the client or staff, disruptions) that may interfere with or prevent service delivery.” Accordingly, certificants must “remove or minimize the conditions, identify effective modifications to the intervention, and/or consider obtaining or recommending assistance from other professionals” and “document the conditions, all actions taken, and the eventual outcomes” (2.19). This means that if there are barriers to service provision in a particular region or context (e.g., a mandate to engage social distancing, high-risk clients) that cannot be removed or adequately addressed, certificants must document in writing the barriers and steps taken for each client.

As BACB certificants endeavor to uphold the Code and protect clients, we provide the following considerations:

Health and Safety

  • The Centers for Disease Control and Prevention (CDC) currently list the following as groups who may be at increased risk for getting “very sick” during the pandemic: older adults; people of any age who have asthma, COVID–19, or serious underlying medical conditions (blood disorders; chronic kidney and liver diseases; compromised immune systems; current or recent pregnancies; diabetes heart disease; lung disease; metabolic disorders; and neurological, neurologic, and neurodevelopmental conditions).

    Each certificant is responsible for verifying whether a client falls into one or more of these groups to assist in fully determining the risks associated with continuing to provide services in their current form.

  • The World Health Organization and the CDC recommend social distancing to slow the spread of the infection, minimize the risk of infection to those considered high–risk, and reduce the strain on health services and resources. In the United States, the federal and state governments have directed the public to engage in social distancing, schools have closed or moved to online instruction, and many other public services have been limited or temporarily stopped. Similar practices have been enacted in many other countries.
  • The CDC indicates that individuals who are asymptomatic or have yet to display symptoms may expose others to the virus, and because testing is limited, most individuals are unable to verify that they are not infected. This means that service providers or clients who do not appear ill could be spreading the virus.
  • To minimize risk, service providers should consider developing a COVID–19 pandemic risk mitigation plan and implementation policies. The risk mitigation plan may include some of the following elements: regular communication with staff and clients about how to stay safe, telecommuting/telehealth, limits on air travel, attestations about symptoms and exposure, encouraging social distancing, considerations for determining whether to continue/augment/suspend client services, and cancelling services/sessions if clients or service providers are symptomatic or if deemed necessary to comply with social distancing recommendations.

Continuity of Care and Appropriate Transition of Services

  • Standard 3.14, Facilitating Continuity of Services, indicates that certificants must work in the best interest of clients to avoid interrupting or disrupting services. This Code element must be balanced with the overall requirement to not harm clients. Therefore, certificants providing services to vulnerable individuals must first comply with all government mandates (standard 1.02 of the Code). Assuming there are no mandates to the contrary, the service provider must determine if the risk of suspending services (e.g., substantial risk of injury to the client) is greater than the risk of continuing to provide services.
  • If continuing services is deemed appropriate, the certificant must then determine if services can be delivered in a manner that does not unduly increase the risk of exposure to COVID–19 (e.g., enhanced disinfecting protocols, minimizing numbers and points of contact, using protective gear).
  • In the event that services should be suspended in their current form, the next step is to determine if services can be augmented (e.g., provide telehealth services, develop maintenance and generalization programming, create home-based program materials, move to parent consultation via telehealth) to minimize disruptions (i.e., minimize loss of critical skills).
  • If it is determined that services must be stopped, as opposed to augmented, providers should engage in appropriate steps to ensure continuity of care and appropriate transition (e.g., update reports and data, make relevant documents and materials available to caregivers, provide caregivers with a list of other relevant providers).

In summary, certificants must systematically and carefully consider the risks of stopping, continuing as-is, or augmenting services, and then take steps to carry out the decision in a way that minimizes risks to clients, caregivers, and staff and maximizes therapeutic benefits to clients.

As certificants make these difficult decisions, we urge you to follow all laws and public health recommendations from your local health authority and respective governmental agencies. We have compiled a list of resources relevant to the COVID–19 pandemic below. Note that including a resource is not an endorsement of the agency or organization, or the guidance provided by said agency or organization.

The BACB will continue to monitor the evolution and impact of COVID–19 and work to continue supporting the profession during this difficult time. If you have questions, please visit the Contact Us page.

Resources