Ethics Guidance for ABA Providers During COVID-19 Pandemic

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.


March 19, 2020 (Modified June 10, 2020)

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 Professional and Ethical Compliance 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. Section 2.0, Behavior Analysts: Responsibility to Clients, states: "Behavior analysts have a responsibility to operate in the best interest of clients." Section 2.04(d) states: "Behavior analysts put the client's care above all others."

Section 1.04(d) 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 4.07(b) of the Code. Essentially, the social distancing requirements could be deemed "environmental conditions [that] hinder implementation of the behavior-change program." Accordingly, certificants must "seek to eliminate the environmental constraints, or identify in writing the obstacles to doing so." 4.07(b). 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). For more information on these categories, please see the following resources: https://www.cdc.gov/coronavirus/2019-ncov/specific-groups/high-risk-complications.html and Appendix A in https://www.cdc.gov/coronavirus/2019-ncov/downloads/community-mitigation-strategy.pdf. 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

  • Section 2.15, Interrupting or Discontinuing 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 (1.04(d) 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

BACB Examinations at Pearson VUE

August 12, 2020 Update:

Pearson VUE testing center availability has been changing on a daily basis due to the COVID-19 pandemic. In addition, many testing centers that have opened are operating at a reduced capacity to implement social distancing measures (including the required use of masks). For the latest information regarding Pearson VUE testing centers and availability, please visit the Pearson VUE website.

Individuals who held an examination authorization in May 2020: We extended the expiration date of your examination authorization due to Pearson VUE testing center closures during the entire month of May 2020. If you did not receive an extension and held an examination authorization during that time, please review the Administrative Appeals Policy and file an appeal.

We continue to monitor this situation closely. To reach a customer service representative, please use our online Contact Us form.


 

April 27, 2020 Update: On May 1, 2020, Pearson VUE will begin reopening testing centers in areas that permit operation. Testing centers will open at a reduced capacity in facilities that can be equipped with appropriate social distancing measures (including the required use of masks). Please visit the Pearson VUE website for further details and scheduling.


March 18, 2020 (Modified August 12, 2020)

On March 16, 2020, Pearson VUE made the difficult decision to close all Pearson VUE–owned testing centers in the U.S. and Canada for a minimum of 30 days in response to the COVID–19 pandemic. Many other countries have closed their testing centers as well. For the latest information regarding Pearson VUE testing centers, please visit the Pearson VUE website.

Pearson VUE's decision was primarily based on guidance from the Centers for Disease Control and Prevention, which now recommends that no more than 10 people congregate in the same physical space in an effort to help contain the COVID–19 pandemic. We understand the closure of Pearson VUE testing centers presents a hardship for our certificants and consumers of ABA services. We will continue to monitor the situation closely and provide guidance to all those unable to test in the weeks ahead.

Individuals who hold a current examination authorization: We will extend the expiration date of your examination authorization by the number of days Pearson VUE testing centers are closed and you are unable to test. If you receive an automated email from the BACB that includes the date of your authorization expiration (e.g., reminders, expiration notices), please be aware that date will be adjusted once we know when Pearson VUE testing centers will reopen. Should your examination authorization expire during this period, we will reinstate it based on the number of days testing centers are closed and you are unable to test. This applies to all BACB testing candidates regardless of location.

Individuals who have submitted or will soon submit a BACB certification application: We will continue to process applications. If your application is approved, please disregard the examination authorization expiration date you receive in your approval email from the BACB. We will adjust the date your examination authorization expires once we have more information regarding the availability of testing.

We continue to receive inquiries about potential modifications to our standard testing practices, including whether candidates may test at other venues or in a remote environment. Because the BACB contracts solely with Pearson VUE, testing at other venues is not permitted. It is also likely impossible given that many other testing vendors are closing in response to the COVID–19 pandemic. Finally, due to our stringent examination security requirements and standards, we are unable to offer remote examination delivery at this time.

Again, we will continue to monitor this situation closely. While we have implemented remote operations to ensure the health and safety of all BACB employees, we remain operational and continue to process applications and respond to emails. To reach a customer service representative, please use our online Contact Us form.

COVID-19 Update from the BACB

March 18, 2020 Update: In response to the COVID–19 pandemic, Pearson VUE has closed all its testing centers in the US and Canada. Please visit the Pearson VUE website for the latest updates and to reschedule your BACB examination for a later date. You can cancel up to 24 hours before your scheduled examination without being charged a cancellation fee.


March 17, 2020 (Modified August 12, 2020)

The COVID–19 pandemic has implications for every aspect of society. Given this unprecedented situation and the impact it will continue to have on our certificants, clients, families, and trainees, we are offering the following information for BACB certificants and trainees in a number of areas related to our requirements.

Experience, Fieldwork, and Supervision for Trainees, RBTs, and BCaBAs

Our certification requirements were developed to provide flexibility in how they are met across a variety of conditions. In special circumstances, however, we have a compassionate–exception appeals process in which reasonable deviations that still meet the intent of our requirements may be accepted. This process may include greater leniency around specific requirements that involve interactions with clients (e.g., number of trainee- or RBT–client observations, minimum number of experience hours in a month). It is particularly important that you keep detailed documentation in the event you are subject to a BACB–requirements audit. That documentation should include information about how the pandemic impacted your services, supervision, etc., and the steps you took to try to meet the requirements. Finally, we encourage every BACB certificant and trainee to seek guidance from their supervisors about how supervision and service delivery might be impacted in the weeks ahead. Please see the “Temporary Allowances for Experience/Fieldwork and Competency Assessments” COVID–19 update for more information.

Examinations

Pearson VUE has implemented additional safety procedures and is providing regular updates to ensure the safety of our candidates. Remember that all BACB examinations are available on demand and you can schedule your examination for a later date. Additionally, you can cancel up to 24 hours before your scheduled examination without being charged a cancellation fee.

Continuing Education

The number of recent conference cancellations and the use of social distancing measures might impact how some of you with upcoming recertification dates were planning to obtain continuing education. Although we can't recommend specific continuing education providers, please note that there are many options available online. In addition, the new CEU requirements implemented in January 2020 no longer restrict types of CE activities, so some of you might be able to earn CEUs from other sources.

Application Submissions

Because mail service and processing may be impacted by changes to delivery timelines, the more information you submit electronically, the better.

Finally, we have implemented measures to ensure the health and safety of our employees, including remote work for employees beginning on March 17th. Although we have discontinued phone–based customer service during this period, we will continue to process applications and respond to emails. To reach a customer service representative, please use our online Contact Us form.