COVID-19 Waivers Update

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 will no longer be in effect beginning on January 1, 2022. 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.

Temporary Allowances for Experience/Fieldwork and Competency Assessments

Due to social distancing requirements during the COVID–19 pandemic, the BACB will allow temporary deviations for certain "with a client" requirements. As of March 1, the "observation with a client" sub–requirement that applies to Experience and Fieldwork will be temporarily waived for those without access to clients.

In addition, all RBT competency assessments received as of April 28, 2020 will allow "with a client" tasks to be fulfilled via "role play."

To learn more about COVID-19-related changes or news from the BACB, please visit our BACB COVID-19 Updates web page.

Temporary Allowances for Experience/Fieldwork and Competency Assessments

October 1, 2021, Update: As of January 1, 2022, these temporary waivers are no longer in effect.


April 28, 2020 (Modified August 11, 2020)

Due to social distancing requirements during the COVID–19 pandemic, we will provide temporary deviations for the following "with a client" requirements.

  • Experience and Fieldwork ("observation with a client") — As of March 1, and until further notice, we will temporarily waive the “observation with a client” sub-requirement for trainees who do not have in-person access to clients and, thus, are only accruing unrestricted hours. As always, all unrestricted activities must relate to a specific client’s needs.
    If you are a supervisor and you want your trainees to qualify for this temporary exception:
    • You (the supervisor) must complete the attestation for each month impacted.
    • You and your trainee must keep this document in your records.
    • In the event of a future audit, this form must be submitted for any of the qualifying months that were impacted.
    • RBT Competency Assessments ("with a client" tasks) — For all initial and renewal competency assessments received as of April 28, 2020, and until notified on the BACB's COVID–19 Updates page, we will temporarily allow the "with a client" tasks to be assessed in a role–play situation with a client surrogate.
      If you are a Responsible Assessor and you want those you are assessing to qualify for this temporary exception.
      • You (the Responsible Assessor) must complete the attestation and indicate on the Competency Assessment "role play."
      • You and the applicant/RBT must keep this document in your records.
      • The applicant/RBT must submit this document with the competency assessment when submitting their RBT certification or renewal application.

    Continue to monitor BACB correspondence and the COVID–19 Updates page for the date on which these temporary exceptions will no longer be allowed. This is only applicable for the sub–requirements stated above and does not apply to any other requirements.