What is Applied Behaviour Analysis (ABA)?
Applied Behavior Analysis (ABA) is the application of the science of learning to understand and improve behavior that is meaningful to the person and those around them. ABA considers how the environment impacts learning. The term behaviour refers to anything a person says or does, including skills and actions needed to talk, play, and live. Behavior can also be private (e.g., thoughts and feelings).
ABA can help increase helpful or functional skills (e.g., communication) and/or decrease behaviours that are harmful or interfere with learning (e.g., self-injury).
ABA intervention uses evidence-based procedures such as positive reinforcement to address a client’s concerns and needs and to reduce interfering behaviour and increase desirable behaviour. Behaviour Analysts practice in a variety of settings with many different client populations.
Resources:
- The Ontario Association for Behaviour Analysis (ONTABA) has developed this graphic to describe ABA, what it is and what it is not. The graphic and more information can be found on their website.
- The Behavior Analyst Certification Board (BACB) has additional information on its website about the profession of ABA and the client populations it serves.
Why are Behaviour Analysts being regulated?
In 2017, the Minister of Health and Long-Term Care asked the Health Professions Regulatory Advisory Council (HPRAC) to provide advice on:
- What activities or aspects associated with ABA therapy pose a significant and inherent risk of harm (if any), and whether the risk of harm of this therapy varies by client population (e.g., children and adults); and
- If there is a risk of harm, what is the range of options for an approach to oversight that could be considered?
In HPRAC’s January 2018 report to the Minister of Health and Long-Term Care, Applied Behaviour Analysis: Risk of Harm and Oversight, it concluded:
“Based on the evidence reviewed, HPRAC affirms that there is a risk of harm associated with most ABA interventions for clients, therefore oversight is recommended. Several oversight options to regulating providers were examined with a particular focus on clinical supervisors.”
With respect to oversight, HPRAC recommended the following:
“Because ABA therapy is deemed to pose a significant and inherent risk of harm across many client populations, HPRAC recommends that ABA providers performing a clinical supervisory role be regulated under an established health regulatory college, governed by the Regulated Health Professions Act, 1991 (RHPA). Other ABA providers would be accountable to the regulated clinical supervisors.”
To protect the public from risk of harm, once regulated Behaviour Analysts who supervise and/or deliver ABA interventions will have to meet clearly defined standards. These standards will include having the necessary knowledge, skills, and judgement to meet practice requirements and to be allowed to use the regulated title “Behaviour Analyst”.
What does it mean when a profession is regulated?
Anyone who wants to practise a regulated health profession in Ontario, i.e., psychologists, psychological associates, physicians, nurses, dentists, occupational therapists etc., and now, Behaviour Analysts, must be registered with, and be accountable to, a health regulatory College. A College is not a university, community college, or school. Instead, its mandate is to protect the interests of the public by ensuring that clients receive competent and ethical professional services from qualified providers.
Ontario Health Regulators includes the 26 health regulatory Colleges in Ontario, including the College of Psychologists of Ontario. To learn more about how and why health professions are regulated in Ontario, visit their website.
How does regulation of Behaviour Analysts protect you?
Regulated professionals are required, by law, to deliver professional services competently and ethically. They are accountable to the public, through their regulatory body, for their professional behaviour and activities. Once regulated, Behaviour Analysts will have to meet rigorous professional entry requirements, adhere to prescribed standards, guidelines and ethical principles and participate in quality assurance activities to continually update and improve their knowledge and skill. Complaints and discipline processes hold professionals accountable when a client, or other member of the public, believes that the standards may have been breached.
In contrast, the College has no authority over unregulated service providers. There is no regulatory body with the authority to set minimum levels of education, training, and competence or to establish and monitor professional and ethical standards of conduct. There is no professional regulatory body responsible to protect your interests and hold unregulated providers accountable for the services you receive.
What does the new legislation do?
On June 3, 2021, the enabling legislation to authorize the College of Psychologists of Ontario to regulate the profession of Applied Behaviour Analysis (ABA), Bill 283, Advancing Oversight and Planning in Ontario’s Health System Act, 2021 received Royal Assent. Included in Schedule 4 of this Bill is the legislative authority for the College to regulate the profession of Applied Behaviour Analysis. On July 1, 2024 this legislation will be proclaimed by the government and will repeal the Psychology Act, 1991 to replace it with the Psychology and Applied Behaviour Analysis Act, 2021.
The new Act establishes the regulation of two separate and distinct professions, Psychology and Applied Behaviour Analysis within one College. The current College of Psychologists of Ontario will be the regulator for both professions and will be renamed the College of Psychologists and Behaviour Analysts of Ontario to reflect its expanded role. The legislation maintains the regulatory framework for current members, Psychologists and Psychological Associates, but additionally:
- Defines the scope of practice for ABA: “The practice of applied behaviour analysis is the assessment of covert and overt behaviour and its functions through direct observation and measurement, and the design, implementation, delivery and evaluation of interventions derived from the principles of behaviour in order to produce meaningful improvements”;
- Restricts the use of the title “Behaviour Analyst” to members of the new College registered as Behaviour Analysts;
- Expands the “Representations of Qualifications” restriction to include holding oneself out as qualified to practice as a Behaviour Analyst or in a specialty of behaviour analysis; and
- Updates the size and composition of the current College’s Council to enable fair representation for both professions.
Why is ABA being regulated by the College of Psychologists of Ontario?
In 2017, the Health Professions Regulatory Advisory Council (HPRAC), at the request of the then Minister of Health and Long-Term Care, undertook to review Applied Behavioural Analysis; its potential for harm and need for regulation. In response to a request for information, the College submitted a letter which stated, in part, that, “Should ABA regulation proceed in Ontario, the Council of the College of Psychologists is prepared to undertake this process within its governance structure”.
On September 19, 2019, the College received a letter from Minister Todd Smith of the Ministry of Children, Community and Social Services and Minister Christine Elliott of the Ministry of Health inviting the College to confirm its interest in undertaking the regulation of ABA as part of its governance structure. In their letter, the Ministers state that, “Strengthening the oversight of behavioural clinicians will protect vulnerable Ontarians from risk of harm and set standard expectations for professional standards and educational requirements for ABA providers across the province. It will also support families in finding qualified providers, and making complaints about providers, if necessary. Our ministries would like to begin with regulating those who are in a supervisory role, and we envision that this will be broadened to include front-line clinicians over time.”
On September 27, 2019, the Council of the College of Psychologists passed a motion confirming the offer to undertake the regulation of ABA within its governance structure.
On July 1, 2024, the College of Psychologists became the College of Psychologists and Behaviour Analysts of Ontario, to reflect its expanded role.
When did the new regulation of Applied Behaviour Analysis come into force?
On July 20, 2023, the Ontario Government approved the regulations made under the Psychology and Applied Behaviour Analysis Act, 2021, for the profession of Applied Behaviour Analysis (ABA). The Act was proclaimed effective July 1, 2024, when the College changed its name to the “College of Psychologists and Behaviour Analysts of Ontario”. Effective this date, only ABA practitioners who are registered with the College of Psychologists and Behaviour Analysts of Ontario are allowed to use the title “Behaviour Analyst” in Ontario.
Who will be registered with the College of Psychologists and Behaviour Analysts of Ontario?
Any person wishing to use the title “Behaviour Analyst”, a variation or abbreviation or an equivalent in another language, must register with the College. This would apply to clinical supervisors who provide clinical direction and supervision of ABA activities, which include behaviour assessment, designing an intervention plan, implementing intervention plans, and monitoring and evaluating the plans. Beginning on July 1, 2024, and going forward, only those who have registered with the College will have access to the restricted title “Behaviour Analyst”.
Service providers who deliver ABA interventions directly to a client or caregiver and are accountable to a Behaviour Analyst clinical supervisor will not be regulated.
Where can I get more information?
I am a Psychologist/Psychological Associate; how will adding a new profession to the College affect my College membership?
For most current members of the College, adding the profession of applied behaviour analysis to the College will have little or no effect. The College will regulate the two professions separately. Therefore, Psychologists and Psychological Associates should not see any change in their interactions with the College with respect to their practice or expectations of the College.
Behaviour Analysts will have their own standards of practice, quality assurance program and registration requirements. The current Professional Misconduct, Advertising and Quality Assurance Regulations will be revised so that they apply to the practice of applied behaviour analysis as well as psychology. The College Council will be enlarged and both Council and Committees will be made up of Psychologists, Psychological Associates, Behaviour Analysts, and public members appointed by the government. Decisions made by the College’s statutory committees will rely on the expertise of members of both professions and the public members who participate on each Committee.
There are members of the College who may also want to register as Behaviour Analysts in order to be able to use the restricted title “Behaviour Analyst”. They will hold two certificates of registration: one authorizing the practice of psychology and one authorizing the practice of applied behaviour analysis. These members will be expected to meet the College’s registration criteria and practice expectations with respect to both professions.
What will be restricted; the title “Behaviour Analyst” or the activities related to applied behaviour analysis?
The scope of practice or activities that a Behaviour Analyst performs when providing services to a client are not Controlled Acts or restricted activities. They are therefore, in the public domain. If one is not registered with the College, one must be aware of the restrictions within the Psychology and Applied Behaviour Analysis Act, 2021, regarding how one refers to themselves in the course of providing services in applied behaviour analysis.
On July 1, 2024, the date that the Act was proclaimed, the title “Behaviour Analyst” became a restricted title that can only be used by individuals registered with the College as Behaviour Analysts. Members registered as Behaviour Analysts may also refer to any earned certification they have, such as a BCBA or BCBA-D certification, that would assist the public in understanding their qualifications as a regulated health provider registered with the College. Non-members who use the title “Behaviour Analyst” or indicate any certification or designation or communicate in any way that could be considered as holding oneself out as a person who is qualified to practice as a Behaviour Analyst, could be in violation of the Act.
The applicable legislation prohibits unauthorized use of the specific title “Behaviour Analyst.” It does not otherwise prohibit the use of specific words in job titles or in describing the service offered or provided. However, in any title or description of services, individuals should be cautious about how their status as an unregulated individual will be perceived.
An unregulated person who “holds out” as qualified to practice as a Behaviour Analyst may also be in violation of the Act. In looking at whether someone is “holding out,” the College would consider all the circumstances, including the context of any communications and the language used. The focus would be on determining what a reasonable service recipient or funder would understand about whether the service was provided by, or under the supervision of, a regulated health professional.
In deciding on job titles and job descriptions for unregulated service providers, individuals should consider avoiding any confusion in the way they identify themselves, their colleagues, and their employees. Examples of some of the less ambiguous titles unregulated individuals may wish to consider using would include, but not be limited to: Supervised Instructor, Supervised Instructor-Therapist, Supervised Therapist, Supervised Interventionist, etc. The College is of the view that public protection is enhanced when behavioural services, like any other health services, are provided or directly supervised by regulated professionals.
What are Controlled Acts? Will Behaviour Analysts be authorized to perform any of the Controlled Acts?
Controlled Acts are health care activities or interventions that are considered to be potentially harmful if performed by unqualified persons. Some examples of Controlled Acts are administering a substance by injection, setting a broken bone, dispensing a drug, prescribing glasses, performing a surgical procedure, managing the delivery of a baby, and applying a form of energy. The full list of the 14 Controlled Acts may be found in section 27 of the Regulated Health Professions Act, 1991 (RHPA).
Due to the potential for harm, a Controlled Act may only be performed by a regulated health professional who is authorized, in legislation, to do so. Not all regulated health professions are authorized to perform Controlled Acts. Each profession specific act, e.g., the Medicine Act, 1991, Pharmacy Act, 1991, Psychology and Applied Behaviour Analysis Act, 2021, or Nursing Act, 1991, etc., prescribes which, if any, Controlled Acts may be performed by members of that profession.
Behaviour Analysts will not be authorized to perform any of the Controlled Acts outlined in the legislation. A Controlled Act may only be performed by those professions that have been granted authorization under the Regulated Health Professions Act, 1991 and their profession specific acts. The full list of the 14 Controlled Acts may be found in section 27 of the RHPA. This prohibition on performing any of the Controlled Acts is currently in place for individuals practicing applied behaviour analysis or any form of behaviour therapy and will continue with the proclamation of the new Act.
If a Behaviour Analyst registrant is dually registered with another regulatory College, and if their registration with that College qualifies them to perform one or more Controlled Acts, that registrant can continue to perform the Controlled Act(s) they are authorized, in legislation and in their profession specific act, to perform, while engaged in the practice for which they have been authorized to perform the Controlled Act(s).
Will the College have grand-parenting options for experienced Behaviour Analysts to register with the College?
Yes. The College has developed pathways for both entry level registration (i.e., new to the profession), and transitional registration (or “grandparenting”) for those currently in practice. To register with the College, experienced Behaviour Analysts will be required to demonstrate that they were practising the profession of Applied Behaviour Analysis prior to proclamation of the Act, and that they are safe and competent practitioners. Transitional registration will be open for a limited time following proclamation. Details regarding the qualifications the College will require and the evidence to demonstrate these will be available shortly.
I am a practitioner registered with another College (e.g.,College of Audiologists and Speech-Language Pathologists, College of Occupational Therapists of Ontario, College of Nurses of Ontario), and I also practise Applied Behaviour Analysis. Will I have to register with the College of Psychologists and Behaviour Analysts?
Many professionals registered with other regulatory colleges, including nurses, social workers, occupational therapists, speech language pathologists, educators, and others, may use behavioural techniques in their practice. As noted above, these will remain in the public domain and are not restricted activities. If, however, a practitioner wishes to use the title “Behaviour Analyst” or indicate any certification or designation or communicate in any way that could be considered as holding themself out as a person who is qualified to practice as a Behaviour Analyst, they will be required to also register with the College of Psychologists and Behaviour Analysts of Ontario.
Dual registration occurs often in many sectors as professionals may hold certificates of registration with more than one regulator to practice multiple professions. It is permissible, and may be necessary, for a Behaviour Analyst to be registered with more than one regulatory College. In this same vein, Psychologists and Psychological Associates, that want to be able to use the restricted title “Behaviour Analyst”, must meet the registration requirements to obtain a second certificate of registration authorizing practice as a Behaviour Analyst.
Are Behaviour Analysts required to carry professional liability insurance?
Professional liability insurance coverage is required for all regulated health professionals. Behaviour Analysts are required to hold or otherwise be covered by professional liability insurance in all settings in which they practise. Insurance must be in place upon registration and confirmed annually with the College during the annual renewal process.
A Behaviour Analyst who is employed by an organization may be insured under their employer’s professional liability insurance policy so long as it meets the minimum requirements to be set by the College. It is important to know however, that one’s insurance through the workplace covers only the services provided while working for that employer. If an employed Behaviour Analyst also provides services to clients outside of their employment, they must also obtain individual professional liability insurance.
Professional liability insurance can be obtained through associations, insurance companies and other organizations and coverage must be in accordance with the College By-laws.
What is the supervision structure in the practice of ABA?
Supervision is defined as:
…an ongoing educational, evaluative and hierarchical relationship, where the supervisee is required to comply with the direction of the supervisor, and the supervisor is responsible for the actions of the supervisee.
Supervision in ABA is a regulated professional service. The ABA supervisor is in a hierarchical relationship with their supervisees, whereby the supervisees must comply with the supervisor’s direction.
Models of care in ABA can sometimes include multiple teammates working together to serve a client’s needs.
The College does not permit “second-order” supervision. This means that, while a Behaviour Analyst’s supervisees may have varying roles and responsibilities as among themselves, including some oversight or supervisory roles, the Behaviour Analyst is directly responsible for all supervisees.
It may be helpful to think of the Behaviour Analyst as the one responsible for all services provided to the client. There may be multiple individuals involved in providing those services, who may have varying roles and responsibilities. The Behaviour Analyst is responsible for all the individuals involved in the provision of services to clients. The illustration above is meant to assist in emphasizing the Behaviour Analyst’s supervisory responsibilities across different models of care.
How do I submit supporting documents for my application for Behaviour Analyst?
Behaviour Analyst applicants must have the relevant organization submit the following supporting documents directly to the College: transcript(s), BACB® verification letter, and letters of good standing from other regulatory Colleges/Boards (if applicable).
E-mail is preferred: cpbao@cpbao.ca. If e-mail is not possible, please have the organization mail the document to:
The College of Psychologists and Behaviour Analysts of Ontario
110 Eglinton Ave West, Suite 500
Toronto, ON
M4R 1A3
Regarding the Vulnerable Sector Check, applicants may e-mail or upload it to their application form. Please contact the College if your region does not issue Vulnerable Sector Checks for registration purposes.
Can the Peer Assessment for Transitional Route 2 be conducted virtually?
Yes, the Peer Assessment may be conducted in-person or virtually. Any confidential documentation must be shared via a secure platform, and either anonymized or with the consent of the client.
Where can I find the Attestation Forms and Peer Assessment Form (for Transitional Route 2)?
Behaviour Analyst Transitional Route 2 applicants can download the Attestation A/B, Attestation C, and Peer Assessment Forms from the "Download Documents" section in the application portal or from the "Become a Member" section of the Reference Library.
How do I submit my results of the Vulnerable Sector Check to the College?
All applicants must upload the original results of the Vulnerable Sector Check to the College through the application portal. Applicants should keep a scanned copy for their records. If the Vulnerable Sector Check is password protected, please email the password to cpbao@cpbao.ca. If your original results were issued as a paper hard copy from the police, please submit them to the College in an enclosed letter:
The College of Psychologists and Behaviour Analysts of Ontario
110 Eglinton Ave West, Suite 500
Toronto, ON, M4R 1A3
Where do I obtain a Vulnerable Sector Check, and how much does it cost? How long will it take to get my results?
To obtain a Vulnerable Sector Check, please contact your local police service for more information. You will be responsible for obtaining the correct type of check and ensuring all related fees are paid. Each police service has different processing times, and it may take time to receive the results of a Vulnerable Sector Check. It is recommended to allow yourself enough time to apply for the Vulnerable Sector Check ahead of your registration date, but no more than 6 months before.
I live in the City of Toronto. How do I obtain a Vulnerable Sector Check?
For applicants living in the City of Toronto, please contact the Toronto Police Service to obtain a Vulnerable Sector Check. The Toronto Police Service offers an online, in-person and mail-in option. Visit the Toronto Police Services website for more information.
A unique “Agency Code/Program Number” code that the College has been assigned by the Toronto Police will be required. The College’s Agency Code/Program Number is: 202311TPSONA3383
How long will my Vulnerable Sector check be valid for?
The College will only accept Vulnerable Sector Checks that were issued within 6 months from the date the College receives it.
What is a Vulnerable Sector Check, and why do I have to get it?
A Vulnerable Sector Check is the standard police screening for individuals who work with vulnerable persons. A Vulnerable Sector Check collects offense information, including convictions, outstanding warrants, juridical orders, charges, and record suspensions (pardons) for sexual offences.
All applicants for registration as a Behaviour Analyst are required to provide the results of a Vulnerable Sector Check as part of their application. The practice of applied behaviour analysis is used widely to treat autism and other developmental disabilities, and Behaviour Analysts work closely with and have authority over children and other vulnerable persons in their care. A Vulnerable Sector Check provides an added level of public protection by obtaining information from an outside entity about an applicant’s good character.
What type of criminal record check will the College accept?
Applicants applying for registration as a Behaviour Analyst will be required to obtain a Vulnerable Sector Check. Applicants living in regions that do not issue Vulnerable Sector Checks for registration purposes will be asked to provide a Level 2 Criminal Record and Judicial Matters Check. These applicants will also be required to sign an Undertaking and Agreement with the College.
I am an international applicant. What criminal record check should I obtain?
If you currently reside outside of Canada and are unable to obtain a Vulnerable Sector Check, please contact the College at aba@cpbao.ca.
Do Behaviour Analysts Require Supervision?
Registrants who have been issued a certificate of registration authorizing autonomous practice as a Behaviour Analyst by the College of Psychologists and Behaviour Analysts of Ontario are considered autonomous/independent practitioners of applied behaviour analysis (ABA). Therefore, autonomous practice Behaviour Analysts do not require supervision from a Psychologist/Psychological Associate or another regulated professional to practice ABA.
Can I complete the JECAABA and OEPPABA after the transitional routes close?
Yes, provided that you submit an application form and fee by 11:59pm on June 30, 2026, the deadline for the closure of the transitional routes. Once a complete application (i.e. application form, fee, and all supporting documentation) has been received and approved, you will be given access to the Jurisprudence and Ethics Course and Assessment in Applied Behaviour Analysis (JECAABA) (Transitional Routes 1 & 2), and the Ontario Examination for Professional Practice in Applied Behaviour Analysis (OEPPABA) (Transitional Route 2 only). Applicants who do not submit an application form and fee by the deadline will not qualify for registration via a transitional route, and therefore, must apply via the Entry Level Route.
Does the College have Ontario residency requirements?
No, applicants and registrants are not required to reside in Ontario. However, Section 3.3. of the Registration Regulation, specifies that, in order to be issued with a certificate of registration the applicant must be a Canadian citizen, a permanent resident of Canada or authorized under the Immigration and Refugee Protection Act (Canada) to engage in the practice of the profession. Applicants who are not citizens or permanent residents of Canada may meet the requirement by holding a valid work permit, for example. For information respecting authorization to work in Canada go to https://www.cic.gc.ca/.
Where can I find the Supervisor’s Agreement and Confirmation of Private Practice Arrangements Form for Entry Level Route Behaviour Analysts?
The Supervisor's Agreement and Confirmation of Private Practice Arrangements Form required for all Entry Level Route (Supervised Practice) Behaviour Analyst applicants can be found in the Reference Library under "Become a Member". Applicants may upload the completed form to their application.
