Questions to Ask as Organizations That Provide Behavioural Services

Reflection questions for any employer of behavioural services to consider:

  • Are all behavioural services being provided or supervised by a registered professional?
  • Are any service providers holding themselves out to be Behaviour Analysts or using a variation of the term such as Behaviour Therapist?
    • What titles are used in your organization?
    • How will you manage Human Resource and Union considerations, if the titles you currently use are no longer permissible?
    • Will these regulatory changes impact your model(s) of care?
    • Are clients and/or their Substitute Decision Makers fully informed of the individuals involved in providing care, including the provider’s registration status, regulated title, and how to have their quality-of-care concerns addressed?

How will the regulation of applied behaviour analysis impact professionals currently registered with other regulatory bodies who use ABA techniques?

  • Although Behaviour Analysts are not authorized to perform any controlled acts, behavioural services pose potential risks to the public and should only be provided by those competent to do so.
  • The Act will not restrict competent registered professionals from practicing ABA techniques, as behavioural interventions are in the public domain and registered professionals are accountable to their respective College for practicing competently within the scope of their profession. The public has a regulator to whom they can voice complaints or concerns.
  • It will be important to be clear with the public about the regulation status of their service provider (regulated or not, by whom, whether there are supervisors of services, and whether those supervisors are regulated).
  • Once the Psychology and Applied Behaviour Analysis Act, 2021 is proclaimed on July 1, 2024, the title “Behaviour Analyst” will be restricted (as well as variations of the title) that can only be used by individuals registered with the College of Psychologists and Behaviour Analysts of Ontario as Behaviour Analysts.
  • Anyone not registered with the College of Psychologists and Behaviour Analysts of Ontario as a Behaviour Analyst will not be able to use any earned ABA credentials (e.g., BCBA or BCBA-D certification) or hold themselves out to be a Behaviour Analyst.
  • If receiving ABA services, the public will expect to know the qualifications of the professional(s) involved in their care.

What is involved in becoming a Registered Behaviour Analyst?

Can Registered Behaviour Analysts refer to BACB credentials?

  • Registrants 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-registrants 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 Psychology and Applied Behaviour Analysis Act. Members of the public will be able to verify the registration status of a Behaviour Analyst using the College’s public register. 

This guidance is meant to assist employers navigate these new expectations. The College encourages you to seek legal advice for specific questions.

Public protection requires clarity and transparency for all roles related to ABA services. In naming and outlining roles related to ABA services, it is important to bear the following in mind:

Transparency: People should know if their ABA services are provided by registered, supervised, or unsupervised individuals.

Clarity: With the regulation of ABA services, people may expect accountability to the College regardless of job title. If using a variation of the regulated title, such as “Behaviour Therapist,” extra care should be taken to clarify registration status, and accountability for services, if any.

Flexibility in Job Titles: The College does not have a set list of approved job titles. However, the College does expect clarity and transparency regarding offering any ABA services.

Accountability: Employers should indicate when services are provided by or under supervision of a regulated ABA member. This includes explaining roles and professional accountability to the College as the regulator.

Professional Standards: ABA College registrants who assume roles under any job title remain bound by College Standards. They must remain transparent about their qualifications and/or supervision status.

Controlled Acts: There are no Controlled Acts set out in legislation that apply to the provision of ABA.

Title: Only the title “Behaviour Analyst” will be regulated by the College; only those registered as a Behaviour Analyst with the College may use the title “Behaviour Analyst”, a variation or abbreviation or an equivalent in another language, or hold themself out as a person who is qualified to practise in Ontario as a Behaviour Analyst or in a specialty of applied behaviour analysis.

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.