Response to BACB Changes in Ontario

The College would like to address the recent decision by the Behavior Analyst Certification Board (BACB) to discontinue BACB certification in Ontario. The College respects BACB’s decision and will continue to work with them in a mutually respectful and collaborative manner. The College looks forward to potential opportunities to partner with BACB in the future.

It is important to reflect upon the evolution of Applied Behaviour Analysis (ABA) as a profession in Canada. Ontario will be the first Canadian jurisdiction to regulate the profession of ABA, through the collaboration and rigorous work of government, the College, and a variety of stakeholders. 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 ABA, its potential for harm, and need for regulation. 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.” In their September 19, 2019 letter to the College, the Minister of Children, Community and Social Services and the Minister of Health invited the College to confirm its interest in undertaking the regulation of ABA as part of its governance structure, and stated 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.”

BACB certifies practitioners at three levels: Board Certified Behavior Analyst® (BCBA®)/Board Certified Behavior Analyst-Doctoral® (BCBA-D®), Board Certified Assistant Behavior Analyst® (BCaBA®), and Registered Behavior Technician® (RBT®). According to BACB, individuals holding either RBT or BCaBA certification work within a tiered model of service provision, supervised by a BCBA or BCBA-D. As of July 1, 2024, when the Psychology and Applied Behaviour Analysis Act, 2021, is proclaimed into law, only registrants of the College who hold a Certificate of Registration for a Behaviour Analyst Authorizing Autonomous Practice will be able to use the title “Behaviour Analyst” or any variation on that title, or  present themselves as a Behaviour Analyst practising ABA autonomously. Hence the titles of BCaBA and RBT pose the risk of unregistered practitioners presenting themselves to the public as regulated health professionals in ABA. This poses significant and undue risk to the public, as the College will have no accountability or authority over unregistered practitioners. The recently announced upcoming changes to BACB certification in Ontario reflect growth of the profession of Applied Behaviour Analysis in Ontario and will benefit the public by providing greater transparency of services provided.

Regulation of the ABA profession does not change the demand for ABA services in the province and the need for team-based approaches to serving clients and their families. Pre-registration of Behaviour Analysts is expected to open early in 2024 for individuals who are new to the profession, as well as those who are currently practising ABA.  During the first two years after proclamation (July 1, 2024, to June 30, 2026), a transitionary period will open to register or “grandparent” as many practising professionals as possible who meet the College’s registration requirements.

Those who assist Behaviour Analysts will continue to be able to provide ABA services under the supervision of a registrant of the College. The formal definition of supervision according to the College is, “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.” Therefore, those who have been historically certified as a BCaBA or RBT will be able to continue to work in the field under the supervision of a registrant of the College. However, these supervised practitioners will not be able to use titles that could mislead the public that supervisees are autonomously practising ABA professionals. Title restrictions are important to protect the public from those who do not belong to a health regulatory College but present themselves as an independent professional to clients and families.

Anyone who wants to practise as 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’s mandate is to protect the interests of the public by ensuring that clients receive competent and ethical professional services from qualified providers. The College has and will continue to publish updates on the ABA page of its website. You are strongly encouraged to  review the information on the ABA page and the FAQs page before contacting the College. We are looking forward to onboarding the profession of ABA and the formation of the new College of Psychologists and Behaviour Analysts of Ontario on July 1, 2024.