"See No Evil, Report No Evil?" – Holding Insurance BCBAs Accountable

In my last post, I brought up a troubling trend in our field: BCBAs employed by insurance companies denying medically necessary ABA services without transparency, clinical review, or professional accountability.

The response was overwhelming. Many of you shared your frustrations and personal experiences, while others debated the ethical responsibilities of insurance-employed BCBAs. But now, we need to address the bigger question:

Do we, as providers, have an ethical responsibility to report these BCBAs to the BACB?

The Crossroads: To Report or Not to Report?

Let’s start by acknowledging that this isn’t about vilifying every BCBA working for an insurance company. Many are doing their best to navigate a deeply flawed system. But what about those who:

Issue blanket denials without asking for clarifying information?
Approve denials without reading clinical reports?
Hide behind ‘company policy’ to justify ignoring BACB ethical guidelines?

At what point does this stop being a job requirement and start becoming an ethical violation?

If We Don’t Hold Them Accountable, Who Will?

The BACB Ethics Code exists for a reason—to ensure that our field remains grounded in clinical integrity and client-centered care. Yet, we’re seeing insurance-employed BCBAs make decisions that directly contradict this code. And the most concerning part?

No one is holding them accountable.
No major action has been taken.
No one is reporting them.

If we, as behavior analysts, stay silent, we’re essentially saying:"It’s acceptable for BCBAs to prioritize cost-cutting over clinical need."

And that is not acceptable.

The Ethical Violations We Should Be Reporting

Here are just a few examples of how these actions violate the BACB Ethics Code:

BACB Code 3.01 – Responsibility to Clients: Behavior analysts must act in the best interest of their clients. Denying services without due diligence is the opposite of that.
BACB Code 2.15 – Interrupting or Discontinuing Services: Abrupt denials that force immediate service termination violate our obligation to ensure continuity of care.
BACB Code 1.04 – Integrity: Making clinical determinations without reviewing documentation is a fundamental breach of integrity.
BACB Code 1.06 – Avoiding Conflicts of Interest: When an insurance-employed BCBA is pressured to deny services despite knowing the client still needs them, does that not compromise their objectivity?

These are not minor oversights. These are serious ethical violations that harm clients, families, and the integrity of our field.

So, Should We Report Them?

Let’s be honest—reporting another BCBA to the BACB is not something any of us take lightly. We understand the gravity of an ethics violation report. But if we allow unethical behavior to continue unchecked, it risks becoming the new norm.

So, what are our options?

Option 1: Report BCBA Violations to the BACB

If an insurance-employed BCBA knowingly denies services without a fair review, it’s our ethical duty to file a report with the BACB. The BACB exists to regulate and protect our field. If enough providers report these trends, they will have to take action.

Option 2: Demand Industry-Wide Oversight

Push for state-level Medicaid oversight and advocate for formal investigations into how insurance companies are using BCBAs to justify cost-cutting denials. Partner with state ABA associations to amplify the conversation and demand accountability.

Option 3: Stay Silent and Let This Become the Standard

If we choose to stay silent, we’re accepting that insurance companies will continue to use BCBAs to rubber-stamp denials without real clinical review. Families will lose access to care, small ABA businesses will struggle, and our field will be dictated by cost-cutting algorithms instead of client-centered care.

What Happens Next is Up to Us

This isn’t just an insurance issue—it’s an ethical issue. We cannot call ourselves evidence-based clinicians while ignoring the fact that some of our colleagues are violating the very ethical standards we hold ourselves to.

If you’ve been affected by these unethical denials, it’s time to take action.