ABA Accountability Project · April 2026
A trade association governed entirely by executives of its own member organizations has spent more than a decade quietly positioning itself as the authoritative voice of applied behavior analysis — setting standards, owning accreditation, lobbying payers, and acquiring data infrastructure — without a single field-wide vote, nomination process, or democratic authorization of any kind. Independent clinicians, educators, researchers, and families did not choose this. They simply woke up to find it already done.
The window to contest it is open. It will not stay open.
Updated May 2026 — Supplemented with an addendum addressing guidelines development standards. Download Addendum →
Start Here
This site presents documented information for independent review. All sources are cited in the full position statement.
Read full position statement →Updated May 2026 — Download May 2026 Addendum →
In Plain Terms
Who Should Read This
The Concern
No election. No nomination process. No field-wide consent.
CASP appointed itself. Everything that followed flows from that original act of self-authorization.
Every major decision is made by those who benefit from it.
Those setting the standards are the same organizations financially impacted by them.
The same entity that promotes the standard benefits from its adoption.
CASP's own CEO publicly acknowledged that ACQ "wouldn't have been able to make ends meet" without CASP's direct financial support — and CASP's most recent publicly filed financial statements confirm that ACQ continues to carry negative net assets, meaning this dependency is ongoing, not historical. The accreditation body CASP lobbies payers to require cannot sustain itself without the trade association whose members it accredits.
The credentialing double standard.
CASP stewards and promotes the BACB's ABA Practice Guidelines as the clinical foundation of its authority. Yet on its own advocacy page, CASP explicitly identifies mandatory RBT enrollment requirements as a named policy barrier — one it deployed lobbyists to defeat in Indiana Medicaid.
At the federal level, CASP advocates for employment classifications broad enough to bill for services delivered by uncredentialed staff, preserving maximum labor flexibility for large provider organizations.
CASP invokes BACB credibility when it confers authority — and works against BACB standards when they create compliance costs.
"CASP represents the autism provider community to the nation at large including government, payers, and the general public."
— casproviders.org (Official Website)"In 2009, leaders from 10 provider agencies convened in Las Vegas as the Council on Autism Services. The goal of this group was to provide a forum for senior executives from like-minded organizations to meet, share ideas, and solve problems."
— casproviders.org/history-and-mission"The founders of CASP recognized the need for a strong national voice for autism service providers. While there are successful associations representing parents and self-advocates, the priorities of these groups may not always align with the needs of provider agencies."
— casproviders.org/history-and-missionCASP's CEO publicly acknowledged in early 2026 that ACQ "wouldn't have been able to make ends meet" without CASP's direct financial support. CASP's most recent Form 990 confirms ACQ continues to carry negative net assets — meaning this support is ongoing.
— CASP CEO, Public Statement, 2026 · IRS Form 990, Filed September 2025What We Found
Each of the following is documented in CASP's own public materials, its leadership's public statements, and peer-reviewed research. All sources are cited in the full position statement.
01 — Democratic Legitimacy
CASP began in 2009 when leaders from ten provider agencies convened privately and decided to represent the field. No field-wide nomination process occurred. No practitioners outside the founding group were asked to vote on CASP's authority. The organization that now lobbies federal agencies on the field's behalf was never authorized by that field to do so.
02 — Governance Structure
Every member of CASP's Board of Directors simultaneously holds an executive role at a CASP member organization. Every standard set, every accreditation criterion established, every policy lobbied for — decided by executives whose organizations receive direct financial benefits from those very decisions.
03 — Accreditation Ownership
CASP created ACQ as a wholly-owned subsidiary in 2022, then successfully lobbied payers to require ACQ accreditation for network participation. Every accredited organization pays fees to a subsidiary of the same trade association whose member organizations compete for the same contracts.
ACQ's own financial statements show it cannot sustain itself — $178,317 in accreditation fees against negative net assets of $636,088. The only reason ACQ exists is that CASP funds it. Think of it this way: the inspector is on the payroll of the company being inspected. When the inspector's continued existence depends on that company's money, the inspection cannot be trusted — regardless of anyone's intentions.
04 — Credentialing Inconsistency
CASP promotes and monetizes the BACB's ABA Practice Guidelines as the foundation of its clinical authority. Yet on its own advocacy page, CASP identifies mandatory RBT enrollment requirements as a policy barrier it deployed lobbyists to defeat — borrowing BACB credibility when it confers authority, opposing BACB standards when they create cost. The BACB transferred those guidelines to CASP in 2020, apparently without stipulations on their use.
05 — Representation Gap
Even the nine largest providers account for less than 30% of industry revenue — the remainder is distributed across independent and community-based practices. Yet independent clinicians and small providers have no meaningful governance representation. Accreditation requirements are scaled for organizations with compliance departments, not independent clinical teams. The National Restaurant Association represents restaurant owners — it does not claim to set standards for the professionals who work in those restaurants or speak for the people they serve. CASP claims all three.
06 — Missing Protections
Medicine built the Corporate Practice of Medicine doctrine — in 33 states, practices must be owned by licensed clinicians, not investors. Dentistry and psychology built equivalent protections. Hospital accreditation is handled by The Joint Commission, an independent nonprofit with consumer and clinician representation — not owned by a trade association. Between 2017–2022, private equity firms completed 85% of all M&A in ABA services. Every comparable field built these structures before this level of outside capital entered. ABA has not yet built them — and the organization claiming to speak for the field has actively opposed the provider enrollment requirements that verify frontline practitioners hold the credentials the field's own credentialing body requires.
07 — Commercial Ecosystem
CASP operates four paid tiers. Provider organizations pay annual dues. Business vendors pay $5,000 per year. University training programs pay up to $2,000 per year. Allied organizations pay $800 per year. Each tier receives access to the Special Interest Groups and workgroups where CASP's clinical standards are developed.
The training affiliate program creates a documented pipeline routing the next generation of practitioners toward CASP member organizations. Allied affiliates must formally endorse the services CASP member organizations provide as a condition of eligibility. CASP's board determines which organizations are "direct competitors" and therefore ineligible. It is a commercial strategy operating under clinical cover.
08 — Financial Conflicts
CASP's 2024 IRS Form 990 — a public document — shows total revenue of $2,593,034 and CEO compensation of $266,054. The national median salary for behavior analysts is approximately $89,000. The CEO of the organization claiming to represent those practitioners earns approximately three times their median salary.
The same filing discloses a related party transaction in which CASP paid $16,550 to an organization run by the CEO's spouse for rent and services. This was properly disclosed, as required. What it illustrates is structural: every financial decision is overseen by a board composed entirely of its own member organizations' executives, with no independent check.
By Audience
The same governance questions have different implications depending on your role in this ecosystem.
Before granting any organization's accreditation or standards the status of a coverage condition or quality benchmark, payers are well-served to apply a basic governance test: is the standards-setting body governed by a board that is independent of the financial beneficiaries of those standards? Were the standards developed through a transparent, multi-stakeholder process that included clinicians, families, and researchers? Is the accreditation body structurally independent from the trade association whose members it accredits?
These are the same governance tests applied to standards bodies in medicine, dentistry, and every other healthcare field. They are reasonable to apply here.
CASP employs federal and state lobbyists, conducts annual advocacy events in Washington D.C., and has successfully lobbied for mandated recognition of its subsidiary's accreditation in over a dozen payer contracts. Its documented opposition to RBT provider enrollment requirements in Indiana Medicaid raises a direct question about the alignment between CASP's advocacy positions and the consumer protection mechanisms states have put in place.
When CASP argues against mandatory RBT enrollment requirements, it is opposing the mechanism by which states verify that the individuals billing for services hold the training and supervision the field's own credentialing body requires.
The standards being developed and lobbied for in the name of the field were shaped by executives of large provider organizations — for the operational realities of organizations at that scale. The compliance infrastructure CASP's accreditation requires is built for organizations with dedicated compliance departments. For an independent BCBA or small practice, meeting those requirements means diverting clinical time to administrative overhead or absorbing costs the practice cannot sustain.
APBA was founded specifically to represent credentialed individual practitioners. Your professional body exists. The question is whether its voice is being heard — and whether yours is behind it.
The authority to define clinical and ethical standards in applied behavior analysis belongs to the credentialing and scientific bodies of this field. The BACB credentials its practitioners. ABAI convenes its science. APBA represents its professional membership. None of these bodies appointed CASP to speak for the field or endorsed its accreditation subsidiary as the quality benchmark for ABA services.
This statement asks each of these organizations to examine, formally and publicly, what CASP's growing institutional authority means for the integrity of the standards they exist to protect — and to exercise the independent voice their constituencies need them to use.
The Documents
All claims are drawn from CASP's own public materials, its leadership's public statements, and peer-reviewed research. Every source is cited in the full position statement.
Full Position Statement
The complete statement covering CASP's origin, governance structure, accreditation ownership, credentialing inconsistencies, the private equity context, and what independent governance should actually look like.
Read Full Statement →Letter — Professional Body
Asks the BACB to account for a specific contradiction: the organization it transferred its ABA Practice Guidelines to in 2020 is simultaneously lobbying against mandatory provider enrollment requirements for RBTs — the mechanism by which payers verify that frontline practitioners hold the BACB's own credential for that role — and to examine whether that transfer has served the consumer protection purpose those guidelines were developed to fulfill.
Read & Download →Letter — Professional Body
Calls on APBA — founded specifically to give credentialed individual practitioners an independent voice — to examine whether its growing entanglement with CASP has compromised that independence, and to exercise the practitioner representation that is its founding purpose and its members' primary reason for belonging.
Read & Download →Letter — Professional Body
Asks ABAI to clarify publicly that CASP's standards do not carry ABAI's scientific endorsement — and that payers and federal agencies should not interpret CASP's advocacy as reflecting the scientific consensus of the field.
Read & Download →Colleague Outreach
A letter for sharing with trusted colleagues who may not yet be aware of CASP's governance trajectory. Written for private, professional conversation — not public confrontation.
Read & Download →Send Your Own Letter
These are field versions of the institutional letters — adapted so any credentialed practitioner, family member, or concerned citizen can send them directly. Fill in your name and credentials, and send.
Field Letter — BACB
Asks the BACB to account for the contradiction between the guidelines it transferred to CASP and CASP's documented opposition to enforcing those guidelines' frontline credential. Adapted for any practitioner, family member, or concerned citizen to send directly.
Download & Send →Field Letter — ABAI
Asks ABAI to clarify publicly that CASP's standards do not carry ABAI's scientific endorsement — and that payers and federal agencies should not treat CASP's advocacy as reflecting the scientific consensus of the field. Adapted for any practitioner, family member, or concerned citizen to send directly.
Download & Send →About This Project
This project was prepared by Kirstin Hall, MS, BCBA, IBA, a behavior analyst in private practice in San Diego, CA, with over 23 years of experience in the field. The decision to attach her name to formal institutional letters — to the BACB, ABAI, and APBA — while others contributing remain anonymous reflects a deliberate choice: someone needed to be willing to be named. She chose to be named.
The concerns documented here are shared by credentialed ABA providers, educators, and field stakeholders who have chosen not to be publicly identified at this time. Members of this field have reported concerns about professional retaliation for public criticism of CASP. Those concerns are taken seriously here. The anonymity of contributors is not a weakness in this argument — it is evidence of the exact power dynamic this project is documenting.
CASP paid their CEO over $250k in 2024 — approximately three to four times the median salary of the behavior analysts it claims to represent. Several board members hold no clinical credentials in applied behavior analysis whatsoever. The people writing the rules for how ABA services should be delivered are not the clinicians who deliver them, the educators who train the next generation of practitioners, the families who receive them, or the researchers who developed the science behind them.
CASP is a trade association. Its board consists of executives of large provider organizations. Their interests — operational efficiency, billing flexibility, accreditation market share — are not the same as the interests of the independent BCBA running a community-based practice, the RBT sitting in front of a child, or the family trying to access consistent, quality care. They are not like us. They should not be the ones speaking for us.
AI was used as a writing and editing tool to help organize and articulate arguments that are entirely the product of human research, analysis, and professional experience. Every claim in this statement was identified, verified, and sourced by the humans behind this project. AI made the writing cleaner. It did not generate the concerns, the evidence, or the argument.
If your response to this project is to focus on the tool rather than the documented facts — you are choosing deflection over substance.
We are not arguing that organizational accreditation in ABA is wrong. The field needs quality standards. The problem is structural: an accreditation body should be governed by an independent board with clinical, scientific, and consumer representation — not owned outright by the trade association whose members are being evaluated. Every comparable profession built that separation deliberately. ACQ's concept is valid. Its governance is not.
ABA has been practiced for more than 60 years. It has been insurance-mandated in all 50 states since 2020. The BACB has credentialed practitioners since 1998. Private equity firms completed 85 percent of all mergers and acquisitions in autism services between 2017 and 2022. The field was apparently mature enough to attract billions in investment. It is mature enough to govern itself.
Calling ABA too young for independent governance is not an argument. It is a delay tactic that benefits the organizations already filling the vacuum.
No one. We did not ask for authorization — and neither did CASP when it appointed itself. Any credentialed professional has the right to document publicly available facts and ask that professional bodies examine them. We are not claiming authority to speak for the field. We are claiming the right to ask who does — and whether that authority was ever legitimately granted.
This is not a campaign against CASP's existence. The field desperately needs quality standards — rigorous, enforceable, meaningful ones. But the field should determine them. Not a trade association whose governance structure concentrates decision-making in the hands of executives of its own member organizations, with no structural requirement for frontline clinical experience and no independent voice for the practitioners, educators, and families who actually deliver and receive care.
The organizations that could build legitimate governance already exist. ABAI holds the science. The BACB holds the credentialing infrastructure. APBA was founded to hold the practitioner voice. The field does not lack for governance models — it lacks the organizational will to activate the legitimate bodies it already has before the entity that self-appointed as its standards authority makes them irrelevant.
Add Your Voice
Endorsements are accepted from credentialed behavior analysts, ABA providers of any size, researchers, educators, family members, and concerned citizens who believe the governance of ABA services should be independent, transparent, and accountable to the field it claims to represent.
You choose your level of disclosure. Your identity is verified by the coordinating author before your endorsement is published. Requests for anonymity are honored without question — they do not diminish the weight of your endorsement.
If you have professional concerns about retaliation, choose the anonymous option. Members of this field have reported concerns about professional retaliation for public criticism of CASP. Anonymity in that context is not cowardice — it is rational self-protection, and it is exactly the power dynamic this statement is documenting.
Your submission has been received and will be verified before appearing on the statement. A confirmation will be sent to your email.