Issued — March 2026
Status — Open for Endorsement
Field — Applied Behavior Analysis
Audience — Payers · Regulators · Providers
Position Statement — Governance & Accountability in ABA
The Council of Autism Service Providers claims to represent the autism services field to payers, regulators, and the federal government. It was never authorized to. No election was held. No vote was taken. CASP appointed itself — and has been expanding its regulatory authority, accreditation ownership, and data infrastructure ever since.
What This Is About
CASP is a 501(c)(6) trade association — a legal structure that exists to advance the business interests of its dues-paying members. Its board is composed entirely of CEOs and Executive Directors of its own member organizations. Every governance decision CASP makes is made by people who financially benefit from those decisions.
CASP has successfully lobbied more than a dozen payer entities to require accreditation from ACQ — an accreditation body CASP wholly owns — as a condition of network participation. In December 2025, it fully acquired Jade Health, consolidating a second accreditation program (BHCOE) and a national patient data registry under the same trade association.
This is not a statement against quality standards. We support them deeply. This is a statement about who gets to set them, how those standards are governed, and whether an organization with this governance structure can be trusted to do so without an independent check anywhere in the chain.
The evidence, documented entirely in CASP's own public materials, shows it cannot.
"CASP represents the autism provider community to the nation at large including government, payers, and the general public."
— casproviders.org (Official Website)"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 — contradicting CASP's repeated claim that ACQ operates independently.
— CASP CEO, Public Statement, 2026The Case
Each of the following is documented in CASP's own public materials, its CEO's public statements, and peer-reviewed research. None require interpretation — they are statements of fact.
01 — Self-Appointment
CASP began in 2009 when ten executives convened privately and decided to represent the field. No field-wide nomination occurred. No credentialed behavior analyst outside CASP's founding membership was asked to consent. CASP appointed itself — everything it has done since flows from that original act of self-authorization.
02 — Governance Conflict
Every member of CASP's Board of Directors simultaneously holds an executive leadership role at a CASP member organization. Every standard set, every accreditation criterion established, every policy lobbied for — all decided by people whose organizations directly benefit from those decisions.
03 — Accreditation Capture
CASP created ACQ as a wholly-owned subsidiary, then successfully lobbied payers to require ACQ accreditation for network participation. Every accredited organization pays fees to a subsidiary of the trade association whose members compete for the same contracts. Its CEO admitted ACQ could not pay its own bills without CASP keeping it alive.
04 — Credential Double Standard
CASP promotes and monetizes 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 policy barrier it deployed lobbyists to defeat — borrowing BACB credibility when convenient, undermining BACB standards when they create cost.
05 — Independent Provider Exclusion
Even the nine largest providers account for less than 30% of industry revenue. Yet independent and small-to-mid-size providers have no meaningful governance representation. The accreditation infrastructure CASP lobbies payers to require is scaled for compliance departments — not clinical teams running community-based practices.
06 — No Structural Protection
In most states, you cannot own a medical practice without a medical license. ABA has no equivalent protection. Between 2017–2022, private equity firms completed 85% of all M&A in autism services. The organization claiming to represent clinical quality in this field has not advocated for the structural protections every other healthcare field has bilt to limit investor control.
The Documents
All claims are drawn entirely 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 14-section statement covering CASP's origin, governance structure, accreditation conflicts, credentialing stance, private equity context, and what structural change is required.
Read Full Statement →Letter — Professional Body
Raises the central contradiction: CASP stewards the BACB's ABA Practice Guidelines while actively lobbying against mandatory enforcement of the BACB's own frontline practitioner credential in Medicaid.
Read & Download →Letter — Professional Body
Addresses APBA's recent co-publication of ASD Assessment Guidelines with CASP. Asks whether APBA conducted a formal governance review before lending its professional authority to the arrangement.
Read & Download →Letter — Professional Body
Calls on 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 scientific consensus.
Read & Download →Colleague Outreach
A letter for sharing with trusted colleagues who may not yet be aware of CASP's governance trajectory. Framed for private, professional conversation — not public confrontation.
Read & Download →Who Should Read This
The same governance failure has 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 should 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?
CASP and its subsidiaries do not satisfy these tests as currently structured. Adopting ACQ accreditation as a meaningful quality standard — without requiring independent governance first — rewards a structural conflict of interest and may ultimately harm the very patients whose quality of care you are seeking to protect.
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 represents a direct conflict between CASP's member organizations' financial interests and the consumer protection mechanisms states have constructed.
When CASP argues against mandatory RBT enrollment requirements, it is opposing the mechanism by which states verify that the people billing for services to autistic children are actually qualified to deliver them.
You are not represented by CASP. The standards being lobbied for in your name were written by executives of large organizations for the operational realities of large organizations. The compliance infrastructure CASP's accreditation requires is built for organizations with compliance departments. For a BCBA running a community-based practice, meeting those requirements means diverting clinical time to administrative overhead or hiring staff whose cost the practice cannot absorb.
Each new CASP product that becomes a de facto network requirement narrows the space for independent providers to survive. The authority CASP has claimed for itself was never inherent. It was taken. And it can be contested.
The authority to define clinical and ethical standards in applied behavior analysis belongs to the credentialing and scientific bodies of this field — not to trade associations governed by the financial beneficiaries of those standards. None of the field's legitimate governance structures — the BACB, ABAI, APBA, or state licensure boards — appointed CASP to speak for the field or endorsed its accreditation subsidiary as the quality standard for autism services.
ABAI's silence on these questions is not neutral. When the field's preeminent scientific organization does not clarify that CASP's standards do not carry the scientific community's endorsement, that silence is reasonably interpreted by payers, regulators, and federal agencies as implicit validation. The lobbying at CMS, TRICARE, and the DOL is happening now.
Add Your Voice
Endorsements are accepted from credentialed behavior analysts, independent and small-to-mid-size ABA providers, researchers, and family members of autistic individuals who receive ABA services.
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. What matters is that your endorsement is counted.
Your submission has been received and will be verified before appearing on the statement. A confirmation will be sent to your email.