Project Updates — ABA Accountability Project

The Work After March

A dated record, not a rewritten origin story.

Some entries document actions the Project took. Others document research or analysis that changed how we understand a problem. The distinction matters. Each update is labeled so readers can tell the difference between a letter that was sent, a finding under review, a public clarification, and an exploratory workstream.

AUG 15 2026

DOCUMENTSPUBLIC USEPAYER / POLICY

Public-use document set refreshed and aligned with the Project’s current framing.

The payer brief and current public-action templates were updated to distinguish legitimate provider-business representation from practitioner, scientific, consumer, and field-wide authority; to use CMS’s quality-measurement language precisely; and to make conflicts of interest and commercial overlap visible without treating them as proof of misconduct.

The March 2026 Position Statement remains unchanged.
Exploratory research on outcome-measurement frameworks remains internal unless it becomes directly relevant to payer policy.
Earlier correspondence to professional bodies remains preserved as dated historical correspondence. The Project is not launching a second send-your-own campaign to those organizations.
Working spreadsheets, research trackers, and internal crosswalks are not being published as public products.
The next institutional step under consideration is broader professional and scientific scrutiny, including a potential multi-author call-to-action paper.

Current public documents →

Aug. 142026

ClarificationGovernance

Representation clarified: influence is not the same thing as representation.

The Project refined an important part of its original framing. The concern is not that CASP is a 501(c)(6) trade association. Trade associations are normal and useful. The accountability question is whether recommendations from an association representing provider businesses are later treated as though they also represent practitioners, scientists, families, autistic people, or the ABA field as a whole.

Provider-business representation, practitioner representation, scientific authority, consumer voice, and field-wide authority are different functions.
The Project's concern is role clarity, independence, and what happens when one constituency's influence travels farther than its actual mandate.
This clarification applies to later Project work; it does not silently amend the March statement.

Current Project documents → Governance visuals →

Aug. 142026

AnalysisWorkforce

Frontline accountability review: what was the RBT credential built to do?

The Project traced the RBT credential from its creation as an externally verifiable frontline standard through the current patchwork in which substantially similar direct-care work may still be performed under generic behavior-technician pathways, depending on payer, state, employer, and accreditation rules.

The BACB built the RBT credential around standardized eligibility, training, competency, supervision, ethics, verification, and discipline.
ACQ's 2022 standards allow an internal training-and-competency pathway in lieu of an RBT or equivalent credential where regulations permit.
The unresolved accountability question is not whether every technician must follow one career path. It is who owns and enforces the minimum qualification for people delivering core treatment.

Documents & supporting work → Sources →

Aug. 13–142026

AnalysisAccreditation

Accreditation findings expanded beyond the question of whether a seal exists.

The Project's accreditation work shifted toward a more useful payer question: what does the accreditation actually require, who governs it, and what protections remain outside the seal? Current work compares organizational standards, governance composition, workforce requirements, clinical-control safeguards, outcomes expectations, and the practical cost of making accreditation a participation gate.

ACQ's published standards distinguish scored accreditation requirements from Recommended Practices.
The Project began comparing multiple ABA/autism accreditation approaches rather than treating any one private program as the automatic benchmark.
Governance reviews now ask who is literally at the table across CASP, BACB, APBA, ABAI, and ACQ — and whether that composition matches the authority being exercised.

Accreditation work → See the governance diagrams →

Aug. 2026CMS Toolkit

CrosswalkFederal Policy

CMS released a Medicaid & CHIP ABA Toolkit. The Project mapped it against the accountability gaps already under review.

CMS's August 2026 toolkit addresses clinical standards, provider qualifications, ownership, supervision, utilization management, organizational accreditation, site visits, fraud/waste/abuse, and managed-care oversight. The Project built a verified crosswalk to identify where the federal toolkit reinforces existing concerns — and where important governance questions remain unresolved.

The toolkit reports that from 2021–2025, the number of children with ASD receiving ABA increased 189% while ABA spending for children with ASD increased 421%.
CMS expressly frames the toolkit as decision support for states, not as a clinical standard of care.
The Project is using the toolkit as a federal policy baseline, not as proof that every Project recommendation has already been adopted.

The Project’s detailed CMS standards/accountability crosswalk remains an internal working research tool. Public findings are summarized in finished Project materials rather than publishing the working spreadsheet.

Public CMS / payer materials → Federal sources →

CMS ABA Toolkit accountability crosswalk

Aug. 2026Payer Work

Payer PolicyAnalysis

Payer work moved from “please fix ABA” to concrete safeguards payers can already require.

The payer brief now focuses on tools already available through provider contracting, credentialing, utilization management, and network participation — rather than waiting for a new law, a new accreditor, or a new national governing body.

Clinical operations directed by credentialed clinicians with real authority.
Frontline credentialing, experienced clinical leadership, beneficial-ownership and functional-control disclosure.
Site visits at actual service-delivery locations, intensity-tiered oversight, meaningful outcomes review, and clear modality expectations.
An independence test before any private accreditation seal becomes a payer or regulatory participation gate.
Network-adequacy and implementation costs treated as part of the requirement — not as somebody else's problem.

Payer brief & public letters →

Aug. 2026California

Sent / PreparedState Oversight

State-level payer and regulator outreach expanded alongside the federal work.

The Project developed California Medi-Cal / DHCS correspondence addressing ABA provider standards and oversight, while continuing to build reusable payer and regulator materials that can be adapted across jurisdictions.

Letters & policy materials →

July 152026

MediaEmail Update

Rad N Bad Podcast: “Who the Hell is Steering this Profession?”

The ABA Accountability Project was featured on the Rad N Bad Podcast for a long-form discussion of private equity, CASP, accreditation, field governance, and the question behind the Project: who has authority to speak for ABA — and who decided?

A Project email update announced the episode to the mailing list.
The website added a “New here from Rad N Bad?” pathway so podcast listeners could move directly from the conversation to the underlying documents and sources.

Podcast & media page → Documentation behind the episode →

June 62026

SentCMS

Federal oversight request sent to CMS.

The Project asked CMS for federal review and guidance on Medicaid ABA oversight, provider qualifications, service classification, ownership transparency, clinical control, treatment intensity, caregiver involvement, and accreditation independence.

The letter framed the issue as beneficiary protection, program integrity, and federal expenditure — not merely an internal professional dispute.
It asked CMS to distinguish clinical ABA from transportation, respite, recreation, passive supervision, and other nonclinical support services.
It also requested stronger ownership/control disclosure and an independent multi-stakeholder review rather than allowing any provider trade association to stand in for the field as a whole.

Federal correspondence →

May 2026Workstream

ExploratoryOutcomes

Outcome measurement became its own accountability question.

The Project began separating “an organization measured something” from “treatment produced meaningful benefit.” Early work examined existing outcome-standard frameworks and compared standards-development features against Institute of Medicine criteria such as transparency, conflicts of interest, stakeholder composition, evidence review, external review, and updating.

This remains an exploratory workstream, not a Project-endorsed national outcome set.
The longer-term question is whether payers can require meaningful, independently interpretable outcomes without rewarding sterile clinic metrics or simplistic hour-cutting.

Spring2026

CorrespondenceProfessional Bodies

The Project began asking each institution to state what role it actually owns.

Letters to professional and scientific bodies asked a narrower question than “who should run ABA?”: What responsibility does each organization accept for science, practitioner representation, certification, clinical guidance, organizational standards, and public accountability — and where does its authority stop?

The Project is not asking one organization to replace all the others.
The emerging model is one of checks and balances among scientific, professional, business, payer, consumer, credentialing, and regulatory interests.

Professional-body letters →

March2026

Anchor Document

The Position Statement was issued — and this is where its text stops.

The March 2026 Position Statement documented the Project's original governance concerns and call for independent accountability. It remains available exactly as the document endorsers reviewed. Everything above this entry is later Project work.

Read the locked statement → Sources & references →

What Belongs Here Next

If the Project learns it after March, it gets a date — not a stealth edit.

Future correspondence, payer tools, corrections, research findings, media appearances, subscriber emails, and new workstreams should be added to this stream when they become public or materially change the Project's analysis. For questions, source corrections, or documents that should be added, contact WhoRepresentsABA@gmail.com.