Frequently Asked Questions

BHCOE’s expectation is that organizations accredited under previous versions of the Standards of Excellence for Applied Behavior Analysis Services work towards compliance with the new standards beginning July 1, 2022.

With regard to compliance complaints, all organizations will be held to the 2021 Standards of Excellence unless they have been evaluated under the 2022 Standards. Areas of non-compliance with the 2022 Standards will be addressed on an individual basis for those organizations accredited under previous Standards.

To calculate accreditation scores, BHCOE conducts an evaluation that reviews areas of your practice related to: Ethics and Professionalism; Equitable and Inclusive Employment Practices; Overall Business Practices, Recruitment, Hiring and Retention Practices; Patient Intake Practices; Service Delivery; Clinical Documentation, Family Involvement and Coordination of Care; Creating a Safe Working Environment; Ethical Marketing Practices; and Ensuring the Safety of Patient Information.

An organization must show conformance with the BHCOE Standards of Excellence through a variety of verification methods including interviews, direct observation of service delivery, attestation, documentation review and survey results. Depending on the Accreditation you are seeking, each verification method is weighted accordingly and contributes to the final accreditation score.

To earn an accreditation, an organization must score at least 80% on the evaluation for the accreditation they are seeking and meet all “must pass” standards.

The BHCOE Full, Telehealth, and Training Site Accreditations are valid for two years. School Accreditation is valid for one year.

Behavioral Health Center of Excellence Accreditation is an Accredited Standards Developer by the American National Standards Institute (ANSI). As such, we are required to comply with the essential requirements and policies of ANSI in our standards development activities.

BHCOE’s standards development policies are outlined in our “POLICIES & PROCEDURES FOR THE DEVELOPMENT OF AN AMERICAN NATIONAL
STANDARD” (found on our website at: bhcoe.org/standards/standard- development/) in line with the “ANSI Essential Requirements: Due process requirements for American National Standards.” Where the BHCOE operating principles and procedures are silent on an issue, ANSI’s Essential Requirements document shall serve as the precedent document.

BHCOE established the BHCOE Standards of Excellence to reflect best practices in applied behavior analysis service delivery and were developed via review of available peer-reviewed literature, best-practice literature, and state and federal law as well as review by subject matter experts and relevant stakeholders.

The BHCOE Commission oversees the development of the BHCOE Standards of Excellence and other standards and is responsible for approving the improvement and revision language for the BHCOE Standards of Excellence. The BHCOE Standards Coordinator coordinates the activities of the BHCOE Commission and coordinates subcommittees when needed. The BHCOE Commission maintains the process, appeals, interpretations, self-assessment guidance, and other training and education activities relevant to the BHCOE Standards of Excellence. The BHCOE Standards Coordinator, BHCOE Commission and subcommittees must comply with the ANSI requirement for openness, balance and due process. The BHCOE Commission will also serve as the “consensus body” for the purpose of documenting consensus on all American National Standards developed by BHCOE.

BHCOE’s exhaustive policies and procedures for the development of the American National Standard can be found on BHCOE’s website. BHCOE’s accreditation policies and procedures are continuously reviewed and updated. Accordingly, this manual may contain outdated information. To receive the most current information, please visit the BHCOE website, bhcoe.org, or contact BHCOE directly at standards@bhcoe.org.

The BHCOE evaluation is like going to the doctor. You pay for the check-up, NOT for the diagnosis. Payment does not impact whether an organization will become a Behavioral Health Center of Excellence. The cost is a flat fee for the evaluation based on the size of the agency and the number of locations. To learn more about the cost for your organization, you may email info@bhcoe.org or schedule a call to discuss.

The evaluation is conducted via the Accreditation Gateway, our online platform that guides you through each stage of the evaluation process, covering each verification method including attestations, document review, survey, observation, and interview. Your responses to each of these verifications are evaluated by our clinical evaluators. Clinical evaluators area Board Certified Behavior Analysts who have at least 5 years of experience in a leadership position at an ABA organization and/or have providedOrganizational Behavior Management consultation services. All evaluators are trained by BHCOE to provide impartial and constructive feedback throughout the evaluation process.

As part of the evaluation process, evaluators and necessary BHCOE personnel have access to confidential information such as patient records, collectively referred to as protected health information (PHI). As a Business Associate as defined in the Health Insurance Portability and Accountability Act (HIPAA), BHCOE will ensure that its personnel fully comply with requirements under HIPAA. Further, every agent, employee, subsidiary, and affiliate of BHCOE to whom PHI is disclosed will be required to fully comply with HIPAA and will be bound by written agreement to the same restrictions and terms and conditions.

The service recipients of organizations who are subject to HIPAA enforcement are protected under section 45 CFR 164.506 of the HIPAA Privacy Rule in which health care operations for certain administrative, financial, legal, and quality improvement activities of a covered entity are necessary to run its business and to support the core functions of treatment and payment. These activities, which are limited to the activities listed in the definition of health care operations at 45 CFR 164.501, include:

• Conducting quality assessment and improvement activities, population-based activities relating to improving health or reducing health care costs, and case management and care coordination;
• Reviewing the competence or qualifications of healthcare professionals, evaluating provider and health plan performance, training health care and non-healthcare professionals, accreditation, certification, licensing, or credentialing activities”
• “Health care operations” are certain administrative, financial, legal, and quality improvement activities of a covered entity that are necessary to run its business and to support the core functions of treatment and payment.

In addition, consumers are notified prior to survey administration that the response to the survey is voluntary and will not affect their services in any way. They are also provided with an “opt-out” option at the initial point of contact.

The Behavior Analyst Certification Board® (BACB®) certifies individual practitioners of applied behavior analysis services whereas BHCOE accredits organizations that provide applied behavior analysis services. These organizations may employ BACB certified individuals.

BHCOE provides ample resources for organizations to prepare prior to their evaluation. The BHCOE Learning Hub includes many valuable resources for meeting our Standards. Organizations gain access to the BHCOE Learning Hub upon signing their letter of engagement. Additionally, the Knowledge section of the Accreditation Gateway offers many resources regarding the evaluation process, the Standards of Excellence, and ways to get support during the evaluation process.

BHCOE is not able to provide consultation or coaching services for organizations hoping to pursue accreditation in the future.

No. Accreditation is specific to the applied behavior analysis component of your organization. If your organization provides additional services such as occupational therapy, speech and language therapy, physical therapy, etc. The BHCOE evaluation will review only those practices in your ABA service delivery branch and only the ABA services will be accredited. Additionally, separate offices or clinic locations are evaluated independently. An organization can choose to accredit all locations or select locations.

While the Standards of Excellence were developed to guide ABA services delivered in a tiered service delivery model, organization’s using a professional behavior analyst only model (e.g., BCBA only) may be eligible for accreditation. To find out more, please contact standards@bhcoe.org.

Recording interviews is an important component of BHCOE’s internal quality assurance process. BHCOE regularly conducts inter-observer agreement (IOA) on evaluations to ensure that findings are scored fairly and appropriately. This helps our organization maintain a high standard of reliability in our accreditation scoring process.

1. Liability Reduction: accreditation reduces the risk of allegations of negligence, professional misconduct, and breach of confidentiality — the costs of which can far exceed the cost spent on accreditation.

2. Compliance with Funders: Many funders are moving towards requiring health care providers to hold accreditation for their organization. BHCOE has seen this in some states. Organizations already accredited by BHCOE may be compliant and need not undergo any additional surveys or inspections. In addition, other accreditations are much more expensive. BHCOE is priced as the most affordable accreditation that reviews the clinical and administrative practices.

3. Reimbursement Rate Negotiations: Accreditation is currently a voluntary peer review process. It’s a great way to approach your funder for a rate increase to show compliance with quality standards and efficiency of your services. Rate negotiations likely only occur during the re-credentialing period. Providers should think about what the insurance business wants and where your organization fits in. On top of that, ABA providers must prove they’re an asset to the network and show how their services are vital to the network’s survival (for instance, through cost savings). The trick is to convey this information with as much hard data and analyses as possible. A provider can’t simply approach an insurance payer and say, “Can we have an increase?” Instead, an organization needs to come to the negotiating table with numbers, figures, arguments, and, most importantly, strategy. Insurance payers have a much harder time saying no to numbers. The BHCOE Accreditation process is built to address this by providing your organization with sustainability data and client outcome. Most of the providers who have been successful in rate increases have taken their BHCOE Accreditation report to their negotiation meetings, along with other supporting documents (e.g. letters of support, etc.).

Organizations receiving a non-accreditation decision may appeal to re-score their accreditation review within 30 days of completion of the debrief call. If approved, the rescore is conducted by an alternate evaluator. All appeal decisions are final. Click here for the audit rescore form.

Behavioral Health Center of Excellence (BHCOE) is always looking for new community members who are passionate about Applied Behavior Analysis and the implementation of quality standards within our community. To learn more, please send your CV or letter of interest to info@bhcoe.org.