2022 Standards And New Accreditation Model With Dr. Ellie Kazemi

Aug 4, 2022

On July 1, BHCOE launched its new standards for applied behavior analysis (ABA) and introduced changes to its accreditation process. It has updated its standards to improve understandability and has brought greater focus to clinical practices on the path to quality ABA services. In developing the new standards and making changes to its accreditation process, BHCOE listened carefully to the ABA community and relied on its growing body of knowledge including seven years and more than 100,000 data points about the practices that result in quality ABA services.

In this podcast, Dr. Ellie Kazemi joins Sara Litvak and Anna Bullard to discuss the following changes in BHCOE’s 2022 Standards and new Accreditation Process:

• A newly designed digital gateway to guide providers step-by-step
• Immediate feedback to redirect providers to resources that help them meet a standard
• No reloading documents for accreditation renewals unless they have changed
• More focused, fewer survey questions
• Fewer required documents
• Even more transparency of the scoring criteria
• Greater focus on the quality of therapy sessions and the quality of services
• Scalability for organizations with fewer than 25 patients
• Additional clinic-specific data visibility for a larger organization

Listen to the Episode

2022 Standards And New Accreditation Model With Dr. Ellie Kazemi

Anna and I are here with BHCOE‘s very own Dr. Ellie Kazemi to talk about the 2022 Accreditation Standards Launch. Welcome, Ellie. It’s nice to have you back.

It’s good to be here and talk with you again.

Thanks, Ellie. We’ve got a lot of exciting things happening at BHCOE. I’m excited to dive into a lot of stuff you and your team have been working on with the 2022 standards.

I’m so excited. Ellie, I don’t want to brag, but this is like your baby. I feel like this is one of the first standard sets aside from the new training site that you launched that I am like, “I don’t know. Go ask Ellie.”

I appreciate that. I have been spending a lot of my time with a beautiful team of brilliant people. I don’t ever feel like it’s my baby. It’s our baby. You and Anna are helpful with the perspectives you offer. We’ve had a fantastic team, but I agree. The excitement is something we all share with the evaluators. They were also quite impressed and excited. I’m so happy to put it out and hopefully see how everyone responds to it. Our providers are going to find it helpful, so we’re excited about that.

I’m stoked. Before we get into what exactly those changes are, I know that anytime we make changes, we listen to the community. We have years of data points and practices that have resulted in the standards that we work off of. Can you tell us a little bit about what impacted some of the changes we’re about to discuss? What’s your process for determining the types of changes that need to be made to this standard set?

It takes a lot of time, energy, and resources to involve all the different types of stakeholders that may be impacted by any change to any standard set and accreditation that results from that. We have been fortunate to have been given the time and resources to meet with all of these different stakeholders and gather their feedback. The new standard sets are based on some of the feedback the parent and family work groups have been giving us during our meetings with them.

We have had lots of surveys from our customers that tell us what would be more helpful and what areas of strengths they would for us to keep. We’ve had a series of discussions and focus group meetings with our evaluators that has provided a lot of fantastic feedback about the barriers they have faced. Our field is ever-changing, so we’re always revisiting our items. We have an ANSI group that we have put together at BHCOE that’s overseen by ANSI Commission, so we are able to get a lot of direction from them. All of these different stakeholders have provided us with feedback. We have helped the shaping of the new standards.

BHCOE Commission is our ANSI-accredited governing body. That meeting is open to the public. Every meeting they have, any stakeholder can attend, and all of the public comments go through that group and are made public to anyone interested. I love that it’s a transparent process. Our public comment period has to be open for 45 days. You can’t close it and then announce the standards. It takes almost a year to get through all those comments.

[bctt tweet=”It takes a lot of time, energy, and resources to involve all the different stakeholders that any change to any standard set may impact, and then an accreditation that results from that.” username=”bh_coe”]

It’s been an exciting time to see that come to fruition. The first thing that I wanted to speak to before we get into the actual standards themselves is that one of the new features that are coming with the standards is a new digital gateway. I would love for you to share with all of us what that’s going to look like because, by the time everyone reads this, we will have already launched this exciting gateway.

Talk about a world where we’re moving more and more toward understanding how to utilize technology and leverage it to make things easier for the people involved. One thing that’s always difficult about any evaluation process or audit is balancing transparency, how much information the person can get, inundating it, and how much they’re feeling overwhelmed with all the amount of information that they’re getting.

The new gateway is going to make life simpler for all of our individuals interested in seeking accreditation or those coming back for re-accreditation. This was a part of the feedback we were getting from customers. They had difficulty with document uploads and sometimes had to upload the same documents repeatedly.

The beautiful part of our new gateway is that they only have to upload a particular document once. Throughout the process, they can refer back to that document or tell us that something is in that same document, which simplifies things for us and allows an archival process or for us to hold onto material as they become reaccredited. It makes life easy for everyone involved.

The other part of what I love personally about the gateway system is that it provides us with the opportunity to take anyone interested in accreditation through the process step by step. They’re able to be asked questions about their procedures, their staff, and their training. They’re able to focus on that question and answer certain things that are about that issue at hand and provide any documentation that comes with that.

That not only increases the transparency we’ve always had a name to provide, but it also decreases the effort the customer is going to feel, hopefully, on their end with getting so much information transparent but too much information, which can also be a problem. This gateway system will allow us to balance that beautifully. I’m excited about that.

Ellie, talk a little bit more about the re-accreditation because that is where we got a lot of feedback from our accredited providers. It was great to hear from them that they were frustrated with having to load the same documents in for their re-accreditation. How is this going to make that easier for them?

The fact that we will be able to hold to documents they ask us to hold will be huge for them. The fact that we will be able to identify anything that’s been revised within that timeframe when and if it has been revised so that they don’t have to redo the entirety of the material. It will also be helpful for them. In short, keeping documentation attached, secure, and only for that provider, with the provider being able to choose how to utilize it, is going to make life easy for them.

The other thing I think about is the myth that our accreditation is not conducive to smaller organizations. I think that we do more smaller organizations than larger organizations. Sara talks about that a good bit, but this is also going to make this easier for smaller providers that may not have extra staff or extra hands. Everyone is dealing with that, trying to leverage the capacity that they have. This is going to help with that. Don’t you agree?

TSR 6 | BHCOE 2022 Accreditation Model

BHCOE 2022 Accreditation Model: All of these different stakeholders have provided us with feedback and helped shape the new standards.


Anna, you’re 100% right. We’re aware of the fact that we are here to provide oversight, help, quality control, distinguish, and elevate organizations that are working so hard to provide good service. We realize that they are under so much pressure at the same time with the ever-changing requirements of them, but also the workforce and the things that are going on within the workforce for them.

In every way, we try to make the process easier for them so that we can have the verifications we need and speak to the quality and their adherence to best practices but make it as easy as possible. It is a great point that you’re bringing up the smaller organizations, Anna because they have fewer resources. They don’t have an entire person often that can be devoted, for example, to a task like this.

The new gateway system allows for them to get questions. We have created a unique process for smaller organizations. The exciting news is that, in the past, we had called these different names. We had tried to help them come along the path in a different manner. We don’t need to do any of that because of the gateway system. We’re able to create a unique opportunity for what applies to an organization with less than 25 patients and not overburden them, and they’re still able to obtain full accreditation, which will be exciting.

The truth is if I were to start up an organization and was interested early in my organization development, much of your time, resources, and energy is put into figuring out all your documents and purely understanding how you shape up and create a good operating system for you. At the gateway, the questions, answering, and going through the accreditation will guide the smaller organization to be able to get all of that in order. I’m pretty excited about that.

Ellie, talk to me a little bit about the survey. A big part of our accreditation process is that we survey patients and staff, and then we use a lot of the data that are returned to us to benchmark providers and help them understand what’s going on. I know there have been some significant revisions to the surveys. Can you tell us a little bit about those?

Yes. That’s where the seven years of data you were speaking about becomes handy for us. We utilize our wonderful data analytics team led by Dr. David Cox to do a deep dive analysis of the survey responses. We’re getting to be able to tell which survey items are helping us get toward and get further information and which survey items we could get rid of or are not written well.

For some time, we’ve had to have more questions to be able to do that. In this situation where you’re not fully sure about the questions you’re going to ask, the development of the survey itself to do it well requires some trial and error with the population at hand. We have gained so much information about what’s helpful, what our patients respond better to, what items and how have we written it that allows them to answer in a correct way with regards to their services as well as when we talk, survey staff, and the supervisory level staff.

For one thing, we are asking a lot fewer questions because we’ve been able to become a lot more focused. For another, the questions will align much more clearly now with each of the standards because we’re able to focus on the things that have given us the most for each of the standards. Both of those are exciting about our newer surveys.

I was thinking about that, Ellie. We’ve talked so much about the family survey and how to improve that so that it’s not overburdensome. As a parent myself, I think that’s one of the areas where we have done such an incredible job at BHCOE. That’s always putting the family at the forefront of what we’re doing. I’m excited about that survey. Also, it’s so important for families to know that survey is helping to ensure that your provider is providing quality service to you and that your voice is heard. That piece and the changes you’ve made are exciting for me, especially.

[bctt tweet=”One thing that’s always difficult about any evaluation process or any audit is balancing between that transparency, how much information a person can get, and how much they’re feeling overwhelmed with the amount of information they’re getting.” username=”bh_coe”]

I very much appreciate that. We’ve gotten feedback from parents and our providers about either the length of the surveys or some of the questions. We’ve been listening. We are good at listening to the community here at BHCOE.

The other significant change, Ellie, that a lot of providers are excited about is that we are moving to a two-year accreditation with annual conformance. If you’ve been with us historically, we’ve had a 1-year, a 2-year, and a 3-year accreditation. I would love to learn a little bit more about how you came to that conclusion and some of the rationale behind it.

I’m excited about it because it will create a lot more equity across the different providers and make sure that when a parent sees the BHCOE brand, they know they’re accredited or not accredited as opposed to what level of accreditation they are. From the parent perspective, I’m excited about it, but I’m curious from the compliance and scientific perspective why we made that shift.

You nailed it. One thing that is important to us is when we think about the focus of accreditation. It is to take and develop a standard of best practices and then be able to look at organizations. For those who are adhering to those to be able to elevate them, showcase them, distinguish them, and say, “These are folks that are, in fact, doing these things.”

To do that, how we messaged that information is important to us. The messaging around 1 to 2 to 3 years was unclear. We learned a lot from parents and staff that they didn’t quite understand the differences between them. Those did not necessarily have meaning for them. From a scientific perspective, we went back to look to see if there were clear distinctions between these years of evaluation.

Although we could identify why through our evaluation process, they would have been at one versus another, the clear difference was between those in that two-year mark. We felt that putting the accreditation benchmark that you are accredited and you can be accredited for two years made sense based on the scores and the years of experience we’ve had looking at accreditation.

The other thing that’s become clear to us is our field is ever-changing. Even with the development of the diversity, equity, and inclusion standards, we were pioneers and leaders in putting those out with the standards. When we put them out, I knew there was a little bit of fear at the beginning when we did. It came mostly from the community at that time, but now, everyone recognizes it. Its importance is everywhere, like in literature and everywhere else.

We still have to stay with the ever-changing best practice, keep on top of it, and make sure that we’re reading and continuing to do that. Three years was too long. We find ourselves not able to outreach and look at things. Three years can be a lot of time to change things for organizations, particularly with scale-up and other things that may be happening for them. For all of those reasons, we thought the two-year mark was a good bit to go.

I’m excited about the shift, especially because of the impact it will have on the patients and their ability to have faith in what it means for an organization to be accredited. Another piece that I was excited about is that in your webinar and the introductory guide, you talked about this component related to attestations and the idea that there were certain documents that would no longer be required.

TSR 6 | BHCOE 2022 Accreditation Model

BHCOE 2022 Accreditation Model: The beautiful part of our new gateway is that people only have to upload a particular document once. Then throughout the process, they can refer back to that document or tell us that something is in that same document, which simplifies things for us and makes life easy for everyone involved.


A lot of providers ask us, “Why do you need this document? What does it allow you to understand about our business?” My understanding is there’s going to be a reduced load of documents uploaded. The ones uploaded are the core business or core organizational documents, and some have moved to an attestation format. I would love for you to share a little bit about the validity of using attestations. How did you decide which documents were no longer necessary?

I’m a visual person. If you could see me here in the background, my hands are up because there were lots of good sources of information that we used. One was that we looked back again at our rich database of information and documents we had been historically asking for to see if that served as a good verification point. We would know that from the scores and how much it impacted scores overall when it came to accreditations.

A number of times, potentially, an organization may have been asked to revise or do anything with those. The other source of information we had was our customer’s feedback with regards to where they found us most helpful. Our customers told us that when it came to their patient handbooks, patient intake information, getting to know their staff, organizing their policies and procedures, and tightening those up so staff understood expectations better were all areas that they felt we were strong in.

We knew what some of the must keep from that are between being able to look at all of the data that we have and evaluate how many of those we’ve been asking for. Time and time again, it results always in the past, for example, and it doesn’t provide us with much more information that was helpful. We always end up asking for additional information in these other ways. It was helpful to learn.

We took all of that information. It allowed us to truncate or get a much smaller list of documents we think we should have. It allows us to be much more in-depth there. We also got feedback from customers. Interestingly, because we used to ask for some of these documents, it made them feel accreditation was much more about their paperwork rather than service, which makes sense.

Even though we have talented board-certified data analysts with a lot of experience, we take on as evaluators that we train and work with closely, even though they’re spending a lot of their time looking at those best practice issues. When the number of things an organization is submitting is purely, dauntingly documents, it can overcast for them what the accreditation process may be. All of that told us to focus and get only documents that are helpful for you to help these organizations progress. That revealed best practices to begin with and put the focus in the right places.

I wanted to get your thoughts and your feedback. We know that our customers appreciate and benefit from all of the things we provide on the business side and the things that help them complete audits and ensure they’re in compliance with all the Federal and State guidelines. I want to talk about the clinical piece because you get a lot of questions about that. I know providers who are accredited are striving to provide the highest quality of service with best practices. How are we helping them do that, and how has that changed with the new 2022 standards?

We have focused on best practices in the clinical administration and implementation of what any provider is doing, as well as in their operations and procedures. Those things matter with clear expectations from families and staff and also making sure that the day-to-day operations make sense for a business. With regards to the improvement that we have made in that clinical area, we’re super excited to create and move toward innovative work with our observations of the sessions.

Historically, there’s a lot of literature on, “How do you carry out discrimination training and this specific type of teaching procedure?” Although that’s helpful, we come from different perspectives. We see individuals of all types and all ages being provided with all sorts of different types of services. We’ve had to go into the literature, utilize time with subject matter experts, and put a lot of time into developing.

[bctt tweet=”We have to recognize that we still have to stay with the ever-changing best practice. We have to keep on top of and make sure that we’re reading and continuing to do that.” username=”bh_coe”]

We’re looking at the reliability and validity of a tool that will help us across a session by saying, “This quality behavioral analytic work is being done here.” In my past life prior to BHCOE, working with organizations from site to site and office to the office was hard to know what was happening across them. Being able to understand what’s happening across your sites and staff groups is helpful. That’s an added bonus in this process.

Ellie, is there anything else that you think folks need to know about this new process? I’m so excited already. I can’t wait to start getting more feedback so we can work on our next iteration, hopefully not for another few years.

We are here for the long run. There are lots of great things happening with this standard set. I hope that I do not forget all of them. Some of the things I want to do is to give basic logistics. Folks reading this may be interested in starting with us soon. I want to make sure that they know some of the basic stats. We have a webinar that details all of this and shows graphs and things. I recommend that as well.

The passing score for the accreditation has moved to 80%. It’s where we found that sweet spot to be that truly differentiated our organizations based on previous documents we were getting. We feel comfortable with that because when a customer’s going through the gateway journey, they’re going to be asked questions and upload material to provide evidence of it.

The system will tell them if some of their answers and the things they have done are not going to have them meet that standard. They already will have been given an opportunity to reconsider and think if they can change things, put them into fact, and make those changes if it’s about a document and then upload a new document instead. We feel that 80% will be appropriate given the many prompts the system will give them.

In the event that an organization does not become accredited and needs to go through the process, we’ve changed it so that they can do that in 90 days. A lot of that is because we looked back at our existing organizations and the work we’ve done with the gateway. We feel that that’s enough time to be able to implement something and have some results from that implementation to be able to reapply. We’re excited about that as well. We feel that organizations will be able to do this much faster this time around and much more guided. We also have created information packets so that they can hold that in hand and be able to review things and prepare for anything they want to take care of.

As always, one valuable thing we offer here at BHCOE that I’m sometimes shocked to hear people don’t know about is that we have a compliance department where we can go through appeals and anything done through our accreditation. If, for any reason, anyone feels that something was not done correctly or there was any reason for them to feel they want that to be redone, they can always appeal. We have a great compliance system in place as well. That helps us with many things, including this.

It’s so exciting. It’s going to help organizations be able to get their accreditation sooner. For those that need more support and time, the resources are there to put their organization where it needs to be from a quality standpoint.

The goal is to give everyone high-level cliff notes of some of those changes. If you do go on our website, there is a dedicated page that outlines these changes in detail. Ellie has graciously put together a webinar. We have a crosswalk and so many resources. If you’ve been thinking about going through the process and are trying to understand it a bit better, there are a lot of resources on our website that you can access.

TSR 6 | BHCOE 2022 Accreditation Model

BHCOE 2022 Accreditation Model: The passing score for the accreditation has moved to 80%. It’s where we found that sweet spot that truly differentiated our organizations based on previous documents.


There’s also wonderful work that the team has been doing, like value-based pay models. We are excited about the accreditation process because it prepares individuals, and so much work was already done by them toward any system. The specifics of that are difficult to outline, but you, Sara, and Anna have been working hard so that we can speak up for behavior analysis and make sure we’re not left behind in this next movement in our field. As we’re doing that, I can’t help but realize how much our accreditation sets people up for success for that.

Ellie, thanks so much for coming on and sharing the updates to our 2022 standards. It’s always fun to chat with you. I hope we can get together soon in person again, but great having you on.

Before we wrap up, are there any fun weekend plans?

My husband and I are newlyweds, so we’re trying to explore new things. We did a staycation. That was fun. We got to see some things in LA. We promised to camp in our own backyard. That’s what we’re going to do.

Anna, you’ve been married forever. Are you and your husband doing that?

Me and my husband camped one time. That was a big mistake and I hated it. We’ve never camped since. I’m not sure what’s going to happen, but I prefer to stay in a hotel, but you may love it.

I’ve not done it enough in my life, so this is new and I’m looking forward to it.

I can’t wait to hear how that goes. That sounds romantic and sweet. I hope you can roast some marshmallows.


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