Abstract
To remain in compliance with the Health Insurance Portability and Accountability Act of 1996, U.S. health care providers are required to register for a National Provider Identifier (NPI). When applying for an NPI, providers must select the Healthcare Provider Taxonomy Code(s) that most closely describes the services they offer. Three distinct taxonomies describe the services offered by behavior analysts. Two of these codes, the Behavior Analyst (103K00000X) and the Assistant Behavior Analyst (106E00000X) taxonomies, specify that the health care provider must hold either a certification from the Behavior Analyst Certification Board or a state-issued credential to practice behavior analysis. The purpose of this study was to investigate the concordance between health care providers who utilize these behavior-analytic NPI taxonomy classifications and health care providers who meet the credential qualifications specified in the code descriptions. Results indicated that there are potentially more than 20,000 U.S. health care providers who do not hold the behavior analyst credentials specified in the taxonomy descriptions linked to their accounts. The implications of providers being mistakenly classified as credentialed behavior analysts and credentialed assistant behavior analysts in federal data and how the field should respond are discussed.
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Notes
In some instances, an individual health care provider who is also incorporated may need to obtain an NPI as an individual and as an organization. Individual health care providers may only obtain a single NPI; however, organizations may be eligible for multiple NPIs (Medicare Learning Network, 2016).
NPPES provides a link to the Washington Publishing Company (WPC) website on the taxonomy section of the NPI application page (www.wpc-edi.com/reference). Applicants can use this link to navigate the WPC website to find taxonomy descriptions.
Prior to October 2019, the NPPES incorrectly listed the “Behavior Analyst” taxonomy classification as “Behavioral Analyst” in their registry and when applying for a new NPI number. The issue was brought to the attention of CMS by the first author and appears to have been corrected. Regardless, old records may still be found online with the incorrect label.
BACB certification is the primary qualification for licensure across states. However, additional minor requirements beyond licensure application fees are also sometimes involved (e.g., additional hours of ethics training, background checks, additional state examinations).
The licensing language included in some state statutes is not always clear on whether a non-BACB certificant can qualify for a license to practice ABA.
Both active (n = 32,870) and inactive (n = 492) BACB certificants were included in count totals because some state licensing laws only specify that an applicant for licensure pass a BACB examination, and do not clearly state whether or not the licensee needs to maintain his or her BACB credential. Of the total BACB certificant pool examined, only 1.5% were identified as inactive.
Behavior analysis licensure laws at the graduate and undergraduate levels use various titles depending on the state (e.g., behavior analyst, licensed behavior analyst, applied behavior analyst, assistant behavior analyst, licensed behavior analyst, certified assistant behavior analyst, registered assistant behavior analyst).
States where the law was unclear on whether or not a non-BACB provider may qualify for a credential to practice ABA were included in this analysis to provide the most conservative estimate possible.
This figure does not include annual data for non-BACB licensees. However, as 97% of graduate licensees were assumed to hold a BACB credential at the time of this analysis, the exclusion of these numbers is unlikely to have a large impact on the overall data trends shown.
The publicly available NPI file does provide a date for when an NPI account was last updated. However, this information is limited, as it does not indicate how the account was updated.
This value takes into consideration BCBAs who reportedly work in the following practice areas: autism (67.65%), developmental disabilities (8.33%), behavioral medicine (2.08%), other (2.12%), behavioral pediatrics (0.69%), brain injury rehabilitation (0.58%), child welfare (0.38%), and behavioral gerontology (0.14%).
Job task survey data were not available at the BCaBA level, so a similar analysis was not conducted.
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Dubuque, E.M., Yingling, M.E. & Allday, R.A. The Misclassification of Behavior Analysts: How National Provider Identifiers (NPIs) Fail to Adequately Capture the Scope of the Field. Behav Analysis Practice 14, 214–229 (2021). https://doi.org/10.1007/s40617-020-00451-w
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DOI: https://doi.org/10.1007/s40617-020-00451-w