By Matt Harrington, BCBA · Behaviorist Book Club · Research-backed answers for behavior analysts
The six ACT core processes are acceptance, cognitive defusion, present-moment awareness, self-as-context, values clarification, and committed action. Together, they build psychological flexibility — the capacity to contact the present moment fully and act in ways consistent with one's values. Within a behavior analytic framework, these processes are conceptualized through functional contextualism and relational frame theory. They complement operant principles by addressing the verbal-behavioral functions of private events — thoughts and emotions — that influence overt behavior without relying on mentalistic explanations.
ACT components can be incorporated within standard ABA session billing when they are functionally linked to the client's behavior analytic treatment goals and delivered by a BCBA operating within their scope of competence. The service code used should reflect the primary service being delivered — behavior reduction, skill acquisition, caregiver training — with ACT-based strategies as the implementation method. Separate billing for ACT as a distinct psychological service would require appropriate credentialing beyond the BCBA certification. Consult your payer agreements and legal counsel for jurisdiction-specific guidance.
HIPAA-compliant platforms require a Business Associate Agreement (BAA) with the provider and technical safeguards including end-to-end encryption, access controls, and audit logging. Common platforms that have offered BAAs for healthcare use include Zoom for Healthcare, Doxy.me, SimplePractice, and Microsoft Teams for Healthcare. Standard consumer versions of video platforms — including basic Zoom accounts — do not meet HIPAA requirements without BAAs. Behavior analysts should verify that their organization has an active BAA with the platform and document this in their compliance records.
Telehealth suitability assessments should evaluate safety (presence of challenging behavior requiring physical intervention), technology access (device, internet, privacy), caregiver capacity to facilitate sessions, client learning history with remote instruction, and the behavioral targets on the client's treatment plan. Some targets — particularly those requiring physical prompting, highly controlled environmental arrangements, or real-time safety management — are better suited for in-person delivery. Document your rationale clearly, review it at each authorization period, and update it as the client's presentation changes.
Values clarification in family-based ABA involves structured conversations and exercises that help caregivers identify what matters most to them in their role — connection, independence, safety, participation in community activities. These values then anchor the treatment goals: rather than targeting behaviors because they appear on a standardized curriculum, targets are chosen because they move the client closer to a life that reflects the family's stated values. This approach improves caregiver buy-in, increases treatment validity, and creates more durable motivation for implementing behavior change programs at home.
Informed consent for ACT-based telehealth services should cover: the nature of telehealth delivery and its differences from in-person services, confidentiality limitations specific to remote platforms, the availability of in-person alternatives, the acceptance-based nature of ACT and how it differs from exclusively contingency-focused interventions, the client's right to withdraw consent at any time, and billing and cost information. For clients with limited English proficiency or caregivers with literacy barriers, consent must be provided in accessible formats. Document that consent was obtained and that the caregiver had the opportunity to ask questions.
Emergency telehealth waivers issued during the COVID-19 public health emergency expanded reimbursable telehealth services, temporarily waived certain in-person requirements, and allowed cross-state service delivery in many jurisdictions. As PHE waivers have expired or been modified, behavior analysts must verify the current telehealth policies of each payer — Medicaid, private insurance, and managed care organizations — rather than assuming pandemic-era rules remain in effect. State licensing board rules around delivering services across state lines have also been re-established in many states. CASP and ABAI continue to publish updated guidance.
Several BACB Ethics Code sections apply directly to telehealth: 2.01 (Providing Services Within Competence), 2.15 (Maintaining Current Knowledge), 4.07 (Informed Consent and Assent), and 3.10 (Conflicts with Third-Party Payers). Additionally, 4.11 (Documenting Service Delivery) is especially relevant because telehealth records must demonstrate session content, duration, and format. Section 6.01 (Responsibility to the Profession) applies when behavior analysts are navigating emerging regulatory guidance and must advocate for evidence-based policy at the payer and regulatory level.
Committed action plans can be developed, implemented, and monitored via telehealth with appropriate adaptations. The behavior analyst collaborates with the caregiver to identify specific behavioral steps linked to stated values, builds the steps into naturalistic routines observable via video, and uses data shared by caregivers between sessions — via app-based data collection, photos, or brief video clips — to monitor progress. Telehealth may actually enhance committed action fidelity by allowing behavior analysts to observe implementation in the natural environment rather than a clinical analog, increasing ecological validity and reducing generalization barriers.
Begin by building foundational knowledge through ACBS (Association for Contextual Behavioral Science) training materials, ACT workshops offered at ABAI or state conferences, and peer-reviewed literature on ACT in behavior analytic contexts. Seek supervision or consultation from a BCBA with demonstrated ACT competence before implementing ACT strategies with clients. Document your training in your professional development records. Review the ethics code regarding scope of competence carefully, and obtain explicit consent from clients and caregivers before incorporating ACT-based approaches into their treatment plans.
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All behavior-analytic intervention is individualized. The information on this page is for educational purposes and does not constitute clinical advice. Treatment decisions should be informed by the best available published research, individualized assessment, and obtained with the informed consent of the client or their legal guardian. Behavior analysts are responsible for practicing within the boundaries of their competence and adhering to the BACB Ethics Code for Behavior Analysts.