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Frequently Asked Questions About Billing, Social Media, and Advertising Ethics

Source & Transformation

These answers draw in part from “Billing, Social Media, and Advertising” by Carobeth Zorzos (BehaviorLive), and extend it with peer-reviewed research from our library of 27,900+ ABA research articles. Clinical framing, BACB ethics code references, and cross-links below are synthesized by Behaviorist Book Club.

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Questions Covered
  1. What are the most common billing errors in ABA practice?
  2. Can I share client progress on social media if I do not use the client's name?
  3. How should I handle online reviews from clients?
  4. What claims can I make about ABA treatment outcomes in my advertising?
  5. Is it ethical to accept social media friend or follow requests from current clients?
  6. What are my obligations if I discover billing fraud in my organization?
  7. How should I represent my credentials in advertising and on social media?
  8. Can I use client testimonials in my advertising with their consent?
  9. What should I include in a social media policy for my practice?
  10. How do billing ethics intersect with social media and advertising?
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1. What are the most common billing errors in ABA practice?

The most common billing errors include upcoding (billing for a higher-level service than was provided), billing for time that was not spent in direct service or supervision, misrepresenting the credential level of the service provider, billing for services that were not rendered or were significantly different from what was documented, unbundling services that should be billed under a single code, and using incorrect modifier codes. Some of these errors result from misunderstanding billing codes, while others reflect organizational pressure to maximize revenue. Both are problematic because the BACB Ethics Code (2022) requires accuracy in billing regardless of the reason for the inaccuracy.

2. Can I share client progress on social media if I do not use the client's name?

Removing a client's name does not necessarily protect their identity. The BACB Ethics Code (2022) requires maintaining confidentiality (2.06), and this standard is not based on whether you used the client's name but on whether a reasonable person could identify the client from the information shared. Details such as age, diagnosis, geographic area, specific behaviors, or treatment approaches can allow clients to be identified by those who know them. Before sharing any clinical content on social media, apply a rigorous standard: could anyone who knows this client or family recognize them from this content? If there is any possibility, do not share it.

3. How should I handle online reviews from clients?

The BACB Ethics Code (2022) prohibits soliciting testimonials from current clients (5.04). Unsolicited reviews on platforms like Google are largely outside your control. When responding to reviews, never confirm or deny that the reviewer is a client, as this would violate confidentiality. Positive reviews can be acknowledged with a general professional response that does not confirm the reviewer's client status. Negative reviews should be handled carefully. A brief, professional response that avoids disclosing any clinical information and invites the reviewer to contact you directly is appropriate. Never engage in detailed public exchanges about clinical matters.

4. What claims can I make about ABA treatment outcomes in my advertising?

Advertising claims about treatment outcomes must be truthful, supported by evidence, and not misleading. You can reference the general evidence base supporting ABA as an effective treatment for specific populations, but you should not guarantee specific outcomes for individual clients, imply that all clients will achieve particular results, use before-and-after narratives that exaggerate or misrepresent typical outcomes, or make claims about your personal success rates without supporting data. The BACB Ethics Code (2022) requires that public statements about services be based on appropriate knowledge and that they not be deceptive or misleading (5.01, 5.02). When in doubt, err on the side of understating rather than overstating likely outcomes.

5. Is it ethical to accept social media friend or follow requests from current clients?

Accepting social media connections from current clients creates potential ethical issues related to multiple relationships (Ethics Code 1.11), confidentiality (2.06), and professional boundaries. Viewing a client's personal social media content can create dual relationship dynamics and introduce information into the clinical relationship that the client may not have intended to share with their provider. Similarly, the client seeing your personal social media content may alter the professional relationship. The safest practice is to maintain separate professional and personal social media presences and to decline personal connection requests from current clients while directing them to your professional page or profile.

6. What are my obligations if I discover billing fraud in my organization?

If you discover billing fraud within your organization, you have ethical obligations under the BACB Ethics Code (2022) to address the issue. Core Principle 3.08 requires behavior analysts to take reasonable steps when they become aware of practices that threaten the welfare of clients or the profession. Begin by documenting what you have observed and raising the concern through your organization's internal channels. If internal reporting does not resolve the issue, you may need to report to external bodies including the BACB, state licensing boards, and potentially law enforcement, as billing fraud may be a criminal offense. Consult with legal counsel about whistleblower protections in your jurisdiction before making external reports.

7. How should I represent my credentials in advertising and on social media?

The BACB Ethics Code (2022) requires that credentials be represented accurately in all public communications (5.02). Use only credentials you have actually earned and maintain. Do not imply specializations, certifications, or expertise that you do not possess. Use your BACB designation correctly according to BACB guidelines for credential use. If you hold state licensure, represent it accurately including the issuing state. Avoid vague or inflated titles such as behavioral expert or autism specialist unless these are formally credentialed designations in your jurisdiction. When listing professional affiliations, ensure they are current and accurately described.

8. Can I use client testimonials in my advertising with their consent?

The BACB Ethics Code (2022) prohibits soliciting testimonials from current clients (5.04) because the power differential in the therapeutic relationship may compromise the voluntariness of consent. Testimonials from former clients are permissible if the individual provides genuine informed consent that is free from any real or perceived pressure. However, practitioners should exercise caution. Even with consent, testimonials may implicitly promise outcomes that are not guaranteed, may influence prospective clients' expectations in ways that are difficult to manage, and may compromise the former client's privacy if they are recognizable. Written testimonials that are anonymous and reviewed for accuracy are generally less ethically problematic than video testimonials or those with identifying details.

9. What should I include in a social media policy for my practice?

A practice social media policy should address who is authorized to post on behalf of the practice, the approval process for content before publication, confidentiality requirements including a prohibition on sharing identifiable client information, guidelines for responding to online reviews and comments, rules about social media connections with current and former clients, requirements for accurate credential representation, guidelines for distinguishing professional opinions from established facts, procedures for addressing policy violations, and regular review schedules for updating the policy. All staff should be trained on the policy and sign an acknowledgment. The policy should be reviewed at least annually to address changes in platforms and professional standards.

10. How do billing ethics intersect with social media and advertising?

The intersection is primarily about consistency and truthfulness. If your advertising represents that you provide certain services, your billing should reflect those same services. If your social media presents your practice in a certain light, your actual billing practices should match that presentation. Discrepancies between how services are marketed and how they are billed create ethical and legal risks. For example, advertising comprehensive ABA therapy while billing primarily for lower-level services may constitute misleading advertising. Similarly, advertising specialized services that your practice does not actually provide creates expectations that cannot be met. The BACB Ethics Code (2022) requirement for truthfulness applies across all of these domains simultaneously.

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Research Explore the Evidence

We extended these answers with research from our library — dig into the peer-reviewed studies behind the topic, in plain-English summaries written for BCBAs.

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Clinical Disclaimer

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.

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