By Matt Harrington, BCBA · Behaviorist Book Club · April 2026 · 12 min read
The convergence of telehealth service delivery and Acceptance and Commitment Training (ACT) represents one of the most significant practice evolutions in contemporary applied behavior analysis. When the COVID-19 pandemic accelerated the shift to remote services in early 2020, behavior analysts faced an urgent dual challenge: maintaining clinical fidelity while simultaneously learning new delivery modalities. This webinar, facilitated by CASP's Telehealth Task Force, captures a pivotal moment in the field's adaptation — a live Q&A where practitioners sought real-time guidance on billing practices, service models, and the clinical application of ACT principles in virtual environments.
ACT is a third-wave behavioral intervention grounded in relational frame theory and functional contextualism. Its six core processes — psychological flexibility, acceptance, defusion, present-moment awareness, values clarification, and committed action — provide behavior analysts with a framework for addressing the psychological barriers that frequently interfere with skill acquisition and behavior change. When delivered via telehealth, these processes require thoughtful adaptation: the therapeutic relationship must be built across a screen, environmental barriers to participation become more visible, and the behavior analyst must become skilled at reading non-verbal cues through video.
The clinical significance of this content extends beyond pandemic-era necessity. Telehealth has proven to be a durable service modality that increases access for clients in rural or underserved areas, reduces transportation barriers, and can be equally effective as in-person services for many behavioral targets. Understanding how ACT principles translate to telehealth contexts equips BCBAs to serve clients and caregivers who benefit from remote delivery — not as a compromise, but as a clinically valid choice.
This session is particularly relevant for behavior analysts who supervise staff providing remote services, coordinate care with families who have limited access to in-clinic options, or who are developing hybrid service models. The integration of ACT into telehealth practice also aligns with the broader movement toward assent-based and acceptance-based interventions in ABA, making this content foundational for practitioners aiming to deliver compassionate, flexible, and effective care.
Acceptance and Commitment Training emerged from Steven Hayes's relational frame theory (RFT), which posits that human language and cognition create psychological inflexibility through experiential avoidance and cognitive fusion. Unlike traditional behavioral interventions that focus on direct contingency manipulation, ACT targets the function of private events — thoughts, emotions, and sensations — rather than their form or frequency. This distinction is critical for behavior analysts trained in operant and respondent frameworks: ACT is not opposed to behavioral principles but extends them into the domain of verbal behavior and derived stimulus relations.
Within ABA, ACT has been applied across a range of populations and settings. With clients who engage in escape-maintained problem behavior driven by anxiety, ACT-based acceptance strategies can reduce the aversive function of stimuli without requiring extinction-based procedures that may be ethically or practically challenging. With caregivers experiencing burnout, values clarification exercises can re-anchor motivation to the client relationship rather than the burden of daily demands. With behavior analysts themselves, ACT has been incorporated into supervision frameworks to address professional rigidity, burnout prevention, and values-based practice.
The telehealth context introduces specific antecedent conditions that shape how ACT processes manifest. Physical distance removes the sensory richness of in-person contact — there is no tactile feedback, proxemics are compressed into a frame, and environmental stimuli in the home may compete with session content. These conditions require behavior analysts to identify telehealth-specific discriminative stimuli for engagement, develop remote-compatible prompting hierarchies, and troubleshoot technological and motivational barriers in real time.
Billing and regulatory context in 2020 was rapidly evolving. CMS and many state Medicaid programs issued emergency telehealth waivers, temporarily expanding reimbursable service codes and waiving certain in-person requirements. CASP's Telehealth Task Force played a central role in aggregating this information and communicating it to providers. The inclusion of legal expert Jenna Minton, Esq. in this panel reflects the complexity of navigating insurance, licensing reciprocity, and HIPAA-compliant platform requirements — all of which intersect with the clinical delivery of ACT-based services via video.
For behavior analysts implementing ACT-based strategies in telehealth settings, several clinical adaptations are essential. First, the values clarification component of ACT must be operationalized with sufficient specificity to be meaningful within a behavioral framework. Rather than treating values as abstract constructs, practitioners should work with clients and caregivers to identify observable, measurable behaviors that are consistent with stated values. For example, a caregiver who values 'being present' might operationally define that as maintaining shared attention during five-minute play intervals without checking their phone — a target that can be tracked, shaped, and reinforced during remote sessions.
Defusion techniques, which aim to alter the behavioral function of problematic verbal behavior, can be adapted for telehealth through structured verbal exercises, written reflection prompts shared via screen, or caregiver-mediated practice in the home environment. The behavior analyst facilitates these processes by reinforcing contact with defusion language, prompting perspective-taking, and reducing the social validity barriers that sometimes make ACT exercises feel unfamiliar or uncomfortable for clients and families.
Committed action — the ACT process most directly aligned with traditional behavioral intervention — involves building patterns of effective behavior linked to personal values. In telehealth contexts, committed action plans are particularly powerful because they are developed in or near the client's natural environment. The home setting provides immediate access to relevant antecedents and consequences that may not be observable in a clinic. Behavior analysts can use this ecological validity to identify specific environmental barriers, prompt caregiver implementation, and observe the natural reinforcers already present in the home that can support behavior change.
Present-moment awareness, another ACT core process, can be facilitated through brief mindfulness-based exercises at the start of remote sessions to improve focus, reduce caregiver-reported stress, and increase responsiveness to the session content. These exercises should be delivered within a behavioral conceptualization — framing them as behavior with functional antecedents and consequences — rather than as spiritually framed practices, to maintain consistency with the science of behavior analysis.
The ABA Clubhouse has 60+ on-demand CEUs including ethics, supervision, and clinical topics like this one. Plus a new live CEU every Wednesday.
The delivery of telehealth services, particularly those incorporating ACT-based psychological flexibility interventions, carries distinct ethical responsibilities outlined in the BACB Ethics Code (2022). Section 2.01 requires that behavior analysts provide services only within their scope of competence based on education, training, supervised experience, and study. For practitioners new to telehealth delivery or ACT application, this section requires honest self-assessment and potentially additional training or consultation before implementing these approaches with clients.
Section 2.15 addresses the requirement to apply and maintain current knowledge, which in the telehealth context means staying current with HIPAA-compliant platform requirements, state-specific telehealth regulations, and insurance billing codes. As emergency waivers introduced during the pandemic sunset or are modified, behavior analysts must proactively update their knowledge rather than relying on assumptions about what remains permissible.
Section 4.07 addresses the requirement to obtain informed consent for services and specifically requires disclosure of service limitations. When delivering services via telehealth, this informed consent must explicitly address the modality, its limitations relative to in-person services, the technology requirements, confidentiality risks inherent in remote platforms, and the availability of in-person alternatives. For ACT-based interventions, consent should also address the acceptance and values-based nature of the approach so caregivers and clients understand what they are participating in.
Section 3.10 addresses conflicts with third parties, relevant here because billing guidance from insurers may conflict with what behavior analysts determine to be clinically necessary. Legal counsel, such as that provided by attorney Jenna Minton in this webinar, is an appropriate resource when navigating conflicting guidance. BCBAs should document their decision-making process when facing such conflicts and consult with supervisors or legal counsel before submitting claims that involve billing uncertainty. Maintaining documentation of sessions, supervision, and clinical decision-making is especially important in telehealth contexts where the paper trail may be scrutinized more carefully during audits.
Determining whether ACT-based telehealth services are appropriate for a given client or family requires a structured assessment process. The initial clinical decision point involves evaluating whether the client's behavioral targets and learning history are compatible with remote delivery. Not all clients benefit equally from telehealth: individuals with severe problem behavior that poses safety risks, or those who require intensive physical prompting, may require in-person services even when telehealth is otherwise preferred. This determination should be documented in the client's service plan with a functional rationale.
For clients and caregivers who are candidates for telehealth, a technology assessment should precede service initiation. This includes verifying access to reliable broadband internet, a compatible device with camera and microphone, a private or semi-private space for session participation, and the caregiver's basic technology literacy. Where technology barriers exist, the behavior analyst should document efforts to resolve them — including referrals to community resources for device access — before concluding that telehealth is not feasible.
Assessing the appropriateness of ACT components requires evaluation of the client's verbal behavior repertoire and the caregiver's capacity for implementing acceptance-based strategies. Clients who lack sufficient verbal repertoires to engage in metaphor-based exercises or perspective-taking may require more direct contingency-based interventions with ACT components reserved for caregiver coaching. Caregivers who are experiencing significant mental health challenges, limited support systems, or high levels of caregiver burnout may actually be the primary candidates for ACT-based intervention, with the behavior analyst targeting caregiver psychological flexibility as a prerequisite to effective child behavior management.
Decision-making around billing should follow a clear documentation protocol: the behavior analyst records the service code used, the rationale for that code, the duration and content of the session, and any applicable modifiers for remote delivery. When guidance from payers is ambiguous or contradictory, the behavior analyst should contact the payer directly, document the response, and seek legal or billing consultation before submitting claims. This protects both the client's access to services and the behavior analyst's professional standing.
For behavior analysts working in or transitioning to telehealth models, this content underscores several practical commitments. First, ACT is not a separate clinical modality — it is an extension of behavioral principles that can be integrated into existing ABA service structures when behavior analysts have the training and clinical rationale to do so. Exploring formal ACT training through workshops, supervision, or coursework strengthens your ability to serve clients whose psychological flexibility barriers are limiting their progress.
Second, staying current with telehealth billing regulations in your state and with your specific payers is an ongoing professional responsibility, not a one-time task. Designate regular intervals — at least quarterly — to review payer guidance, CASP and ABAI position statements, and relevant state licensing board communications. Join professional association task forces or listservs where practitioners share emerging guidance in real time.
Third, telehealth service delivery creates new opportunities for caregiver coaching that often exceed what is achievable in clinic settings. Use the home environment as an asset: observe the actual antecedents and consequences operating in the client's daily environment, involve siblings and other family members who are naturally present, and build committed action plans that are embedded in the family's routine rather than extracted from it. This ecological approach strengthens generalization and maintenance of behavior change in ways that clinic-based services often cannot replicate.
Ready to go deeper? This course covers this topic in detail with structured learning objectives and CEU credit.
Telehealth Tuesday June 09 2020 — CASP CEU Center · 1 BACB Supervision CEUs · $
Take This Course →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.