Some ABA owners know if they had a good or bad month.

Some ABA owners don’t really know where things stand financially. Even fewer can point to the day they sat down, on a set schedule, and actually reviewed the budget, the financials, and the revenue cycle. Standard 3.01 is about turning that gut sense into a routine, and explicitly identifying who’s responsible for it. In a nutshell: review the money on a set schedule, understand what you’re looking for, and put someone qualified in charge of it.

If you’re just joining us, the prior posts cover folder setup, tracking, and all of Sections 1 and 2. We’re starting Section 3 (Financial Operations) with 3.01.

The standard

ACQ 3.01 (Financial and Fiduciary Management) reads: “The Organization shall: (A) Review on a predetermined schedule its budget, financial reports, and revenue cycle; and (B) Appoint an executive internally, or contract with a professional, with the relevant background and expertise to oversee its financial operations in accordance with established accounting principles and business practices.”

The guidance adds that organizations regularly assess financial key performance indicators that may include, but are not limited to,

• daily revenue and expenses,

• profit margin per hour,

• daily profit margin,

• average daily rate,

• staffing expense as a share of total expense,

• total cost of a service delivery hour,

• percentage of billed claims collected,

• days of revenue outstanding,

• total accounts receivable over time,

• and claim denial reasons.

Accounts receivable may be managed in-house or through a contracted billing company.

This standard connects to two others. Standard 1.03 (Governance and Management) establishes the broader leadership structure, including financial solvency oversight, while 3.01 covers the specific oversight of financial operations and who leads that function. Standard 4.01 (Compliance Program) covers fraud, waste, and abuse safeguards including billing; 3.01 covers the financial oversight function itself, and the internal audits supporting 4.01 are informed by the regular review described here.

What’s scored

The standard itself. Review of the budget, financial reports, and revenue cycle on a predetermined schedule, and an appointed executive or contracted professional with the relevant background and expertise to oversee financial operations.

3.01 also carries Recommended Practices: aligning financial goals with your guiding principles, annual GAAP-consistent financial audits, using practice management or EHR software compatible with your accounting system, and diversifying your payer portfolio where possible. Recommended Practices are not scored in this version of the Standards but are assessed to inform future ones. Not required for this submission.

Three items you can upload to your folder

1. Financial Review Schedule and Recent Financial Report. The predetermined schedule on which you review your budget, financial reports (P&L, balance sheet, cash flow), and revenue cycle, including how often and who participates, plus a recent report reflecting an actual review (a dated P&L, an RCM dashboard, a leadership review summary). If no written schedule exists, capture the current cadence in a brief memo. If practice and schedule differ, align them before submission.

2. Designated Financial Operations Oversight. Documentation identifying the internal executive or contracted professional overseeing financial operations: name and title (or firm), relevant background (such as CPA, MBA, or finance leadership), defined responsibilities (budgeting, financial reporting, revenue cycle, AP/AR), reporting relationship, and supporting documentation (job description, designation memo, or engagement letter). If the role is informal or shared, identify who currently fulfills it.

3. Revenue Cycle and Financial KPI Review. Evidence that you regularly review revenue cycle activity and selected KPIs, such as percentage of billed claims collected, days of revenue outstanding, total AR over time, claim denial reasons, daily revenue and expenses, profit margin, or staffing expense as a share of total expense. Track the KPIs most relevant to you; evidence can be any format in use (a dated dashboard, a billing or RCM report, a finance review summary). If this overlaps with Standard 4.01 (billing audit findings, claim accuracy review), pick one primary folder and shortcut it in the other. Aside: for Partners clients, we build reporting that structures these KPIs around core ABA operations, with visibility into whether authorized, medically necessary care is being delivered as intended.

Keep all responses brief, concrete, and observable. Everything you submit should reflect what is currently in place and in use.

How it shows up in practice

Financial oversight is easy to describe and harder to show on a rhythm. What evaluators may look for is whether reviews actually happen on the schedule you set, and whether whoever oversees finances can speak to them.

A practical version of this may look like:

• A review that lands on a set cadence, with a dated report or minutes to prove it happened.

• A named owner of financial operations with real background for the role, whether internal or contracted.

• A handful of KPIs you actually track, tied to decisions rather than filed and forgotten.

Preparedness for interview questions

Questions that may come up:

• How often are financial reviews held, who participates, and what is reviewed?

• Who oversees financial operations, and what is their background?

• Which KPIs do you track, and how do the results inform decisions?

The answers should match what is in the uploads.

On a personal note

I talk about finances a lot, and I want to be clear about why. When people discuss ethics in this field, money is often treated as the thing you set aside to be ethical. I see it the other way. Running an ethical practice means building one that is sustainable, that can afford the qualified people who handle clinical care, compliance, and standards properly, and that will still be here for its clients and team next year. That kind of stability does not happen by accident. It comes from a financially healthy organization built around clinically sound practice. Financial rigor is not in tension with ethics. It is part of how you deliver on them. Sometimes that means hard decisions, and making the right ones at the right time means understanding, managing, and monitoring finances alongside client outcomes and satisfaction, regularly, not as a side note.

For those who want more

A paid Substack tier is coming with sample documents, supporting templates, and additional resources. Partners ABA clients receive individualized pacing aligned with their team’s progress, review and feedback on each submission, and support in developing and adopting policies, standards, and practices within the scope of their service package.

What’s next

3.02 next: fee schedule. Same structure: the standard, what to upload, how it shows up in practice, what may come up in interviews.

If you know other ABA leaders who’d benefit from this series, invite them to subscribe.

As always, this is guidance based on experience, not an official ACQ communication. You’re responsible for your own interpretations and submissions. Verify everything against the current ACQ Standards and Guide.

Brandon Herscovitch, PhD, BCBA-D

partnersaba.substack.com | partnersaba.com

If you’re just joining us, the prior posts cover folder setup, tracking, and Standards 1.01 through 2.02. We’re moving to 2.03.

The standard

ACQ 2.03 (Training) reads: “The Organization shall: (A) Provide and document orientation training for new hires, with applicable checklists for their respective functions; (B) Offer and document ongoing staff training relevant to their positions and according to applicable regulations; and (C) Ensure training occurs at sufficient intervals to effectively keep staff properly updated.”

The guidance adds that training opportunities made available to staff include, but are not limited to, applicable regulations; organizational policies, procedures, and protocols; relevant ethical codes of conduct; patient rights and responsibilities; clinical standards and operations; computer systems and technology; patient communication, literacy, and cultural diversity; complaints and grievances; and health, safety, and emergency management.

This standard connects to two others. Standard 2.01 (Human Resource Management) covers the broader HR program, while 2.03 covers the training function specifically. Standard 2.02 (Recruitment and Hiring) covers hiring, while 2.03 picks up after hire with orientation and ongoing training.

What’s scored

The standard itself. Documented orientation training for new hires with function-specific checklists, documented ongoing training relevant to positions and applicable regulations, and training at sufficient intervals to keep staff updated.

2.03 also carries a couple of Recommended Practices: documenting an onboarding program with individualized department-level components, and documenting completion of diversity, equity, and inclusion training. Recommended Practices are not scored in this version of the Standards but are assessed to inform future ones. Not required for this submission.

Three items you can upload to your folder

1. Orientation Training Program and Checklists. Your written orientation training program and the checklists used to confirm completion for each function. Topical areas made available include, but are not limited to, applicable regulations; organizational policies, procedures, and protocols; ethical codes of conduct; patient rights and responsibilities; clinical standards and operations; computer systems and technology; patient communication, literacy, and cultural diversity; complaints and grievances; and health, safety, and emergency management. Checklists should fit the new hire’s function, since orientation for clinical roles may differ from administrative roles.

2. Ongoing Training Program. A written description of your ongoing staff training program, addressing training relevant to staff positions, alignment with applicable regulations, and the intervals at which training occurs to keep staff updated. If practice differs from what is written, align the two before submission.

3. Training Documentation. A representative, de-identified sample showing orientation and ongoing training are completed and recorded, for example completed orientation checklists, training completion logs by staff member, certificates of completion, or sign-in sheets or LMS reports. If this overlaps with another standard (for example 4.02 Privacy and Security training, or 5.06 Clinical Supervision), choose one folder as the primary home and place a shortcut (or equivalent) in the other so updates carry across both.

Keep all responses brief, concrete, and observable. Everything you submit should reflect what is currently in place and in use.

How it shows up in practice

Training is easy to do informally and hard to prove after the fact. What evaluators may look for is whether training actually happens on a rhythm and whether it is documented, rather than described from memory.

A practical version of this may look like:

• Orientation checklists that match each role and are actually completed and filed.

• Ongoing training on a real interval, tied to positions and regulations.

• Records that show who was trained, on what, and when.

Preparedness for interview questions

Questions that may come up:

• What does a new hire receive during onboarding, and how is completion documented?

• How are ongoing training topics selected, and how often are staff retrained?

• How is training completion tracked?

The answers should match what is in the uploads.

For those who want more

A paid Substack tier is coming with sample documents, supporting templates, and additional resources. Partners ABA clients receive individualized pacing aligned with their team’s progress, review and feedback on each submission, and support in developing and adopting policies, standards, and practices within the scope of their service package.

What’s next

That wraps Section 2 (Human Resources). Section 3 (Financial Operations) is next, starting with 3.01. Same structure: the standard, what to upload, how it shows up in practice, what may come up in interviews.

If you know other ABA leaders who’d benefit from this series, invite them to subscribe.

As always, this is guidance based on experience, not an official ACQ communication. You’re responsible for your own interpretations and submissions. Verify everything against the current ACQ Standards and Guide.

Brandon Herscovitch, PhD, BCBA-D

partnersaba.substack.com | partnersaba.com

If you’re just joining us, the prior posts walk through folder setup, tracking, and Standards 1.01 through 2.01. Reference those for the groundwork. We’re moving to 2.02.

The standard

ACQ 2.02 (Recruitment and Hiring) reads: “The Organization shall: (A) Provide equal opportunities for employment consistent with applicable regulations; (B) Verify that job candidates have qualifying backgrounds and credentials relevant to the position before hiring; (C) Conduct background checks in compliance with applicable regulations; (D) Use fair hiring practices in compliance with applicable regulations; and (E) Prohibit non-executive job candidates from signing non-compete agreements.”

The guidance adds that candidates have the background and credentials relevant to the position, for example clinical providers with ABA credentials in good standing, or anyone transporting patients with a valid license and motor vehicle insurance. Job offers are made in writing. Background checks are run on employees and contractors who contact patients or medical records, before unsupervised access is granted, and may include, but are not limited to, criminal, sex offender, and exclusions searches (such as the OIG Exclusion List), drug screenings, and identity, employment, and education verifications.

This standard connects to two others. Standard 2.01 (Human Resource Management) covers the broader HR program, while 2.02 covers the recruitment and hiring stage specifically. Standard 5.01 (Provider Credentialing) covers the ongoing provider credentialing required for service delivery and billing, while 2.02 covers verifying backgrounds and credentials at hire. The two overlap at hire but serve different functions.

What’s scored

The standard itself. Equal employment opportunity, verification of qualifying backgrounds and credentials before hiring, background checks in compliance with applicable regulations, fair hiring practices, and no non-compete agreements for non-executive candidates.

2.02 also carries Recommended Practices, covering things like applicant demographic tracking, inclusive recruitment, standardized interview questions, attorney-reviewed applications, and reference and transcript verification. Recommended Practices are not scored in this version of the Standards but are assessed to inform future ones. Worth reviewing, but not required for this submission.

Four items you can upload to your folder

1. Recruitment and Hiring Policy or Procedure. Your written recruitment and hiring policy or procedure, addressing equal opportunity employment, verification of qualifying backgrounds and credentials before hiring, written job offers, fair hiring practices, and the prohibition on non-executive candidates signing non-compete agreements.

2. Background Check Policy and Sample Records. Your background check policy and a representative, de-identified sample of completed records. Checks are conducted before giving unsupervised access to patients or medical records, and may include, but are not limited to, criminal, sex offender, and exclusions searches (such as the OIG Exclusion List), drug screenings, and identity, employment, and education verifications.

3. Credential Verification at Hire. Evidence that qualifying backgrounds and credentials are verified before hiring, for example clinical providers holding ABA credentials in good standing, or anyone transporting patients holding a valid license and motor vehicle insurance. Evidence can include a verification log, a screenshot of primary source verification, or a sample completed record. If this overlaps with Standard 5.01 (Provider Credentialing), choose one folder as the primary home and place a shortcut (or equivalent) in the other so updates carry across both.

4. Non-Compete Practice. Evidence that non-executive candidates are not required to sign non-compete agreements. Evidence can include a written statement of policy, sample offer letters for non-executive roles showing no non-compete clause, or a relevant section in the employee or personnel handbook.

Keep all responses brief, concrete, and observable. Everything you submit should reflect what is currently in place and in use.

How it shows up in practice

Hiring is a place where the process on paper and the process in practice can drift apart, especially when hiring moves fast. What evaluators may look for is whether a consistent process runs from application to offer, and whether credential and background checks actually happen before someone starts working with patients.

A practical version of this may look like:

• A hiring process that runs the same way each time, from application to written offer.

• Credential and background checks completed before a new hire has unsupervised access to patients or records, not after.

• Offer letters and handbook language free of non-compete clauses for non-executive roles.

Preparedness for interview questions

Questions that may come up:

• How does a typical hire move from application to offer?

• How are background checks initiated, where are results stored, and how are flagged results handled?

• How are credentials verified before a candidate begins work?

• How does the organization handle non-competes, and who, if anyone, signs one?

The answers should match what is in the uploads.

For those who want more

A paid Substack tier is coming with sample documents, supporting templates, and additional resources. Partners ABA clients receive individualized pacing aligned with their team’s progress, review and feedback on each submission, and support in developing and adopting policies, standards, and practices within the scope of their service package.

What’s next

2.03 next: training. Same structure: the standard, what to upload, how it shows up in practice, what may come up in interviews.

If you know other ABA leaders who’d benefit from this series, invite them to subscribe.

As always, this is guidance based on experience, not an official ACQ communication. You’re responsible for your own interpretations and submissions. Verify everything against the current ACQ Standards and Guide.

Brandon Herscovitch, PhD, BCBA-D

partnersaba.substack.com | partnersaba.com

If you’re just joining us, the prior posts walk through folder setup, tracking, and all of Section 1 (Standards 1.01 through 1.11). We’re starting Section 2 (Human Resources) with 2.01.

The standard

ACQ 2.01 (Human Resource Management) reads: “The Organization shall: (A) Implement and maintain a human resource (HR) management program that addresses key elements related to the employee experience (e.g., hiring, performance reviews, terminations, employee satisfaction) in compliance with applicable regulations; (B) Assign staff or hire consultants with appropriate level of access, experience, and expertise to manage common human resource functions; and (C) Make available an up-to-date employee or personnel handbook to its employees.”

The guidance adds that organizations determine the size and responsibilities of their HR staff based on available working capital, the size and distribution of their employee population, and their structure. For example, organizations with fewer than 15 full-time employees may not require a dedicated HR department and may outsource some functions, whereas a larger organization operating across multiple locations may need an HR team. HR functions are sometimes paired with additional responsibilities such as payroll, workplace health and safety, compliance, and provider credentialing. Organizations also have a non-discrimination policy that complies with applicable regulations and prevents discrimination based on race, color, national origin, age, disability, religious affiliation, sex (including pregnancy, sexual orientation, and gender identity), or other protected characteristics, made readily available to current and prospective employees. Employee or personnel handbooks address policies specific to each organization’s circumstances and are distributed in a timely manner when updated.

This standard establishes how your organization manages HR, who is responsible, and that a handbook is available. It sits at the head of Section 2 and connects to the two standards that follow it. Standard 2.02 (Recruitment and Hiring) covers hiring practices specifically, while 2.01 covers the broader HR program that hiring sits within. Standard 2.03 (Training) covers staff training, while 2.01 addresses HR program administration rather than the training function itself.

What’s scored

The standard itself. An HR management program addressing the employee experience (hiring, performance reviews, terminations, employee satisfaction) in compliance with applicable regulations, staff or consultants assigned with appropriate access, experience, and expertise to manage HR functions, and an up-to-date employee or personnel handbook available to employees.

2.01 also carries a long list of Recommended Practices, more than a dozen, covering things like HR credentials, handbook attestations, annual performance reviews, annual employee satisfaction measurement, demographic analysis, and separation and exit-interview practices. Recommended Practices are not scored in this version of the Standards but are assessed to inform future ones. Worth reviewing for internal alignment and to get ahead of where the standards may go, but not required for this submission.

Three items you can upload to your folder

1. HR Program Documentation and Assigned Responsibility. A written description of your HR management program, and identification of the staff member or consultant responsible for managing common HR functions. Your description should address hiring, performance reviews, terminations, employee satisfaction, and compliance with applicable regulations. Identify who is responsible, whether staff or consultant, and confirm they have appropriate access, experience, and expertise. If a written description does not exist, a one-page memo or a section within an existing operations document is sufficient. If practice differs from what is written, either update the description to match practice or update practice to match the description before submission.

2. Employee or Personnel Handbook. Your current employee or personnel handbook. Common topical areas include at-will employment; equal opportunity employment; recruiting, hiring, and promotion; standards of employment conduct; employment classifications; anti-harassment and non-discrimination; performance management and discipline; physical work environment; workplace health, safety, and security; attendance, wage and hour, and compensation; benefits, leaves, and disability benefits; meal and break periods; professional development; receipt of company property; and separation of employment. The handbook should be made available to employees and updated when policies change.

3. Non-Discrimination Policy. Your written non-discrimination policy. The policy should prevent discrimination based on race, color, national origin, age, disability, religious affiliation, sex (including pregnancy, sexual orientation, and gender identity), and other protected characteristics. Confirm the policy is readily available and clearly communicated to current and prospective employees, for example on your website, employment applications, or in the handbook. If this policy is also relevant to another standard, for example Standard 7.01 (Patient Rights and Responsibilities), which references a non-discrimination policy directed at patients, choose one folder as the primary home and place a shortcut (or equivalent) in the other so updates in one location are reflected in both.

Keep all responses brief, concrete, and observable. Everything you submit should reflect what is currently in place and in use.

How it shows up in practice

HR is one of those areas where the paper and the practice can drift apart, especially as a practice grows. What evaluators may look for is whether the HR program described is the one actually running, whether the responsible person can speak to it, and whether the handbook employees receive is the current version.

A practical version of this may look like:

• An HR program that names how hiring, reviews, terminations, and satisfaction are actually handled today, scaled to your size.

• A clear owner, staff or consultant, who can describe how HR runs day to day.

• A handbook employees can actually access, updated when policies change, with a non-discrimination policy that is easy to find.

Preparedness for interview questions

Leadership should be able to speak to the HR program with relative ease. Questions that may come up:

• How does the HR program function day to day, and who handles HR matters?

• How is the handbook distributed, and how are employees notified of updates?

• Where is the non-discrimination policy published, and how are employees made aware of it?

• Does the person responsible for HR have the access, experience, and expertise the role needs?

The answers should match what is in the uploads. If the uploads describe a program that no one on the team can describe in their own words, that is where gaps may show.

For those who want more

A paid Substack tier is coming with sample documents, supporting templates, and additional resources. Partners ABA clients receive individualized pacing aligned with their team’s progress, review and feedback on each submission, and support in developing and adopting policies, standards, and practices within the scope of their service package.

What’s next

2.02 next: recruitment and hiring. Same structure: the standard, what to upload, how it shows up in practice, what may come up in interviews.

If you know other ABA leaders who’d benefit from this series, invite them to subscribe.

As always, this is guidance based on experience, not an official ACQ communication. You’re responsible for your own interpretations and submissions. Verify everything against the current ACQ Standards and Guide.

Brandon Herscovitch, PhD, BCBA-D

partnersaba.substack.com | partnersaba.com

If you’re just joining us, the prior posts walk through folder setup, tracking, and Standards 1.01 through 1.10. Reference those if you need the groundwork. We’re moving to 1.11.

The standard

ACQ 1.11 (Testimonials) reads: “The Organization shall remain in compliance with all applicable regulations and ethical guidelines if it collects and uses testimonials from current and former patients or their caregivers.”

The guidance adds that organizations may use testimonials from current and former patients for non-advertising purposes, such as fundraising, grant applications, or disseminating information about ABA, when done in accordance with applicable regulations and ethical guidelines. Organizations do not solicit testimonials from current patients or caregivers for advertising purposes. They use testimonials from former patients or caregivers for advertising only when there is no evidence to suggest the patient will re-enter services. And they do not use or share unsolicited reviews from websites where they cannot peer review and edit the content. When testimonials are used, the guidance sets four conditions: the use complies with applicable privacy and confidentiality regulations; the use and risk have been clearly explained to the patient or caregiver; informed consent has been obtained, with notice that it may be revoked at any time and how; and a statement accompanies the testimonial indicating whether it was solicited or unsolicited and what the relationship was between the organization and the patient at the time.

This standard establishes the conditions under which your organization may collect and use testimonials, and it sits right beside two others. Standard 1.10 (Marketing Practices) covers marketing broadly, including the separation of clinical providers from marketing activities, while 1.11 covers testimonials specifically, including consent and use restrictions. Standard 7.03 (Patient Consent) covers consent for assessment, treatment, and research, while the informed consent in 1.11 is specifically for the use of testimonials, distinct from service consent.

What’s scored

The standard itself. Testimonials collected and used only in compliance with applicable regulations and ethical guidelines: no soliciting current patients for advertising, former-patient advertising testimonials only when there is no evidence of re-entry, no use of unsolicited reviews you cannot peer review and edit, and informed consent with proper disclosure whenever testimonials are used.

One item you can upload to your folder

1. Testimonials Policy and Informed Consent Template. Your written policy governing the use of testimonials, along with the informed consent template used when collecting them. The policy should address the allowed use of testimonials for non-advertising purposes (such as fundraising, grant applications, or disseminating information about ABA) when in compliance with applicable regulations and ethical guidelines, the prohibition on soliciting testimonials from current patients or caregivers for advertising purposes, the conditions under which testimonials from former patients or caregivers may be used for advertising (only when there is no evidence the patient will re-enter services), and the prohibition on using or sharing unsolicited reviews from websites where the organization cannot peer review and edit the content. The informed consent template should reflect compliance with applicable privacy and confidentiality regulations, a clear explanation of the use and risk of the testimonial to the patient or caregiver, informed consent with notification that it may be revoked at any time and how, and a statement accompanying the testimonial indicating whether it was solicited or unsolicited and the nature of the relationship between the organization and the patient at the time of the solicitation. If your organization does not collect or use testimonials, indicate that in your response. If you do but the policy or template is not yet formalized, draft both before the due date.

Keep all responses brief, concrete, and observable. Everything you submit should reflect what is currently in place and in use.

How it shows up in practice

Testimonials are where good intentions and compliance can quietly diverge. What evaluators may look for is whether your use of testimonials matches the conditions above, and whether consent and disclosure are actually built into how you collect them, rather than added after the fact.

A practical version of this may look like:

• A policy that draws the current-versus-former and advertising-versus-non-advertising lines clearly, so staff know what can be used where.

• Informed consent captured before a testimonial is used, with a clear way for the person to revoke it, and a solicited-or-unsolicited disclosure attached.

• A practice for unsolicited reviews: if you cannot peer review and edit the content, you do not repurpose it in your own marketing.

Preparedness for interview questions

Leadership should be able to speak to how testimonials are handled with relative ease. Questions that may come up:

• Does the organization use testimonials, and if so, for what purposes?

• How is informed consent obtained, and how can someone revoke it?

• How does the organization distinguish current from former patients when using testimonials for advertising?

• How are unsolicited online reviews handled?

The answers should match what is in the upload. If you do not use testimonials at all, that is a legitimate answer, and you can say so.

For those who want more

A paid Substack tier is coming with sample documents, supporting templates, and additional resources. Partners ABA clients receive individualized pacing aligned with their team’s progress, review and feedback on each submission, and support in developing and adopting policies, standards, and practices within the scope of their service package.

What’s next

That wraps Section 1 (Business Operations). Section 2 (Human Resources) is next, starting with 2.01. Same structure: the standard, what to upload, how it shows up in practice, what may come up in interviews.

If you know other ABA leaders who’d benefit from this series, invite them to subscribe.

As always, this is guidance based on experience, not an official ACQ communication. You’re responsible for your own interpretations and submissions. Verify everything against the current ACQ Standards and Guide.

Brandon Herscovitch, PhD, BCBA-D

partnersaba.substack.com | partnersaba.com

If you’re just joining us, the prior posts walk through folder setup, tracking, and Standards 1.01 through 1.09. Reference those if you need the groundwork. We’re moving to 1.10.

The standard

ACQ 1.10 (Marketing Practices) reads: “The Organization shall: (A) Accurately depict its services across its marketing initiatives; (B) Abstain from anticompetitive conduct that can harm patient access to care; and (C) Respect limitations on referrals, including not offering remuneration or compensation to current patients in exchange for assistance with patient referrals.”

The guidance adds that organizations accurately portray their scope of services as well as their providers’ expertise and experience across marketing activities. Organizations separate marketing operations from clinical operations by preventing clinical providers from soliciting or sharing testimonials from current patients for advertising purposes, participating in marketing activities during scheduled treatment hours, and publicly sharing identifying information about current or previous patients.

This standard establishes how your organization conducts marketing, and it connects to a few others. Standard 1.04 (Scope of Services) defines the scope your organization offers, while 1.10 ensures your marketing accurately reflects that scope; what you market must align with what you described in 1.04. Standard 1.11 (Testimonials) is the close cousin here: 1.10 covers marketing practices broadly, while 1.11 covers testimonials specifically, including consent and use restrictions. And Standard 7.03 (Patient Consent) covers consent for assessment, treatment, and research, while media consent, when applicable, is addressed here in 1.10 and is distinct from service consent.

What’s scored

The standard itself. Accurate depiction of services across marketing, abstaining from anticompetitive conduct that can harm patient access, respecting referral limitations (including not offering remuneration or compensation to current patients for referrals), and separating marketing from clinical operations.

There are also Recommended Practices associated with 1.10: reflecting the diversity of the community served in advertisements, including disclaimers that informed consent was collected when sharing digital content, and using protocols that govern social media representation with careful monitoring of your own accounts. Recommended Practices are not scored in this version of the Standards but are assessed to inform future ones. Worth doing for internal alignment and to get ahead of where the standards may go, but not required for this submission.

Two items you can upload to your folder

1. Marketing Practices Policy and Social Media Procedures. Your written marketing policy, including your social media procedures. The document should address how marketing initiatives accurately depict your services and your providers’ expertise and experience, how the organization avoids anticompetitive conduct that could harm patient access to care, how the organization respects limitations on referrals (including not offering remuneration or compensation to current patients in exchange for referrals), how marketing operations are separated from clinical operations (including restrictions on clinical providers soliciting testimonials from current patients, participating in marketing during scheduled treatment hours, and publicly sharing identifying information about current or previous patients), and social media procedures governing organizational accounts and clinical provider activity. If this is not yet formalized, draft a simple policy covering these elements by the due date.

2. Media Consent Templates. Your media consent templates, if applicable. Include a media consent template for patients (if patient images, video, or identifying content are used in marketing) and a media consent template for employees (if employee images, video, or identifying content are used in marketing). If your organization does not use patient or employee media in marketing, indicate that in your response. If templates do not yet exist but media is used, draft them before the due date.

Keep all responses brief, concrete, and observable. Everything you submit should reflect what is currently in place and in use.

How it shows up in practice

Marketing is one of the easier places for a gap to open between what you say and what you do. What evaluators may look for is whether your marketing actually matches your scope of services, and whether the wall between clinical and marketing operations is real rather than assumed.

A practical version of this may look like:

• Marketing claims that line up with the scope you defined in 1.04, without implying services or expertise you do not offer.

• A clear rule that clinicians do not solicit testimonials from current families, market during treatment hours, or post identifying patient information.

• Media consent handled separately from service consent, with templates on hand if you use patient or employee images at all.

Preparedness for interview questions

Leadership should be able to speak to marketing practices with relative ease. Questions that may come up:

• How are marketing materials reviewed for accuracy before they go out?

• How is the separation between clinical and marketing operations maintained?

• How does the organization handle referrals, and what is the policy on compensating patients for them?

• If you use patient or employee images, how is media consent obtained and documented?

The answers should match what is in the uploads. If the uploads describe practices that no one on the team can describe in their own words, that is where gaps may show.

For those who want more

A paid Substack tier is coming with sample documents, supporting templates, and additional resources. Partners ABA clients receive individualized pacing aligned with their team’s progress, review and feedback on each submission, and support in developing and adopting policies, standards, and practices within the scope of their service package.

What’s next

1.11 next, and it is the natural follow-up: testimonials. Same structure: the standard, what to upload, how it shows up in practice, what may come up in interviews.

If you know other ABA leaders who’d benefit from this series, invite them to subscribe.

As always, this is guidance based on experience, not an official ACQ communication. You’re responsible for your own interpretations and submissions. Verify everything against the current ACQ Standards and Guide.

Brandon Herscovitch, PhD, BCBA-D

partnersaba.substack.com | partnersaba.com

Here’s Standard 1.09 in a nutshell: carry the insurance a practice your size and type should carry, and be able to show it. This is one of the more straightforward standards, mostly a matter of pulling your current certificates of insurance.

If you’re just joining us, the prior posts walk through folder setup, tracking, and Standards 1.01 through 1.08. Reference those if you need the groundwork. We’re moving to 1.09.

The standard

ACQ 1.09 (Insurance Coverage) reads: “The Organization shall have business insurance coverage commensurate with its size and scope of services.”

The guidance adds that organizations work with insurance brokers or other insurance experts to determine the type of coverage and the size of the policies relevant to their needs across all service locations. Insurance policies may include, but are not limited to, professional liability (such as errors and omissions, medical malpractice), property and casualty, directors and officers, general liability, workers’ compensation, cyber and data privacy, and vehicle insurance. Organizations also ensure their clinical providers have appropriate professional liability coverage.

This standard establishes that your organization holds business insurance coverage commensurate with its size and scope. It is worth distinguishing from one related standard. Standard 5.01 (Provider Credentialing) covers verification of individual provider liability insurance as part of secondary source credentialing verification, while 1.09 covers organization-level business insurance coverage.

What’s scored

The standard itself. Business insurance coverage commensurate with your organization’s size and scope of services, relevant across all service locations, with clinical providers appropriately covered for professional liability.

One item you can upload to your folder

1. Certificate of Insurance Coverage. Your current Certificate(s) of Insurance Coverage. If your organization holds multiple policies, for example professional liability (errors and omissions, medical malpractice), property and casualty, directors and officers, workers’ compensation, cyber and data privacy, or vehicle, include the COI for each. Coverage should be relevant to your needs across all service locations. If you are not sure whether your coverage is commensurate with your current size and scope, this is a good moment to check with your broker or insurance expert.

Keep all responses brief, concrete, and observable. Everything you submit should reflect what is currently in place and in use.

How it shows up in practice

This one is close to a straight document pull, but the framing still matters. What evaluators may look for is whether the coverage actually fits the organization’s size and scope, across every location, rather than a single policy that no longer matches how the business has grown.

A practical version of this may look like:

• A current COI for each policy type the organization carries, covering all service locations.

• Coverage that matches the organization as it operates today, including any new locations, services, or vehicles added since the policies were written.

• Clinical providers covered for professional liability, whether through the organization’s policy or their own.

Preparedness for interview questions

Leadership should be able to speak to coverage with relative ease. Questions that may come up:

• What types of insurance coverage does the organization hold?

• How was the coverage level determined?

• Does the coverage extend across all service locations?

• How are clinical providers covered for professional liability?

The answers should match what is in the upload. If the certificates describe coverage that no one on the team can speak to, that is where gaps may show.

For those who want more

A paid Substack tier is coming with sample documents, supporting templates, and additional resources. Partners ABA clients receive individualized pacing aligned with their team’s progress, review and feedback on each submission, and support in developing and adopting policies, standards, and practices within the scope of their service package.

What’s next

1.10 next. Same structure: the standard, what to upload, how it shows up in practice, what may come up in interviews.

If you know other ABA leaders who’d benefit from this series, invite them to subscribe.

As always, this is guidance based on experience, not an official ACQ communication. You’re responsible for your own interpretations and submissions. Verify everything against the current ACQ Standards and Guide.

Brandon Herscovitch, PhD, BCBA-D

partnersaba.substack.com | partnersaba.com

If you’re just joining us, the prior posts walk through folder setup, tracking, and Standards 1.01 through 1.07. Reference those if you need the groundwork. We’re moving to 1.08.

The standard

ACQ 1.08 (Delegation of Duties) reads: “The Organization shall actively oversee all delegated or outsourced functions, retaining final oversight authority, and have a written delegation policy and agreement when it subcontracts ABA services or functions.”

The guidance adds that organizations have a delegation policy addressing how subcontractors involved with their ABA services are overseen, whether a delegated subcontractor can hire downstream subcontractors to fulfill the terms of their obligations, and how subcontractors are audited. Examples of delegated functions may include, but are not limited to, IT, billing, human resources, or accounting. Organizations may only delegate ABA services, for example to independent contractors, when permitted by applicable regulations. Organizations retain final oversight authority when subcontracting ABA services or functions, and disclose the identity of providers or other third-party entities overseeing patient care and affiliated services to patients in writing prior to engaging in services.

This standard establishes how your organization oversees delegated or outsourced functions and discloses third-party involvement to patients. A few related standards are worth keeping in mind. Standard 1.07 (Written Agreements) covers the policy and process for managing the agreements themselves, while 1.08 covers the policy for overseeing what those subcontracted functions do once an agreement is in place. Standard 4.01 (Compliance Program) covers organizational compliance overall, and the audit and oversight processes named here connect to it; 1.08 is specific to delegated functions. And Standard 7.02 (Patient Handbook) covers the patient packet provided at intake. If your patient handbook already discloses the third-party entities involved in patient care, that disclosure may satisfy the written notification requirement in 1.08.

What’s scored

The standard itself. Active oversight of all delegated or outsourced functions, with the organization retaining final oversight authority, a written delegation policy and agreement when it subcontracts ABA services or functions, and written disclosure to patients when third parties are involved in their care.

One item you can upload to your folder

1. Delegation of Duties Policy and Procedure. Your written delegation policy and procedure. The document should address how subcontractors involved with delegated functions are overseen, whether a delegated subcontractor can hire downstream subcontractors to fulfill the terms of their obligations, how subcontractors are audited, how the organization retains final oversight authority over delegated ABA services or functions, and how the identity of providers or third-party entities overseeing patient care and affiliated services is disclosed to patients in writing prior to engaging in services. If this is not yet formalized, draft a simple policy covering these elements by the due date. If your organization does not delegate any functions, indicate that in your response.

Keep all responses brief, concrete, and observable. Everything you submit should reflect what is currently in place and in use.

How it shows up in practice

Delegation is not the same as handing something off and forgetting it. What evaluators may look for is whether the organization still actively oversees the functions it outsources, and whether patients are actually told, in writing, when a third party is involved in their care.

A practical version of this may look like:

• A written policy that names what is delegated (billing, IT, HR, accounting, any contracted clinical work) and how each is overseen and audited.

• A clear line of final oversight authority that stays with the organization, not the subcontractor.

• Written disclosure to families when a third party is involved in their care, which may already live in your patient handbook or intake packet.

If you do not delegate any functions, that is a legitimate answer. Say so plainly rather than building out a policy for something you do not do.

Preparedness for interview questions

Leadership should be able to speak to the process with relative ease. Questions that may come up:

• What functions does the organization delegate or outsource, and who oversees each?

• How is that oversight documented, and how are subcontractors audited?

• How does the organization retain final oversight authority over delegated work?

• How are patients informed, in writing, when a third party is involved in their care?

The answers should match what is in the upload. If the upload describes a process that no one on the team can describe in their own words, that is where gaps may show.

For those who want more

A paid Substack tier is coming with sample documents, supporting templates, and additional resources. Partners ABA clients receive individualized pacing aligned with their team’s progress, review and feedback on each submission, and support in developing and adopting policies, standards, and practices within the scope of their service package.

What’s next

1.09 next. Same structure: the standard, what to upload, how it shows up in practice, what may come up in interviews.

If you know other ABA leaders who’d benefit from this series, invite them to subscribe.

As always, this is guidance based on experience, not an official ACQ communication. You’re responsible for your own interpretations and submissions. Verify everything against the current ACQ Standards and Guide.

Brandon Herscovitch, PhD, BCBA-D

partnersaba.substack.com | partnersaba.com

If you’re just joining us, the prior posts walk through folder setup, tracking, and Standards 1.01 through 1.06. Reference those if you need the groundwork. We’re moving to 1.07.

The standard

ACQ 1.07 (Written Agreements) reads: “The Organization shall maintain written agreements relating to ABA services and related functions, describing key terms such as the scope of the services to be provided with all patients or legal guardians, participating providers, vendors, and subcontractors.”

The guidance adds that organizations have written policies and procedures addressing how contracts are reviewed, approved, and updated as necessary to ensure the effective administration of contractual obligations, for example Business Associate Agreements (BAAs) with external vendors and subcontractors. Organizations also have a process to verify that all relevant signatures are collected when agreements need to be updated or renewed.

This standard establishes the policy and process by which your organization manages written agreements with the parties named: patients or legal guardians, participating providers, vendors, and subcontractors. A couple of related standards are worth keeping in mind. Standard 1.08 (Delegation of Duties) covers the oversight of delegated and subcontracted functions once an agreement is in place, while 1.07 covers the policy for managing the agreements themselves. Standard 4.02 (Privacy and Security) covers your privacy and security program, which Business Associate Agreements implement, while 1.07 covers the policy governing how those BAAs, and other agreements, are reviewed, approved, signed, and updated. One more note worth flagging: ACQ does not explicitly name payer or funder contracts as a required document in this standard or elsewhere. A case could be made for housing them under 1.02 (authorization), 1.03 (governance), Section 3 (financial operations), or here in 1.07. Handle that placement in whatever way fits how your organization is structured. An ACQ rep may advise your team on this.

What’s scored

The standard itself. A written policy and process for how contracts are reviewed, approved, signed, updated, and stored across the parties named in the standard: patients or legal guardians, participating providers, vendors, and subcontractors.

One item you can upload to your folder

1. Written Agreements Policy and Procedure. Your written policy or procedure governing how contracts and agreements are managed. The document should address how your organization handles agreements with each party named in the standard, patients or legal guardians, participating providers, vendors, and subcontractors, and the process by which agreements are managed: how contracts are reviewed, how they are approved, how they are updated as necessary, how required signatures are collected and verified when agreements are updated or renewed, and where executed agreements (including BAAs with external vendors and subcontractors) are stored. If this is not yet formalized, draft a simple policy covering these elements by the due date.

Keep all responses brief, concrete, and observable. Everything you submit should reflect what is currently in place and in use.

How it shows up in practice

A written agreements policy is not scored on whether the contracts are perfect. What evaluators may look for is whether there is a real, followed process for managing agreements, who reviews them, who approves them, how signatures get collected, and where the executed versions live, rather than only a generic policy written for the submission.

A practical version of this may look like:

• A single, known home for executed agreements, so anyone who needs a contract or a BAA can find the current signed version.

• A clear owner for reviewing and approving agreements, and a process for collecting signatures when something is updated or renewed.

• A policy that names each party type (families, providers, vendors, subcontractors) and identifies how those agreements are actually handled.

Preparedness for interview questions

Leadership should be able to speak to the process with relative ease. Questions that may come up:

• What types of written agreements does the organization hold, and with whom?

• Who reviews and approves agreements, and where are executed versions stored?

• How are signatures collected and verified when an agreement is updated or renewed?

• How does the organization handle Business Associate Agreements with vendors and subcontractors?

The answers should match what is in the uploads. If the upload describes a process that no one on the team can describe in their own words, that is where gaps may show.

For those who want more

A paid Substack tier is coming with sample documents, supporting templates, and additional resources. Partners ABA clients receive individualized pacing aligned with their team’s progress, review and feedback on each submission, and support in developing and adopting policies, standards, and practices within the scope of their service package.

What’s next

1.08 next. Same structure: the standard, what to upload, how it shows up in practice, what may come up in interviews.

If you know other ABA leaders who’d benefit from this series, invite them to subscribe.

As always, this is guidance based on experience, not an official ACQ communication. You’re responsible for your own interpretations and submissions. Verify everything against the current ACQ Standards and Guide.

Brandon Herscovitch, PhD, BCBA-D

partnersaba.substack.com | partnersaba.com

To clarify, this is your organization’s calendar. It tracks agency-level obligations, the things you do once for the whole practice, not anything tied to a single client. Individual clients have their own cadences (plan updates, outcome reviews, reauthorization dates), and those live on separate clinical and authorization calendars or tracking systems. More on that below.

This is a working tool, the same way the folder structure and the tracker are. Here is one simple way to set it up.

The build

Make a checklist where each row is one recurring obligation. Give it a few columns:

• What it is. The thing that recurs (annual policy review, license renewal, satisfaction survey).

• Cadence. How often it comes due (annually, every three years, quarterly).

• Trigger. What forces it off-cycle (a regulation changes, a new location opens, an incident occurs).

• Owner. Who is responsible?

• Last done / next due. So nothing quietly lapses.

Then mirror the time-based rows onto a shared calendar, in whatever system you already use. Google Calendar works well because you can set a recurring event for each cadence item and a reminder ahead of the due date, not on it. You can also share calendars and calendar events with the right people. The event-triggered rows do not sit on a date. They sit on the checklist, and you review the checklist on a set rhythm to confirm each one fired when its trigger came up.

The calendar catches the predictable. The checklist review catches the rest.

What actually recurs

The map below is the quick version of recurring obligations and roughly how often drawn from the current Standards and Guide that carry a cadence or a clear trigger. For a fuller picture, here’s an interactive version of this table where you can filter by cadence and tap any row to see its trigger and where it lives - on the calendar or on the checklist review. It also includes the Recommended Practices you may feel are worth adding while you’re building the calendar anyway. As always, verify each against the current Standards and Guide for your situation. This is meant to provide general guidance.

A note on the patient-level ones

A few items are per patient, not organization-wide, and they belong on your clinical and authorization calendars or systems rather than this one. Examples include updating each treatment plan at least every six months or sooner (6.06), reviewing clinical outcomes for each patient at least every six months (8.03), and tracking each patient’s reauthorization dates by payer. Keeping these on a separate client-level calendar stops the org calendar from turning into a caseload tracker.

The Recommended Practices, if you want to get ahead

These are not scored in this version of the Standards but are assessed to inform future ones. Several are cadence-based, so if you are building the calendar anyway, they are cheap to add:

• Financial audits at least annually (3.01).

• Privacy and security risk assessments at least annually, when an identified need arises, or in response to regulatory requirements (4.02).

• Health and safety risk assessments at least annually (4.03).

• Crisis Management Manual reviewed and updated at least annually (4.04).

• Compliance and ethics program reporting to leadership periodically, for example quarterly or semi-annually (4.01).

• Annual performance reviews and an annual employee satisfaction check (2.01).

• Notifying patients of their rights and responsibilities at least annually (7.01).

• Training staff on the grievance process at least annually, and analyzing grievance data at least annually or sooner in accordance with applicable regulations (9.02).

• Strategic planning at least annually (1.03).

Worth doing for internal alignment and to get ahead of where the standards may go, but not required for this submission.

How it shows up in practice

The point of the calendar is not the calendar. It is that when an evaluator asks how often you review policies, or when you last ran a satisfaction survey, or how you track license renewals, you can answer from something real rather than reconstruct it on the spot. A live calendar and a reviewed checklist are the evidence that these things happen on a rhythm, not just before a submission.

Pick the simplest version that actually works for your size, and put one recurring reminder on it today.

For those who want more

A paid Substack tier is coming with sample documents, supporting templates, and additional resources. Partners ABA clients receive individualized pacing aligned with their team’s progress, review and feedback on each submission, and support in developing and adopting policies, standards, and practices within the scope of their service package.

As always, this is guidance based on experience, not an official ACQ communication. You’re responsible for your own interpretations and submissions. Verify everything against the current ACQ Standards and Guide.

Brandon Herscovitch, PhD, BCBA-D

partnersaba.substack.com | partnersaba.com

If you’re just joining us, the prior posts walk through folder setup, tracking, and Standards 1.01 through 1.05. Reference those if you need the groundwork. We’re moving to 1.06.

The standard

ACQ 1.06 (Organizational Capacity) reads: “The Organization shall define capacity expectations and have a process for evaluating whether these expectations are being met for each location and type of ABA service.”

The guidance adds that organizations define capacity expectations using variables relevant to each position. For example, setting capacity expectations for an FTE Behavior Analyst based on an expected range of direct therapy hours overseen, an FTE Intake Coordinator based on the enrollment of a specific number of patients, or an FTE Scheduler based on a specific number of provider calendars being managed. Organizations admit patients only when they have the capacity to provide medically necessary services unless compelled by applicable regulations. And they openly communicate with current patients when changes in organizational capacity limit access to medically necessary services, and offer referrals if appropriate alternatives are available.

This standard establishes how your organization defines and evaluates capacity. It is distinct from a few related standards. Standard 6.01 (Access to Care) covers patient access, waitlists, and timely communication about service availability; 1.06 defines the capacity expectations that determine whether access is possible. The two are tightly connected: 1.06 sets the targets, and 6.01 manages the patient-facing experience when capacity affects access. Standard 6.03 (Caseload Management) covers per-patient caseload sizing and dosage decisions made by the Behavior Analyst for individual cases, while 1.06 covers org-wide capacity expectations per role and location; the word “caseload” is easy to confuse across the two, but they are not the same. And hiring and staffing decisions tied to capacity needs flow through the HR program in Standard 2.01 (Human Resource Management); 1.06 defines the capacity targets HR is staffing against.

What’s scored

The standard itself. Defined capacity expectations for each location and type of ABA service, and a process for evaluating whether those expectations are being met.

Three items you can upload to your folder

1. Capacity Expectations Policy. Your written policy or document defining capacity expectations across roles, locations, and ABA service types. The document should address capacity expectations for relevant roles using role-relevant variables. Examples: a Behavior Analyst, by the expected range of direct therapy hours overseen per FTE and expected caseload and service hour count; a Behavior Technician, by expected weekly billable hours per FTE; an Intake Coordinator, by expected patient enrollments per period; a Scheduler, by expected provider calendars managed per FTE; and a Clinical Leader, by caseload limits that allow baseline supervisory and oversight responsibilities to be carried out. Segment capacity expectations by location and by service type where applicable (for example, in-home versus clinic, comprehensive versus focused ABA). If this is not yet formalized, draft a simple document covering these elements by the due date.

2. Capacity Evaluation Process. A written description or document outlining your process for evaluating whether capacity expectations are being met. The process should account for the dynamic variables that affect capacity: staff onboarding and offboarding timelines and ramp-up, client onboarding and offboarding (intake throughput and discharges), staff competency level relative to client needs (a Clinical Leader determination), scheduling availability and provider calendar load, and hiring activity tied to projected capacity gaps. Describe the cadence of evaluation (for example, a monthly leadership review or a quarterly capacity check), who participates, and how findings drive decisions about admissions, hiring, and case assignment.

3. Admission and Referral Practice. Two to three bullets covering how admission decisions are tied to current capacity (admitting only when capacity exists to deliver medically necessary services), how current patients are notified when changes in capacity limit access to medically necessary services, and how referrals are offered when appropriate alternatives are available. If practice is currently informal, describe what happens now and identify one way to make it more consistent.

Keep all responses brief, concrete, and observable. Everything you submit should reflect what is currently in place and in use.

How it shows up in practice

Capacity is not a number you set once. What evaluators may look for is whether you have real expectations per role and location, whether you actually check them on a cadence, and whether those checks change what you do: who you admit, when you hire, how you assign cases.

A practical version of this may look like:

• Capacity expectations defined per role and segmented by location and service type, matching how the work is actually staffed.

• A review that happens on a set cadence, with named participants, rather than a calculation pulled together for the submission.

• Admission and referral decisions that visibly track current capacity, including a recent example where capacity shaped a yes, a no, or a referral.

Preparedness for interview questions

Leadership should be able to speak to capacity with relative ease. Questions that may come up:

• How does the organization define capacity expectations, and how do they differ by role, location, and service type?

• How often is capacity reviewed, who participates, and how are decisions made when capacity is constrained?

• How are admission decisions tied to current capacity?

• Can you walk through the most recent example of a capacity-driven admission decision or referral?

The answers should match what is in the uploads. If the uploads describe a process that no one on the team can describe in their own words, that is where gaps may show.

For those who want more

A paid Substack tier is coming with sample documents, supporting templates, and additional resources. Partners ABA clients receive individualized pacing aligned with their team’s progress, review and feedback on each submission, and support in developing and adopting policies, standards, and practices within the scope of their service package.

What’s next

1.07 next. Same structure: the standard, what to upload, how it shows up in practice, what may come up in interviews.

If you know other ABA leaders who’d benefit from this series, invite them to subscribe.

As always, this is guidance based on experience, not an official ACQ communication. You’re responsible for your own interpretations and submissions. Verify everything against the current ACQ Standards and Guide.

Brandon Herscovitch, PhD, BCBA-D

partnersaba.substack.com | partnersaba.com

If you’re just joining us, the prior posts walk through folder setup, tracking, and Standards 1.01 through 1.04. Reference those if you need the groundwork. We’re moving to 1.05.

If your state or a payer is moving toward requiring accreditation, this is one of the standards that rewards starting early. Policies and procedures are not something you assemble the week before a submission, so the sooner the review cadence is real, the easier everything downstream gets.

The standard

ACQ 1.05 (Policies and Procedures) reads: “The Organization shall document, review, and update its written policies and procedures at least annually, in response to regulatory requirements, or when a need arises.”

The guidance adds that organizations review their written policy and procedure manuals on a regular basis, and that they have a process for updating their policies and procedures in response to changes in regulatory requirements or when notified that current policies and procedures do not meet current regulatory requirements. For example, a policy team, including leadership from impacted departments, reviews, updates, and trains on new policies and procedures before a new federal or state law that could impact services goes into effect. Organizations also have a process for updating policies and procedures when an identified need arises, such as a department being realigned, a new service line being added, an audit revealing an issue, or a complaint or grievance identifying a problem.

This standard establishes how your organization documents, reviews, and updates its policies and procedures. A couple of related standards are worth keeping in mind. Staff training on policies and procedures is addressed in Standard 2.03; 1.05 covers the policy lifecycle of document, review, and update, while 2.03 covers how staff are trained on those policies. And updates triggered by complaints or grievances connect to Standard 9.02; 1.05 covers the process for updating a policy when an identified need arises, while 9.02 covers the complaint and grievance process that may surface that need.

What’s scored

The standard itself. A documented process to document, review, and update written policies and procedures at least annually, in response to regulatory requirements, or when a need arises.

There are also Recommended Practices associated with 1.05: storing policies in a centralized electronic location, standardizing policies across locations, and using a standard format with disclaimer statements and version control to track updates. Recommended Practices are not scored in this version of the Standards but are assessed to inform future ones. Worth doing for internal alignment and to get ahead of where the standards may go, but not required for this submission.

Two items you can upload to your folder

1. Policy on Policies. Your meta-policy, or policy-on-policies, defining how the organization creates, reviews, updates, and maintains its written policies and procedures. The document should address how policies and procedures are created and approved, how they are reviewed at least annually, how they are updated in response to regulatory changes or when they no longer meet regulatory requirements, how they are updated when an identified need arises (for example, a department realignment, a new service line, an audit finding, or a complaint or grievance), and who is responsible for policy review, approval, and dissemination. If this is not yet formalized, draft a simple policy covering these elements by the due date. Reference your existing Policy and Procedure manual(s) as the underlying artifact this process governs, and link them in the tracking sheet if applicable.

2. Review and Update Process. Two to three bullets covering your regular review cadence (for example, an annual review or a quarterly leadership check-in), what triggers an update outside the regular cycle (a regulatory change, an identified need, an audit finding, a grievance), and one example of a policy that was updated and why. If review is currently informal, describe current practice and identify one way to make it more consistent.

Keep all responses brief, concrete, and observable. Everything you submit should reflect what is currently in place and in use.

How it shows up in practice

Policies and procedures are not scored on whether they are perfect. What evaluators may look for is whether there is a real process for keeping them current, and whether that process is something the organization actually uses rather than a document assembled for the submission.

A practical version of this may look like:

• A policy-on-policies that names who reviews, who approves, and on what cadence, matching how reviews actually happen.

• A review that lands on a schedule, with a clear trigger for off-cycle updates when a regulation changes or a need surfaces.

• At least one concrete example of a policy that was updated, and the reason it changed.

Tracking that cadence does not need to be elaborate. A simple calendar or checklist, with a review cadence and an update trigger noted for each item, could be enough to keep this current. We walk through one approach to that in a separate post.

Preparedness for interview questions

Leadership should be able to speak to the process with relative ease. Questions that may come up:

• How does the organization document, review, and update its policies and procedures?

• How often are policies reviewed, and what triggers an update outside that cycle?

• Who is responsible for reviewing, approving, and disseminating policies?

• Can you walk through a recent example of a policy that was updated, and why?

The answers should match what is in the uploads. If the uploads describe a process that no one on the team can describe in their own words, that is where gaps may show.

For those who want more

A paid Substack tier is coming with sample documents, supporting templates, and additional resources. Partners ABA clients receive individualized pacing aligned with their team’s progress, review and feedback on each submission, and support in developing and adopting policies, standards, and practices within the scope of their service package.

What’s next

1.06 next. Same structure: the standard, what to upload, how it shows up in practice, what may come up in interviews.

If you know other ABA leaders who’d benefit from this series, invite them to subscribe.

As always, this is guidance based on experience, not an official ACQ communication. You’re responsible for your own interpretations and submissions. Verify everything against the current ACQ Standards and Guide.

Brandon Herscovitch, PhD, BCBA-D

partnersaba.substack.com | partnersaba.com

The standard

ACQ 1.04 (Scope of Services) reads: “The Organization shall clearly and accurately define and differentiate the scope of its ABA services.”

The guidance adds that organizations publicly identify the full scope of their ABA services for patients with ASD on their website and when advertising services where appropriate. This includes the types of ABA services offered (such as comprehensive ABA, focused ABA, academic services, adult services, pediatric feeding services), co-morbid conditions treated alongside ASD (such as anxiety, attention deficit hyperactivity disorder, depression, epilepsy, genetic disorders, sleep disorders), age groups served (such as early childhood, adolescence, mature adulthood), service settings (such as clinic/outpatient, home, community, residential, school, telehealth, vocational), and modalities (such as face-to-face direct services, in-person direct services with telehealth clinical direction, telehealth direct services, caregiver-mediated telehealth services). Organizations differentiate their ABA services from non-ABA services they may offer.

This standard establishes what services your organization offers and how they are described publicly. A few related standards are worth keeping in mind. Whatever you describe here should be consistent with how services are represented in marketing and advertising, which is addressed in Standard 1.10 (Marketing Practices). Any service setting you list should match the settings where services are actually delivered and supervised, addressed in Standard 6.07 (Service Settings); listing a setting in your scope creates an expectation that oversight structures are in place for it. And if you list telehealth as a modality here, Standard 6.11 (Telehealth) addresses the telehealth protocol, informed consent process, and contingency plan that supports it; listing it in your scope creates an obligation to demonstrate it is properly supported.

What’s scored

The standard itself. A clear and accurate definition of the scope of your ABA services, publicly identified, with ABA services differentiated from any non-ABA services you offer.

Three items you can upload to your folder

1. Scope of Services - Public Description. Your current public-facing description of ABA services as it appears to prospective patients, families, and referral sources. Examples include your website service page, marketing or outreach materials, and intake or onboarding materials. If ABA services are not yet clearly described publicly, draft a description and make it available by the due date. If non-ABA services are also offered, make sure ABA services are clearly differentiated from them in this description.

2. Service Scope Breakdown. A structured breakdown of your services by location. Format as a table if not already tracked. For each service location, include the ABA service types available (such as comprehensive ABA, focused ABA, adult services, pediatric feeding), any non-ABA services offered, co-morbid conditions addressed alongside ASD (such as anxiety, ADHD, epilepsy, sleep disorders), age groups served (such as early childhood, adolescence, adulthood), service settings (such as clinic, home, school, community, residential, telehealth, vocational), and treatment modalities (such as face-to-face direct, in-person with telehealth clinical direction, telehealth direct, caregiver-mediated). If services vary by location, complete a separate column or section for each. Any service setting or modality listed here will need to be supported by appropriate oversight structures and protocols in the relevant clinical standards.

3. Differentiation of Services. Two to three bullets covering how ABA services are distinguished from any non-ABA services offered and how that is communicated to patients and referral sources, how different ABA service types are defined or differentiated within your organization (such as comprehensive versus focused ABA), and one example of how this scope is communicated to patients or stakeholders in practice. If not clearly defined, provide a simple differentiation framework before the due date.

Keep all responses brief, concrete, and observable. Everything you submit should reflect what is currently in place and in use.

How it shows up in practice

Scope of services is not just a website page. What evaluators may look for is whether the scope described publicly matches what the organization actually delivers and supervises, and whether the description is consistent across the places it appears.

A practical version of this may look like:

• A public description and an internal breakdown that agree with each other, and with what the organization actually offers today.

• Settings and modalities listed only where there are real oversight structures behind them. If telehealth is in the scope, the telehealth protocol, consent process, and contingency plan exist.

• A clear line between ABA and any non-ABA services, communicated the same way to patients, families, and referral sources.

Preparedness for interview questions

Leadership should be able to speak to the scope with relative ease. Questions that may come up:

• What is the full scope of ABA services the organization offers, and where is it described publicly?

• How are ABA services differentiated from any non-ABA services you offer?

• How does the organization decide which service type is appropriate for a given patient, and how is that communicated?

• For a setting or modality you list, telehealth for example, what oversight and protocols support it?

The answers should match what is in the uploads. If the uploads describe a scope that no one on the team can describe in their own words, that is where gaps may show.

For those who want more

A paid Substack tier is coming with sample documents, supporting templates, and additional resources. Partners ABA clients receive individualized pacing aligned with their team’s progress, review and feedback on each submission, and support in developing and adopting policies, standards, and practices within the scope of their service package.

What’s next

1.05 next. Same structure: the standard, what to upload, how it shows up in practice, what may come up in interviews.

If you know other ABA leaders who’d benefit from this series, invite them to subscribe.

As always, this is guidance based on experience, not an official ACQ communication. You’re responsible for your own interpretations and submissions. Verify everything against the current ACQ Standards and Guide.

Brandon Herscovitch, PhD, BCBA-D

partnersaba.substack.com | partnersaba.com

• Smaller offices

• Less admin support

• Pressure for more billable time

• Pressure to be more efficient with the time available

• Organizations leaving certain funders

• More documentation

• More compliance requirements

• More operational pressure overall

Staff experience these decisions directly, and understandably, may feel pressure and frustration. Sometimes leadership decisions are viewed as selfish, greedy, disconnected, or uncaring.

To be fair, some organizations do make poor decisions. But, sometimes the line between selfish and smart isn’t so clear. To fairly assess, it’s important to have honest and productive communication.

A basis for productive conversation is understanding the basic economics behind it all. Many clinicians are never shown the financial pressures that led to those decisions in the first place.

This post is not about telling clinicians they’re wrong for feeling frustrated. It’s about creating a simpler framework that practice leaders, BCBAs, and teams can use to discuss the operational pressures shaping decisions across the field.

Ideally, this is the type of conversation that happens openly within organizations. And if it’s not happening, hopefully this gives staff a clearer framework to ask questions and better understand the tradeoffs leadership teams may be trying to navigate.

The reality is simple. When reimbursement decreases or operational costs increase, organizations generally only have a few options:

1. Increase efficiency (e.g. billable / [billable + non-billable time])

2. Increase overall billable utilization

3. Reduce expenses

4. Stop taking lower-paying contracts

5. Increase reimbursement rates when possible

In reality, most organizations attempt some combination of all five.

If reimbursement drops while organizations simultaneously maintain the exact same staffing structures, support systems, flexibility, infrastructure, non-billable support time, and lower productivity expectations, the organization becomes financially unstable and something eventually has to change.

That is not unique to ABA. That is basic economics.

There’s another uncomfortable reality when discussing payer mix.

Some funders reimburse substantially less than others. When organizations accept significantly lower-paying contracts while attempting to maintain identical operational structures and support systems across all payers, including those who pay more competitively, the difference has to come from somewhere.

At the same time, higher-paying payers and members may reasonably expect, want, or direct additional opportunities toward organizations providing service levels and infrastructure they feel align with more competitive reimbursement rates.

That creates another pressure on organizations. If reimbursement compression becomes too severe, organizations may struggle to maintain staffing levels, responsiveness, support systems, infrastructure, and operational flexibility at levels competitive with other providers in the market. When that happens, higher-paying opportunities may gradually move elsewhere.

This is why many operational decisions that appear selfish in isolation may actually be attempts to avoid worse long-term outcomes.

Examples might include:

• reducing unnecessary office space instead of layoffs,

• improving scheduling efficiency instead of reducing compensation,

• limiting unsustainable contracts instead of risking organizational collapse,

• or restructuring support systems to preserve long-term stability.

Again, this does not mean every organizational decision is justified. It also does not mean clinicians should blindly agree with leadership. But it does mean the underlying pressures are often more complicated than: “leadership just doesn’t care.”

Another important nuance is that not all organizations operate under identical financial models.

Many organizations operate under more traditional sustainability expectations involving healthy cash flow, operational margins, and long-term financial stability.

Other organizations, including some private equity-backed groups, may sometimes tolerate lower short-term profitability (and even losses) because their long-term strategy may rely more heavily on growth, scale, acquisition value, or future resale potential.

Not all PE-backed organizations operate the same way. Some appear to invest heavily in infrastructure, support systems, advocacy efforts, technology, training, and operational systems that may benefit staff, clients, and sometimes even the broader field.

Some smaller independent providers are also doing incredible work and making major investments in quality and sustainability.

Different financial structures create different operational pressures and competitive realities. Organizations able to tolerate weaker short-term margins or lower near-term cash flow pressure may sometimes be able to offer:

• higher compensation,

• lower productivity expectations,

• stronger support systems,

• or broader acceptance of lower-paying contracts

in ways that may be more difficult for sustainability-focused organizations operating under more traditional financial constraints.

In other words, the same reason one may be inclined to label a company as “good” (higher pay, lower billable requirements) could be the very reason they’d label them as “bad” (creating a more challenging and less sustainable market for smaller, clinicians owned practices).

Of course, not every company is the same, and there’s lots of moving parts. That’s why healthy and respectful discussion around this very topic may be of value.

This comes down to market dynamics, not value judgment.

ABA organizations are constantly balancing:

• staff support,

• client outcomes and quality of care,

• access,

• operational stability,

• and the economics of it all, including long-term sustainability

This is the reality within which we’re operating.

Ultimately, many ABA organizations are not choosing between: “good” and “bad.” They’re choosing between competing tradeoffs under real financial, staffing, operational, and regulatory pressures.

People may more directly experience the specific tradeoff affecting them personally. You don’t have to agree with every organizational decision to better understand the pressures influencing it. But understanding those pressures usually leads to more productive conversations.

The standard

ACQ 1.03 (Governance and Management) reads: “The organization shall be governed by a leadership structure appropriate to its scale with oversight of its operations.”

The guidance adds that organizations have leadership structures responsible for overseeing all their administrative and clinical operations, and that leadership may be assigned responsibilities such as strategic and business planning, outcome achievement, financial solvency oversight, performance evaluation, policy review, ethics and compliance, cultural humility and awareness, health and safety, risk management, succession planning, and leadership development.

This standard establishes who governs the organization and how oversight is structured. A few related standards are worth keeping in mind. Governing documents like Articles of Incorporation and bylaws may also be required under Standard 1.02. Whichever folder you complete first holds the original, and you mirror the file to the other. Organizational capacity and staffing levels are addressed in Standard 1.06, not here. Who is responsible for compliance is defined here, but how the compliance program operates is addressed in Standard 4.01. The Clinical Leader role is identified here in the roster and oversight structure, while clinical credentialing and qualifications are addressed in Standards 5.01 and 5.02. And the oversight cadence you describe should be consistent with the quality assurance program structure addressed in Standard 8.02.

What’s scored

The standard itself. A leadership structure appropriate to the organization’s scale, with oversight of its operations, supported by identifiable leaders and formal governing documents.

Five items you can upload to your folder

1. Organizational Chart. A current chart clearly showing governance roles (for example, owner, board, executive oversight), management roles (for example, clinical director, operations), and reporting relationships. If governance and management are held by the same individual or individuals, reflect that clearly in the chart. If not already compiled, create a current chart before the due date.

2. Leadership and Governance Roster. A list of individuals responsible for governance and leadership. For each individual, include name, title, academic and professional credentials, role in the organization, and email address. Format as a table if not already compiled. Credentials listed here will also be verified under Standard 5.01 (Provider Credentialing), so you do not need to duplicate that documentation here.

3. Leadership Responsibilities and Oversight Structure. A brief document defining the responsibilities assigned to key leadership roles. At minimum, address who is responsible for strategic and business planning, outcome achievement, financial solvency oversight, performance evaluation, policy review, ethics and compliance, cultural humility and awareness, health and safety, risk management, succession planning, and leadership development. Keep this focused on who is responsible and who oversees each area, not the detailed procedures for how each function is carried out. Procedures are addressed in their respective standards.

4. Oversight and Accountability. Two to three bullets covering how governance or leadership reviews organizational performance or operations, how accountability is maintained (for example, reporting structure, regular review points), and one example of how a decision or issue was escalated or overseen. If this is currently informal, describe current practice and identify one way to make it more consistent. Reference supporting source documents (org chart, role descriptions, meeting notes). The oversight cadence you describe here should be consistent with the QA program structure addressed in Standard 8.02.

5. Governing Documents. Copies of your governing documents. Examples include Articles of Incorporation or Organization, and bylaws or equivalent governing structure documents. If these were already submitted under Standard 1.02, decide which folder is the primary home for the original and mirror the file here so the same file appears in both locations, and any future updates to the original are reflected wherever it has been mirrored.

Keep all responses brief, concrete, and observable. Everything you submit should reflect what is currently in place and in use.

How it shows up in practice

Governance is not just a chart on file. What evaluators may look for is whether the structure on paper matches how the organization actually runs, and whether oversight happens on a cadence rather than being assembled for the submission.

A practical version of this may look like:

• A chart and roster that reflect who is actually making decisions today, including where one person holds multiple roles.

• A clear answer, for each major area, to who is responsible and who oversees it.

• A regular review point where leadership looks at performance or operations, with a way to escalate issues when they come up.

If governance and management sit with the same one or two people, that is fine. Reflect it honestly rather than building out roles that do not exist.

Preparedness for interview questions

Leadership should be able to speak to the structure with relative ease. Questions that may come up:

• Who governs the organization, and who manages day-to-day operations?

• For a given area - for example, ethics and compliance, or health and safety - who is responsible, and who oversees it?

• How does leadership review performance or operations, and how often?

• Can you walk through a recent example of a decision or issue being escalated or overseen?

The answers should match the chart, the roster, and the oversight document. If the uploads describe a structure that no one on the team can describe in their own words, that is where gaps may show.

For those who want more

A paid Substack tier is coming with sample documents, supporting templates, and additional resources. Partners ABA clients receive individualized pacing aligned with their team’s progress, review and feedback on each submission, and support in developing and adopting policies, standards, and practices within the scope of their service package.

What’s next

1.04 next. Same structure: the standard, what to upload, how each upload shows up in practice, and what may come up in interviews.

If you know other ABA leaders who’d benefit from this series, invite them to subscribe.

As always, this is guidance based on experience, not an official ACQ communication. You’re responsible for your own interpretations and submissions. Verify everything against the current ACQ Standards and Guide.

Brandon Herscovitch, PhD, BCBA-D

partnersaba.substack.com | partnersaba.com

The standard

ACQ 1.02 (Business Authorization and Jurisdictions) reads: "The Organization shall be licensed and authorized to deliver ABA services by the appropriate regulatory agencies in the location(s) where it operates, if applicable."

The guidance adds that organizations are legally authorized to provide services delivered inside or outside the physical locations they own, lease, or rent, and that authorization is maintained as regulations are updated, telehealth services are offered across jurisdictions, new service lines are introduced, or new locations are added.

This standard covers business and payer authorization to operate. Governing documents like Articles of Incorporation and bylaws may also be required under Standard 1.03 (Upload 5). Whichever standard folder you complete first holds the original. Mirror the file to the other so the same document appears in both locations. Individual provider credentials (BCBA licensure, RBT certification) are not part of this standard. Those live in Standard 5.01.

What's scored

The standard itself. Authorization to deliver ABA services in each location where you operate, maintained as conditions change.

There is also a Recommended Practice associated with 1.02: publishing the geographical areas served on the organization's website. Recommended Practices are not scored in this version of the Standards but are assessed to inform future ones. Worth doing for internal alignment and to get ahead of where the standards may go, but not required for this submission.

Three items you can upload to your folder

1. Business Authorization by Location.

Documentation confirming the organization is authorized to operate, with the state and county (or county equivalent) where services are delivered. May include Articles of Incorporation or Organization, business registration, and state business license. If operating in multiple states or regions, include documentation for each. If anything is missing or outdated, identify the gap and initiate the update.

2. Licensure and Regulatory Requirements.

A list of all applicable licenses, certifications, or regulatory approvals required for the organization to operate. Include type of license or approval, governing body (state, payer, or regulatory agency), and current status (active, pending, expired). Format as a table if not already tracked. Requirements vary by state and payer. Verify current requirements in each jurisdiction.

3. Ongoing Compliance System.

Two to three bullets covering how the organization tracks and ensures it remains licensed and authorized in all service locations, who is responsible for maintaining compliance, and one example of how a renewal or compliance requirement was managed. If no formal system exists, define a simple one. Calendar tracking, assigned owner, checklist. Reference supporting source documents (license copies, renewal logs, compliance trackers).

Keep all responses brief, concrete, and observable. Everything you submit should reflect what is currently in place and in use.

How it shows up in practice

Authorization is not a one-time filing. The guidance language is clear that it has to be maintained as regulations update, as telehealth crosses jurisdictions, as new service lines are introduced, and as new locations are added. What evaluators may look for is whether documentation reflects something the organization actively maintains, not a snapshot pulled together for the submission.

A practical version of this may look like:

- A current list of all jurisdictions, licenses, and approvals, with status and expiration dates visible to whoever owns compliance.

- A defined owner. One person who maintains the list and is accountable for renewals.

- A cadence. Renewals tracked ahead of expiration, not at expiration.

Pick the simplest version that actually works for your size.

Preparedness for interview questions

Leadership should be able to speak to the system with relative ease. Questions that may come up:

- Where does the organization operate, and what authorizations are required in each location?

- Who maintains the list, and how are renewals tracked?

- Can you walk through a recent example of a renewal or compliance requirement being managed?

- How does the organization handle authorization when something changes - a new service line, a telehealth jurisdiction, a new location?

The answers should match what is in the uploads. If the uploads describe a system that no one on the team can describe in their own words, that is where gaps may show.

For those who want more

A paid Substack tier is coming with sample documents, supporting templates, and additional resources. Partners ABA clients receive individualized pacing aligned with their team's progress, review and feedback on each submission, and support in developing and adopting policies, standards, and practices within the scope of their service package.

What's next

1.03 next. Same structure: the standard, what to upload, how it shows up in practice, what may come up in interviews.

If you know other ABA leaders who'd benefit from this series, invite them to subscribe.

As always, this is guidance based on experience, not an official ACQ communication. You're responsible for your own interpretations and submissions. Verify everything against the current ACQ Standards and Guide.

Brandon Herscovitch, PhD, BCBA-D

partnersaba.substack.com | partnersaba.com

I’ve been hearing application volume is up across states, and with the increased demand, timelines are stretching. It’s reasonable to plan that applications submitted now can spill into 2027 before the process is complete.

If you’re impacted by a payer-imposed deadline, a few near term suggested actions are to:

1. Submit applications to ACQ as soon as possible

2. Track your work. I’ve discussed our tracker in the prior article, and some payers may have a tracker of their own that applies

3. Communicate preemptively with your provider rep at applicable funder(s)

4. Communicate with ACQ as to whether they might be able to provide a letter, if needed, indicating you’re actively participating in good faith.

5. Understand advocacy efforts related to your funders and regions. It’s possible there are efforts regarding grace periods, and if so, it might be in your interest to know of and possibly support those efforts.

The practical implication: don’t wait. The items below will help you be ready regardless of how those broader conversations land.

Partners Tracker

Partners’ trackers have gone out to everyone who commented “tracker” on the last post. If you missed it, comment “tracker” and I’ll send it.

A few things worth saying about it.

Why it matters: Standards have multiple required uploads. Many uploads cross-reference other standards. Some documents live in one place and get mirrored to others. Additionally, different standards could be managed by different team members, and at different stages in the process. A tracker can help keep things organized.

Funder-specific trackers, where applicable, may have different functions or capture different elements. Minimally, expect your state or payer to want confirmation of where you are in the process. Practically, you’ll want something more detailed than that to actually get there.

What Partners’ captures: Each row is one upload tied to one standard. It tracks who owns it, where the file lives, internal review status, finalization status, and cross-references to related standards. The version I’m sharing is illustrative, in that it’s representative of some standards across a few sections, not the full set. The full buildout and the auto-calc summary layer are what we develop with clients directly. The structure is yours to use and adapt. Use at your own discretion. It is not a substitute for the current ACQ Standards and Guide.

Folder Structure

Quick reminder from the last post. Create a main ACQ folder in whatever system you use (Google Drive, SharePoint, Dropbox). Inside it, create subfolders by standard, optionally grouped by section. This is your working system, not just a submission folder. The tracker links to the files in that folder structure. The two work together.

If you haven’t set this up yet, do it before you start working through 1.01.

Starting With 1.01

We’re starting at 1.01 for two reasons. First, because it’s first. Second, because it’s one of the more approachable standards, so it’s a good foundation before the heavier ones. It also turns out to be more load-bearing than it looks, which I’ll get to.

The standard

ACQ 1.01 (Guiding Principles) reads: “The organization shall have a set of guiding principles that prioritizes patient care and the ethical provision of services. Organizations adopt guiding principles that serve as the foundation upon which goals and strategies are developed. Guiding principles include a mission statement at minimum and are infused in the organization’s interactions with stakeholders. Organizations make their guiding principles available to staff, leadership, and the public.”

What’s scored

The mission statement. That’s it. Vision and Values are Recommended Practices, not scored in the current Standards, but assessed to inform future ones. Worth doing for internal alignment and to get ahead of where the standards are going, but not required for submission.

Three things evaluators may be inclined to look for in practice:

1. A mission statement exists and is documented.

2. It is accessible to staff, leadership, and the public, meaning it shows up in at least two locations (website, handbook, onboarding materials, intake packet).

3. It is infused in how the organization actually operates, not just posted on a wall, but reflected in a process, system, or interaction you can describe.

That third one is where interviews may tend to go. Evaluators might ask how the mission shows up day to day. Leadership should be able to give a concrete example.

Three items you can upload to your folder

1. Mission Evidence: A screenshot or document showing your mission statement as it currently appears - website, handbook, wherever it lives publicly.

2. Mission Accessibility: A list of every location where the mission is currently available. If it’s only in one place, add at least one more before submitting.

3. Mission in Practice: Two to three bullets identifying one system, process, template, or activity where the mission is actively embedded, and one example of how it influences staff or stakeholder interactions.

Keep responses brief, concrete, and observable. Everything you submit should reflect what is currently in place and in use.

Why 1.01 is more load-bearing than it looks

A mission isn’t just a Standard 1.01 artifact. It can anchor strategic planning (1.03), shape how scope of services is described (1.04), inform marketing claims (1.10), guide hiring and cultural fit (2.01), and show up in patient and family communications throughout. If the mission is vague or boilerplate, those connections get weaker. If it’s specific and lived, they reinforce each other. Worth getting this one right.

If you need to write or refine your mission statement

If you already have a mission statement you’re happy with and it’s accessible and in use, you’re in good shape. Move to the uploads above and you’re done with 1.01.

If you’re writing one from scratch or refining what you have, a strong mission addresses four elements:

• Value: What your organization offers and who it serves.

• Inspiration: It motivates and engages staff, not just describes a service.

• Plausibility: It sounds reasonable and achievable for an organization at your scale.

• Specificity: It reflects your organization, and is not overly generic.

Two to three concise sentences. Cover the what, the how, and the why.

Example: “To provide meaningful support to autistic and neurodivergent individuals and their families by delivering the highest quality, patient-centered ABA therapy, supporting an independent, meaningful, fulfilling, and pleasurable life.”

If you want the full supporting document, which includes the framework in more detail, an extended sample, plus the Vision and Core Values frameworks for the Recommended Practices side of 1.01, comment “Mission” and I’ll send it.

For those who want more

A paid Substack tier is coming, which will include sample documents, supporting templates, and additional resources like this one. Partners ABA clients receive individualized pacing aligned with their team’s progress, review and feedback on each submission, and support in developing and adopting policies, standards, and practices within the scope of their service package.

What’s next

1.02 next. Same structure: the standard, what evaluators look for, what to upload, where it connects to other standards.

If you know other ABA leaders who’d benefit from this series, invite them to subscribe.

As always, this is guidance based on experience, not an official ACQ communication. You’re responsible for your own interpretations and submissions. Verify everything against the current ACQ Standards and Guide.

Brandon Herscovitch, PhD, BCBA-D

partnersaba.substack.com | partnersaba.com

I’ll be at MassABA this Friday (come say hi if you’re there). I’ll plan to start digging into individual standards within a couple of weeks thereafter, and will offer some preparation advice before then, starting with this article.

STANDARD-SPECIFIC POSTS

For standard-specific posts, you’ll receive clear and practical guidance on:

A. The language ACQ uses, what it means in practice, and in relation to other standards

For example, 1.06 (Organizational Capacity) defines how the organization sets and evaluates capacity expectations across roles, locations, and services. It differs from 6.01 (Access to Care), which focuses on the patient-facing side, like waitlists, communication, and access, while 1.06 defines whether access is even possible. It also differs from 6.03 (Caseload Management), which addresses patient-level caseload and dosage decisions by the Behavior Analyst, whereas 1.06 operates at the organization-wide level. Similarly, 6.10 (Treatment Utilization) focuses on whether authorized or recommended hours are actually delivered, while 1.06 defines whether the organization has the capacity structure to support that delivery. Finally, 2.01 (Human Resource Management) governs hiring, staffing, and employee management systems, while 1.06 sets the capacity targets those systems are designed to meet.

B. Documents and evidence to support the standard

For example, to meet 1.06, organizations should be prepared to demonstrate concrete documentation demonstrating how capacity is defined and evaluated in practice. This includes a Capacity Expectations Policy that specifies role-based expectations (e.g., BCBA caseload and oversight hours, BT billable hours, intake and scheduling benchmarks, Clinical Leader limits), segmented by location and service type where relevant, and a Capacity Evaluation Process that outlines how performance against those expectations is reviewed over time. Supporting evidence should reflect real operational variables such as staffing changes, onboarding/offboarding timelines, scheduling load, and hiring relative to projected gaps, along with a defined review cadence, responsible parties, and how findings inform decisions. Additionally, organizations should show how capacity connects to admission and referral practices, including admitting only when sufficient capacity exists, communicating limitations to current patients, and offering referrals when appropriate. Artifacts should reflect how the organization actually operates and be usable in practice.

C. Ensuring the elements represent your actual practice, and where needed, adopt revised practices that align

Continuing our example standard, beyond documentation, 1.06 is about alignment between stated capacity expectations and real-world operations. Organizations should ensure that defined capacity targets are actively used to guide decisions around admissions, staffing, scheduling, and case assignment. Where gaps exist, current practices should be described transparently, and incremental adjustments should be made to improve consistency and alignment over time (e.g., formalizing informal processes, adding review cadence, clarifying role expectations). The focus is not perfection, but demonstrating that capacity is actively managed, regularly evaluated, and meaningfully tied to operational decisions. For interview readiness, leadership should be able to describe recent examples of capacity-based decisions, how often capacity is reviewed, who is involved, and how constraints are handled in practice.

The above examples focus on one standard. There are 50. Laying out specific artifacts to upload for each standard and elements they should include can prove helpful as you prepare. That’ll be the focus of these articles.

ACQ evaluators will consider information obtained from your documentation, practices, and interviews. This process is intended to help position you and your organization for success in those areas.

NEAR-TERM ACTIONABLE ITEMS

In the meantime, here are some things you can do right now to get the process going.

1. Set up your folder structure

However you manage documents (Google Drive, SharePoint, Dropbox, etc.), create a main ACQ folder. Inside it, create subfolders by section, for example, Section 1 Business Operations, and standard, for example, 1.06 Organizational Capacity. Or, just by standard is fine too.

This becomes your working system, not just a pre-submission folder.

2. Prepare to track your progress

Subscribe if you haven’t already, and reply “tracker”. I’ll send it before we kick off. This is a model for how a tracker might be structured, highlighting a few examples standards, not all of them. For clients, we keep it updated as they move through each standard.

3. Align your team on what this is (and isn’t)

This isn’t about pulling documents together last minute. It’s about making sure what you have:

• Exists

• Aligns with actual practice

• And is likely to hold up in conversation

Tell them ACQ is coming, what it is, and that documentation and alignment will matter. People prepare differently when they know it’s real. If your team understands that upfront, everything moves faster later.

I’ll aim to keep content practical for submission, and impactful for operations where applicable.

THE WHY

I’ve been asked what I’m getting out of this and whether it’s really free.

It is free. The goal is twofold:

1. Put out quality information that has real value on its own, without requiring upgrades. For many groups, this will be enough.

2. Share how I think and work with those who may want more support over time.

There are three levels:

Free (this Substack):

A working model you can use and adapt on your own. Again, this is meant to have meaningful value on its own and will be sufficient for some.

Paid subscribers (down the road):

Additional resources, updated trackers, and sample content to support your process, without full hands-on involvement.

Clients (Partners ABA):

1. Individualized pacing based on your needs and services. I.e. individual standards will be sent on a cadence aligned with your team’s progress

2. Review and individualized feedback on each submission, in alignment with your pace

3. Support in developing and adopting policies, standards, and practices to the extent needed by clients and within scope of selected service package

This isn’t about holding value back. The free content stands on its own. The difference is level of support.

What we won’t do, at any level:

We will not create your files independently without your involvement. That’s not what the ACQ process is about, and it won’t hold up.

And although it should go without saying, I’m not speaking on behalf of ACQ. This is guidance based on experience. You’re responsible for your own interpretations and submissions.

That’s it for this week. See some of you Friday at MassABA. The rest of you, the first standard is coming within a couple of weeks.

If you know others who may benefit from this, I’d appreciate it if you’d invite them to join.

Brandon Herscovitch, PhD, BCBA-D

partnersaba.com

partnersaba.substack.com

The document raises real and important structural questions, especially around governance, incentives, and the concentration of influence. I feel its inquiry into the practical impact on smaller and independent providers is particularly relevant, and it’s something smaller providers have understood for some time. There does appear to be a broader, system-level trend where increasing compliance, accreditation, and operational requirements can disproportionately burden smaller organizations. That is not unique to ABA, but it is real, and it is worth addressing thoughtfully.

Where the argument seems less grounded is in how it frames legitimacy and authority. The implication that authority must come from a democratic or field-wide election process reflects a preference, not a standard that is consistently applied across healthcare. It’s my understanding that many influential organizations in other fields were not formally elected into their roles. In practice, authority tends to emerge from a combination of organization, resources, engagement with payers and regulators, and the ability to execute. That does not automatically make it ideal, but it does make it typical.

Related to that, the concerns about conflicts of interest and closed-loop systems are valid at a structural level. At the same time, similar dynamics exist across healthcare, where organizations contribute to standards, accreditation, and payer expectations within the same ecosystem. The key question is not whether these dynamics exist, but whether they are balanced with appropriate safeguards and produce acceptable outcomes. Framing this as uniquely problematic risks overstating the issue.

It is also important to recognize the role of incentives. Trade associations, by definition, operate under different contingencies than professional organizations, academic bodies, regulators, or funders. Those differences are not inherently problematic. In many cases, they are necessary. Sustainable service delivery requires input from those directly responsible for operating organizations, managing costs, outcomes, and maintaining access.

At the same time, this is not to suggest that other stakeholder voices are less important or should be minimized. Rather, it is to recognize that no group is less biased. Each operates under its own contingencies, and it is not clear that any one set of incentives is inherently better positioned to support long-term outcomes for the field, particularly in the roles these organizations are playing. In many cases, those perspectives already have platforms through which they are represented.

There is a practical tension here. Clinicians want quality, integrity, and balanced work conditions. Operators need sustainability, outcomes, and scalability. Regulators want oversight, protection, and cost control. No single group is neutral. Suggesting that one category of stakeholder is inherently better positioned to govern the field is likely an oversimplification. A more productive framing may be how to balance these competing contingencies rather than attempting to eliminate them.

The document also critiques specific positions, such as those related to workforce standards and credentialing. Those debates are real, but they are often more nuanced than presented. In some cases, what is framed as a compromise in quality may also reflect constraints around workforce availability, access to care, or operational feasibility. That does not resolve the tension, but it does complicate a purely one-sided interpretation.

A key piece that seems underdeveloped is the question of what a viable alternative would look like in practice. It is one thing to argue that current governance is imperfect. It is another to establish an alternative structure that has the scale, coordination, and incentives necessary to function effectively. Without that, there is a risk of replacing one set of trade-offs with another, or recreating similar dynamics under a different name.

It is also worth noting that the current structure did not emerge in a vacuum. It developed in response to rapid growth, increased funding, and a lack of pre-existing centralized governance. In that context, it is not surprising that organizations with the resources and incentives to act stepped into that space. If those organizations did not, it is not clear that a more neutral or ideal body would have emerged instead.

In my own experience helping to start a trade association in the past, there were active discussions around how to structure representation across organizations of different sizes and resources. There are multiple ways to approach that balance. It is possible that similar considerations were made here, though I am not in a position to speak to that, and it is outside the scope of what I can assess directly.

None of this is to say there are no issues. There likely are, and they deserve careful, balanced discussion. But framing the situation as inherently unethical or illegitimate may miss the more practical reality. These dynamics reflect common patterns in how fields evolve, particularly when demand, funding, and external pressures increase quickly.

It seems to me the more useful path forward may not be to reject existing structures outright, but to engage with them, refine them, and ensure that multiple stakeholder perspectives, including independent providers and clinicians, are meaningfully incorporated.

It is also possible that some of this is already occurring to a degree. At the same time, these are paid membership organizations, which is a practical reality. That can be viewed as either a strength or a limitation depending on perspective, as it both creates alignment of incentives and introduces potential bias. Ultimately, any proposed alternative should be evaluated not just on its ideals, but on whether it can realistically operate at scale, sustain itself, and align incentives in a way that supports both quality and access over time.

I’m not in a position to fully assess the intent or approach behind this position statement, and to some extent that may not be the most important question. These dynamics now exist, and there is a shared responsibility across the field to respond in a way that leads to the best outcomes for the profession and, most importantly, the people we serve.

This isn’t abstract. At the same time, any system like this involves a complex web of contingencies, whether organizational, financial, or political. How we engage with this moment matters. It affects how we all practice and how people receive care.

If you haven’t started, you probably don’t realize how deep it goes.

It’s not just a paperwork exercise. ACQ forces you to tighten the operational backbone that, when loose, leads to more audits, recoupments, and consequences.

Starting soon, I’ll walk through every ACQ standard one at a time. Each post will include concise guidance, including notes on where organizations typically stumble.

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Other practical and impactful tools and resources coming through there too.

If you know other providers working on ACQ prep, or who ought to be, send this their way. The more of us thinking about this together, the stronger we all get.