What You Didn't Know About the Hurdles of Autism Care in Illinois
In this episode, we sit down with Karem Alnatafgi and Heather Teichman from the Illinois Providers for ABA Access and Quality (IPAAQ) to explore the challenges and complexities of providing high-quality ABA therapy in Illinois. From limited access and inconsistencies in care to the impact of licensure laws and the corporate practice of medicine, they break down the issues that shape the autism services landscape across the state.
While the conversation centers on Illinois, these challenges are far from unique — providers, families, and advocates across the country are facing similar obstacles. Karem and Heather emphasize the power of provider collaboration, community involvement, and advocacy to drive change not just locally, but nationwide.
This conversation offers insight, hope, and a call to action for anyone invested in improving autism services across the U.S.
What You Didn't Know About the Hurdles of Autism Care in Illinois
All Autism Talk
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Learn more on IPAAQ’s Website
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Richie Ploesch
Kareem and Heather, thank you so much for being here. It's a pleasure to have you.
Heather Teichman
Thanks for having us.
Karem Alnatafgi
Thank you so much.
Richie
So one of the things I want us to talk about is this organization, IPAC, and sort of what you all are doing. Can you start by just giving us a, open the hood, so to speak, and let us hear a little bit about what you all are doing?
Heather
So, Kareem, I don't know if you want to jump in. I can definitely tell you IPAC stands for Illinois Providers for ABA Access and Quality. And we are a new group in Illinois that's representing organizations. And we have particular issues we're working on now, but we're also looking to work on a variety of issues over time that will improve ABA access, that will improve quality of care and will hopefully improve funder reimbursement as well.
Karem
Another big thing that IPAC is focusing on is creating a collaborative community of providers. So having different kinds of organizations get into one group that's able to discuss various potential issues with legislation or any kind of payer issues that we have with being in the state of Illinois, particularly. I've seen from the first couple of months that IPAC has been launched.
There has been a tremendous amount of collaboration between large organizations, small organizations, mid-size organizations that has really helped create that community piece so then we can better service our families and provide that high quality therapy that Heather was speaking about. Illinois at the moment is a very complex landscape with legislation, with payer rates. So IPAC is definitely
Richie
Thank you.
Karem
trying to gear up to try and advocate for certain things that will improve the quality of care that the community is providing to the autism community as a whole.
Richie
Beautiful. Thank you both for that. Heather, I want to start with you for this first question. And I think this is something you both mentioned, this concept of ABA access and some of the challenges that are happening sort of within Illinois and really across the nation at this point, but really focusing on Illinois for the moment. Heather, are some of the, when you think about ABA access, what comes to mind and what are some of the barriers?
Heather
think there's several factors that impact families' ability to access ABA. One of those, of course, being just supply and demand of providers to deliver these services. There are not enough BCBAs. There are not enough behavior technicians or registered behavior technicians. And so unfortunately, there are just far more families seeking services than there are providers who can deliver these services. And I would say that's probably one of the just factors. Then of course there's coverage to make sure that it's affordable for families. There can be high out-of-pockets or deductibles that could impact them. And then also time of day. Families whose children are in school and who are looking for after-school hours tend to face even more of a bottleneck of a wait list. So I think there's a lot of things that hopefully we can work on as a field and improve over time.
Richie
I feel like that supply and demand piece has been sort of a conversation for the last 20 plus years of my career and the next 20 plus years of my career. will be, I don't, you know, I think there's a lot of work to being, to be done on that, but what are some of the challenges that you were seeing, specifically with the supply and demand and, also with some of the legislation that's pending and how that's limiting access.
Heather
So definitely, I think even though more BCBAs are passing the exam each year, as we know, there are more kids with autism being diagnosed each year as well. And many individuals with autism require our services for years at a time before they're able to fade or move on to less intensive services. And so even with more professionals entering the field, that does create, again, a backup where we just need more. We need more of them. I think there's a lot of barriers. It's a master's degree, there's field work experience. All healthcare jobs are not paid equivalent to what we think they should be paid. And so being able to attract people into this field and maintain them into this field, I think are also considerations.
Richie
Right.
Heather
And then in Illinois in particular, when you add on top of that the recent BCBA licensure law and the corporate practice of medicine restrictions that were inherent in that law, that can also create some more access issues down the line as well.
Richie
I want to talk about that, but in a minute, because I feel like that whole that whole thing is a there's a lot to unpack there. Can we come back to that? that OK, Heather? Great, great. And certainly either one of you feel free to chime in on either of these questions. I want this to be an open discussion. I'll just kind of ping pong back and forth. That's OK. Excuse me, Kareem, there was something that you mentioned.
Heather
Mm-hmm. Absolutely.
Richie
that I think is also important when we're talking about access and that's the quality of care. It's not just about making sure that people can get access to care. It's making sure that that, that that care is of quality, right? And, and it's not just, you know, you can certainly give a lot of people a lot of access, but if it's not helping and it's not beneficial and it's not in line with what the expectations are, that's not a good thing either. So can you tell us a little bit about some of the standards of quality of care that you were referencing?
Karem
Absolutely. So there are a few things that Heather mentioned earlier about the bottleneck effect, right? So having the constant rising rates in autism diagnosis. And although there are more more certificates being passing the BCBA exam, passing the RBT exam to be able to provide these services, the timeline is just placing a lot of pressure on certain providers with the supply and demand, right? such little supply for such high demand for services. Therefore, we're finding ourselves having to speed up to offer people very time sensitive and life changing therapy. Evidence shows us that ABA, the sooner it's given, the more effective it can be. Therefore, we have to all come together as a field and make these decisions. As far as quality is concerned, there are various barriers that put that are put in place at the moment that impact our quality. The biggest one from my perspective would be the reimbursement rates. We aren't able to attract high quality talent and high quality of services through these clinicians if we're not able to offer them a valuable living wage, especially on the frontline level. So paraprofessionals, direct support professionals, RBT's, or anybody in the service industry that works on the front lines. At the moment, the industry is not compensating them enough. Therefore, if we are fighting for that quality, we need to be able to make sure that these people that are working with our children and our teens and adults on the autism spectrum are able to earn a valuable annual income. Unfortunately, providers are not able to do so with limited budgets and limited reimbursement rates.
Richie
Right. Yeah. I mean, I think, you know, as the. Yeah, I, I'm just thinking like who all needs to hear about that, right? The parents need to know about that, right? The technicians need to know about that. The behavior analysts need to know about that. This, this concept of making sure that we've got a, the appropriate reimbursement rate is a very important one for the entire community to be aware of. Would you agree, Heather, you're shaking your head? Yes. It seems like you want to add to that.
Heather
Yeah, I think, you know, one of the other factors is there's no law or rule on when insurance reviews their rates. And so we also get into situations where the reimbursement rate may remain stagnant for really staggering periods of time. It could be eight, 10 years between increases or over that course of time, you might get increases of 2%. We know cost of living goes up more than that. know people, if we have good retention, people who are here year over year, they want their rates to go up more than that. Insurance companies have all the power. It's really hard to negotiate with them. so I think that's another barrier to it is that there's really no requirement for them to review or raise their rates on any given timeline or by any given amount.
Richie
Hmm. That's interesting. I didn't realize that.
Heather
Yes, it's a big problem.
Richie
Yeah, yeah. So I imagine part of the part of the ways to combat that is back to something that know, cream you had mentioned sort of at the top of the top of the episode, which is this collaborative community where people can come together and talk about this and how this impacts not just the families, but the technicians and also the organizations. Can you talk about some of that collaboration that's happening from I pack?
Karem
So without IPAC, I wouldn't have been able to come into contact with, I first of all want to thank the board. The board has been extremely collaborative and we've all kind of worn multiple hats in the first couple of months to get this organization launched, along with getting the word out to other providers like, hey, we're here, we exist, we're here to help you, let's put our hands together and collaborate. But in some people's eyes, we might all be competitors. We're all trying to fight for the same thing, right? We're all trying to establish stronger organizations. We're trying to establish a strong referral network for the families that we can't accommodate. So then we ensure that the community has access to these services. At the same time, we're trying to get together and discuss these statewide issues that put limitations and burdens on us for operating our practices, regardless of the size, right? So when Heather mentioned the Behavior Analyst Licensure Act, the biggest section in there would be ownership. We all come from very different ownership structures. I'm a small business owner, independently owned. Some other providers may be BCBA owned or another kind of clinician that is involved in the ownership. Now that the state has come up with that decision, there's more limitation on who can and cannot operate these practices. Therefore, the access piece of it, if we don't all come together and show legislators and show the community that there is a need for this to change, we're not gonna be able to make much of a difference for the families at hand, right?
Richie
Yeah, that's interesting, right? mean, getting everybody together. I think a lot of people just from the outside looking in say, you're all competing for the same clients. to your point, Kareem, no, we're all cooperating and trying to support the same clients. And I think that's a different mindset and a different viewpoint.
Karem
Absolutely. And I mean, in my practice, we do have a pretty large wait list that we cannot immediately accommodate for due to that supply and demand concept that we discussed earlier. So I would much rather have the ability to collaborate with Heather's practice and refer clients back and forth within a reasonable geographical area than to just have these clients waiting for months or sometimes years on end to get access to these very time sensitive, life changing services. So that piece of it too has really helped bridge that gap of we're not competing, we're collaborating.
Richie
like that. Heather, want to, were you going to add to that Heather?
Heather
No, think Karim summed it up the best. It's really all about collaboration. Even among people that seem to be competitors, we're all impacted by the same issues.
Richie
you both have mentioned this piece of legislation and so I'm ready for it. I'm ready for the corporate practice of medicine. I'm ready for the summary. Heather, can you tell us a little bit? The licensure law that was that is pending is pending or is passed. Passed. Excuse me. So the licensure law that passed and some of the barriers that it presents to the community.
Heather
Mm-hmm. Absolutely. first off, licensure is really not what's presenting the issue. Having licensed behavior analysts creates a higher level of oversight and monitoring. But the issue that we're working on is that within this licensure law that stipulates that BCBAs must be licensed by the state is a section that includes language related to what's called the corporate practice of medicine. And so this language states that a practice that is providing applied behavior analysis services must be owned by a licensed clinician. And not just any licensed clinician, but a licensed BCBA. And so that creates a lot of issues because many, many companies currently in operation today are not owned by a licensed BCBA, or at least not fully owned by one. And if we are not able to change this portion of the licensure law, it would require many companies, so this would be impacting thousands of families in Illinois, thousands of employees in Illinois who work for these companies to reorganize their structure which might cause some of them to have to close down and seize operations, but also just diverts attention, funds, effort away from our clients and our staff. I'm sure Kareem would agree. I would rather focus our money on further supporting our team and our clients and resources for them than on lawyers fees to reorganize the business. And I'd rather make sure that we buy fireside sees over 400 clients in Illinois and we really want to make sure that those services don't get disrupted and that these families continue to have consistent access to care.
Richie
Yeah, it seems like that was some verbiage that I don't know if that was intentional or not. I don't know that was by design or not. wasn't part of that process, but it seems like that's one of those things that just the nature of it is going to is going to create some of the problems you all are trying to combat, right? It's going to minimize access. It's going to lower the quality potentially because now instead of people focusing on how to implement staff trainings and update and make sure families are getting the services that they need and make sure that they're onboarding clients and getting everything that they need so that they can get started. Now they're worrying about the corporate structure to your point, right? And that's not part of what we need to be addressing as a community. Yeah. You did mention that there were some good things in there, right? Some increases in monitoring and oversight. Can you tell us a little bit about those and the licensure that and what that would require?
Heather
Exactly. Absolutely. Absolutely, being licensed by the state puts BCBAs kind of under the oversight of IDFPR. And so what that allows is more protection for consumers to be able to have a place to report if they do feel that unethical practices are happening. And that gives the state some jurisdiction over investigating that and applying potential consequences if they find that there are violations or unethical practices going on.
Karem
I would like to quickly mention the just one of the biggest reasons why we're all coming together and trying to fight this is mainly just because if we take our clinicians out of the treatment rooms, we're hurting the supply and demand problem, right? We're making it worse. we're essentially, this law is essentially telling BCBAs and licensed behavior analysts to run these businesses to sit down and look at spreadsheets all day versus creating treatment plans for the various number of children in Illinois that are seeking services, right? They're running payroll, they are coming up with business plans, they're talking to vendors, you know what I mean? That would take them out of direction for that piece of quality of care and access to care. So these are the biggest kind-kinds of concerns that the general members, the board members, and everybody from various different organizational structures is having, right? Well, we have a BCBA that is no longer able to service that list of clients that are waiting for services and having to run our payroll or pay our bills. So it's very, very difficult to think of it that way. That this is essentially reality now and we have to all come together and reverse or appeal or try to find a win-win solution that would protect the consumer and protect the industry at the same time keep the ability for us to meet that demand for services.
Richie
Yeah, that makes perfect sense. Kareem. mean, the more that clinicians have to say yes to that also means the more they have to say no to. And when they're having to say no to providing services to individuals and their families and yes to payroll and spreadsheets and signing on Costco deliveries and things of that nature, then that just means they don't have time for the other. And that's not, I don't think that's the intent of the community at this moment. Yeah.
Heather
think the other thing I'd like to add is one of the side effects of the corporate practice of medicine language as it is written is that who it's really going to hurt are those smaller providers that are not backed by private equity. So for example, both Kareem and I work for companies that are self-funded and I don't think there's anything wrong with private equity. I think just like everyone else, there's good examples of that and less good examples of that But at the end of the day, the companies that are backed by private equity are probably most likely to have the funds to be able to reorganize and get into the ownership structure that this particular law would require. It's smaller companies that don't have those deep pockets behind them that are owned by their single owner like Cream or like the company that I work for that potentially may struggle more with that change. And I think that all providers, no matter the size or the ownership structure, can bring value and bring different viewpoints and perspectives into the field and I would hate to shut that avenue down.
Richie
Yeah. Yeah, no, I appreciate that perspective. That's not something I had really considered, but I mean, you're absolutely right. The cost, the cost alone for some of what we're talking about is going to be prohibitive. And again, it's already hard enough. There's already enough mountains to climb uphill. We don't need to make more. Yeah.
Heather
Exactly. You know, don't want to have to choose between, if we have to put aside hundreds of thousands of dollars to reorganize when that could have been money that I budgeted next year for then staff training or materials, resources, things of that nature. I'd much rather take that money and spend it on the clients and the team.
Richie
And then Kareem, from your perspective, from a small business perspective, how do you get this information? How did you find out that this law was pending and passed? How did you find out and interpret, you know, how it was going to impact you in your daily operations?
Karem
From my experience, I've always been very involved with the local industry and I've made it a point to be in pretty much every conversation I possibly could be to make sure that my business is not only protected, but also representing the large community of small business owners that I'm hoping to stand up for Although I do see that there are some issues where small business owners do not know that this is a thing, right? They don't know that the state has already passed this, that it's already written into law, and that IPAC and various lobbying efforts are trying to essentially reverse or change or modify to help this language loosen up and not impact the access and quality that we're trying to stand for.
Richie
Hmm.
Karem
Therefore, I heavily want to encourage small business owners to get out there, get educated, reach out to us and reach out to other people in the field locally that are familiar with these things because this is essentially going to impact everybody in some capacity.
Richie
Yeah, Kareem, let's stay there for just a minute, right? I feel like a lot of people say, I don't have time for that. That's just, that's happening over there. And they kind of keep everything at arm's length, right? And it's so, it's just so easy to sort of turn a blind eye to what's happening, but how, how, how can people get involved? Right? I mean, this is not the, how can they be a part of this process?
Karem
I think the biggest thing that we need to focus on is changing the narrative of, like we spoke about earlier, competition versus collaboration. Once people have that idea that collaboration is the bridge to quality and the bridge to better servicing the community that we all take an oath to service with the highest level of care, they're able to change their mindset about whether or not they would like to get involved in these efforts. Just because a business owner is a licensed clinician and that this wouldn't essentially be a complete disruption for them doesn't mean that this is not going to impact the network itself, right? When funders create networks, we're all part of the network together trying to service the beneficiaries under those insurance plans. We all need to part of all of our contracts is being able to refer to another in-network provider, right? So the way for people to get involved, from my perspective is don't be afraid of having conversations. And I've had the best conversations as a young, very, very young and starter business owner with big people in the field that I've been able to connect with not only personally, but professionally. And all of this has tremendously helped my practice to not only gain the visibility, but also the credibility, right? I've been able to bounce ideas back and forth on operations, on even certain things like employment, right? How do we better structure our employment for clinicians in the field so then we can open up more opportunities for these families that are on a all of our wait lists essentially. So people that are trying to get involved in this effort specifically, even if it doesn't cause the level of disruption that it will cause others, it's important that we all support each other and think of each other as a community versus a long list of competitors.
Richie
Heather, for people to get involved in IPAC, what do they need to be doing?
Heather
Well, it's really simple. IPAC is on social media. We're on Instagram. We're on LinkedIn. We also have a website. And so by reaching out to either any of the individual board members or connecting with us on social media as well. We'd be happy to have conversations, make sure that any other providers are well-versed in the issues that we're working on. We're happy to have people join us at a meeting, before officially joining, just to see who we are, what we're talking about. I think, just like Kareem said, it's about collaboration, and it's about getting as many providers as possible so that we have wide representation. IPAC really prioritizes the voice of our members and so the directions that we go in and the initiatives that we work on are going to be based on what do our members want to do. It's not just based on the few voices of the board who are just leading that and steering that. And so whatever matters in this field, we want to hear about that from providers and we want to be able to pool our collective resources and our collective voices to work on that together.
Richie
Great. I want to go back to something real quick. I'm sorry. We're going to go a little out of order. you mentioned that you were trying to combat some of this legislation and correct some of the verbiage in this law that just passed. What does that process look like that? I can't imagine that that's just an email to an inbox somewhere. That's a, that's a long arduous process.
Heather
It is a long process. do have a lobbyist team that we're working with. And what we're really trying to do is amend the language to state that anyone in an organization that's providing ABA services who is directly overseeing or making decisions regarding clinical treatment must be a licensed behavior analyst. So what that would do is would still protect quality. It would still ensure that the person who is making those clinical policies and procedures does have the necessary background and education to do that, but while also giving some flexibility for the actual ownership structure.
Richie
Yeah, yeah. Well, I have to say just I want to appreciate both of you for a second and just the work that IPAC is doing and I understand the intention behind some of these legislations and I understand what they're trying to do and it doesn't always happen. Like the implementation doesn't always match. So I just appreciate each of you and your and your resources and your communities advocating on behalf of really the families and the providers. And I just think that's so important and I just hope we can continue to do that and do that in a variety of ways. So thank you.
Heather
Thank you for having us on.
Karem
Thank much.
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Q: What does the new Illinois law state?
A: IL PA 102-0953 was created to license behavior analysts in Illinois so they could directly oversee Medicaid-funded ABA services, which was expected to expand access for families. However, Section 150 includes confusing language stating that any business providing ABA services must have every owner, officer, director, or employee licensed. The Illinois Department of Financial and Professional Regulation (IDFPR) has interpreted this to mean that, starting January 15, 2027, ABA companies must be entirely owned and operated by licensed behavior analysts. This Corporate Practice of Medicine (CPOM) restriction could force many existing ABA providers to shut down, limiting access to autism services instead of expanding it.
Q: Doesn’t the new Corporate Practice of Medicine (CPOM) guarantee that client care decisions will always be made in the best interest of the client, since they’ll be made by a licensed behavior analyst?
A: The BACB ethics guidelines already require Board Certified Behavior Analysts (BCBAs) to act in the client’s best interest. In fact, the high demand for ABA services gives BCBAs many job opportunities, so companies that cut corners or compromise ethical treatment quickly lose their staff and the ability to serve clients. Families also have options—if they feel their child’s needs aren’t being met, they can move to another provider. In addition, both parents and staff can file complaints with state regulators or payers (such as HFS HealthChoice Illinois Ombudsman or the Department of Insurance). In practice, companies are able to keep staff, clients, and payer relationships only by providing high-quality, ethical ABA services.
Q: Why does IDFPR require every owner and officer of an ABA company to be licensed?
A: IDFPR calls this “standard language” intended to protect consumers from bad actors by allowing the state to revoke a company’s license if needed. However, ABA services have been successfully provided in Illinois for nearly 20 years without widespread issues. Changing the rules now creates major operational disruptions, forcing companies to spend significant time and money addressing a problem that largely doesn’t exist. Section 150 is also far more restrictive than rules for other licensed professions—like Speech-Language Pathology—which do not require every owner, officer, or director to hold a license.
Q: There are other licensed fields that have CPOM requirements. Why are ABA companies resisting this structure?
A: Section 150 is far more restrictive than CPOM rules for other professions, like Speech-Language Pathology, because it requires every owner, officer, and director to be a licensed BCBA. Some other licensed professions don’t even have this requirement. ABA services are highly intensive: children with autism often receive 10–40 hours per week delivered by a team of multiple technicians and a licensed behavior analyst. A practice serving 50 children may have 40–60 clinical staff, whereas an SLP clinic serving the same number of clients typically has only 2 SLPs. Complying with Section 150 would require moving dozens or even hundreds of employees to new BCBA-owned entities, making the restructuring process far more complex, disruptive, and labor-intensive than in other healthcare fields.
Q: Will CPOM protect ABA services from Private Equity and ensure families receive quality care rather than profit-driven services?
A: It’s important to note that Private Equity (PE) is already present in Illinois ABA services. PE firms often have the resources to adapt to new requirements, and it’s inaccurate to assume all PE-backed companies provide lower-quality care—doing so unfairly generalizes based on ownership alone. In fact, maintaining quality outcomes, compliance, and customer satisfaction is usually in the financial interest of any investor, since unethical practices can lead to losing staff, clients, and payer relationships.
However, CPOM will require nearly all ABA providers to restructure, disproportionately impacting small to medium-sized providers with non-licensed owners. Examples include:
Family-owned businesses with a licensed and unlicensed spouse as co-owners.
Parents of children with autism who wish to own ABA service organizations.
Partnerships between licensed BCBAs and non-licensed operational partners.
Licensed BCBAs who accepted “angel investments” from friends or family.
BCBA-owners planning to sell or retire in the future.
Regardless of ownership, every ABA organization must maintain financial sustainability to support operations, reinvest in services, and adapt to changing needs—whether led by a BCBA, backed by PE, or organized as a for-profit or non-profit.
Q: Will Section 150 encourage more licensed behavior analysts to start their own practices, benefiting families in Illinois?
A: While CPOM may motivate some licensed behavior analysts (BCBAs) to start their own practices, doing so diverts time away from providing ABA services at a time when demand already outpaces supply. New BCBA-run practices cannot scale quickly enough to offset the immediate impact of Section 150 on existing providers, due to the significant time and financial investment required.
Starting a practice requires substantial capital and strong business skills—being a skilled clinician does not automatically mean a BCBA can successfully operate a business. For example, a single child with autism may receive 20–30 hours of ABA services per week, and reimbursement for these services can take weeks or months. To maintain staff and service delivery, a new practice must have enough funds to cover multiple payroll cycles, which often requires external investment beyond what a single BCBA can provide.
Q: Is complying with CPOM really a big deal, or are companies overreacting?
A: While it may be easier for a few companies, for most ABA providers, complying with CPOM requires a major ownership restructure:
Some would need to sell or give away practices they’ve built over years.
They would need to create or contract with a Managed Services Organization (MSO).
New entities would have to negotiate new insurance contracts, which can be challenging due to closed networks or lower rates for new providers.
Staff re-credentialing and client reauthorizations would be required, putting further strain on an already overtaxed insurance system.
Some ABA companies have already indicated they may close their Illinois operations if Section 150 remains in place.
Q: It seems beneficial for all owners and decision-makers to be licensed behavior analysts. Why is this problematic?
A: Section 150 would require all key decision-makers—owners, directors, officers, etc.—to be licensed BCBAs. Running and scaling an ABA organization is extremely complex, and being a skilled clinician does not automatically equip a behavior analyst to successfully manage a business.
Behavior analysts are not trained in critical business areas such as revenue cycle management, accounting, cash flow, and human resources. Most BCBAs rely on specialized partners or officers to manage these functions. Requiring all owners to be BCBAs would pull clinicians away from working with clients, worsening the existing shortage of licensed behavior analysts in Illinois.
Q: Some companies have already started complying with Section 150. Wouldn’t it be unfair to repeal it now?
A: While a few providers may have begun compliance, most companies—especially those needing a Management Services Organization (MSO) and Management Services Agreement (MSA)—have not. Companies already BCBA-owned are minimally affected in the short term. Transitioning to PC/PLLC doesn’t inherently devalue their business, but Section 150 limits future options when they want to sell, reducing the pool of potential buyers and lowering the company’s value.
Repealing Section 150 would not harm compliant companies; in fact, it would protect their long-term value. Asking non-licensed owners to give up practices they built is both short-sighted and harsh, particularly since there is no evidence that Section 150 solves a real problem—and it risks reducing access to ABA services for families.
Q: Can smaller ABA companies avoid Section 150 by becoming non-profits?
A: Suggesting that companies can sidestep Section 150 by converting to a non-profit highlights that the law isn’t truly about ensuring quality care or protecting consumers. Licensure alone doesn’t guarantee effective leadership or high-quality services, and families may suffer from reduced access as BCBAs are diverted from client care to meet compliance requirements.
Requiring non-licensed owners to divest or convert to a non-profit disregards the time, energy, and financial investment they’ve put into building their organization. Non-profits are not automatically more ethical than for-profits, and Section 150 offers no real consumer protections for families seeking ABA services.
Q: Isn’t the impact of CPOM compliance short-lived? Once companies restructure, won’t things improve?
A: The impact on Illinois ABA providers could be long-lasting. For most companies, this unfunded regulation diverts significant financial and leadership resources away from patient care to cover legal and restructuring fees. Even small companies can be heavily affected, and larger providers may spend hundreds of thousands of dollars and hundreds of hours on compliance instead of investing in staff training, quality assurance, or direct clinical care.
Section 150 also limits key roles—directors and officers must be licensed BCBAs—reducing the ability to hire specialized personnel needed to expand services. Managed Service Organizations (MSOs) may help, but efficiency is lost, increasing costs in an already challenging industry. Additionally, succession and sale options for BCBA-owned practices will be severely restricted, as only licensed BCBAs could purchase these companies, making long-term planning and growth difficult.
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