Operating outside your scope of practice is an ethics violation and a patient-safety risk. This policy defines the reporting structure and the boundaries of each role.
| Role | Reports To |
| Behavior Services Director (BCBA) | Director of Residential Operations |
| BCaBA | BCBA |
| Lead RBT | BCBA |
| MANDT Instructor | BCBA |
| RBT | BCBA, with day-to-day direction from the Lead RBT |
2
Behavior Services Director (BCBA)
Also called the Behavior Analyst, BCBA, or Licensed Behavior Analyst (LBA). Requires BACB BCBA certification and active Missouri LBA licensure.
Exclusive, non-delegable responsibilities:
- Conducting FBAs and functional analyses
- Designing, writing, and revising BSPs and skill-acquisition plans
- All clinical decisions โ treatment goals, intervention strategies, plan modifications
- Interpreting data to modify, fade, or discontinue a program
- Authorizing restrictive procedures and managing the Due Process pipeline
- Signing all clinical documentation to DMH, Medicaid, and funders
May delegate to qualified RBTs and Lead RBTs with verified competency:
- Implementing BSPs and skill programs as written
- Collecting data per the plan
- Conducting preference assessments
- Participating in FBA components โ descriptive assessment, ABC data collection
- Modeling BSP implementation for residential staff when directed (demonstration only)
3
Lead RBT โ may / may not
| May | May Not |
| Perform all RBT activities | Conduct FBAs or functional analyses independently |
| Serve as day-to-day operational point of contact for RBTs, routing clinical questions to the BCBA | Write, modify, or revise BSPs, skill plans, or data-collection procedures |
| Conduct fidelity-check observations and report to the BCBA | Make independent clinical decisions or override BCBA guidance |
| Model BSP implementation for new RBTs (demo only) when directed | Approve or authorize restrictive procedures |
| Communicate clinical updates and escalate concerns | Sign clinical documents on behalf of the BCBA |
| Provide RBT caseload coverage when authorized | Serve as primary supervisor of record for RBT certification |
| Train and coach RBTs on documentation (correct service codes in SetWorks, note content and timeliness, identifying and correcting errors before submission) and on behavior department policies | |
| Teach and coach RBTs and caregivers in Tools of Choice โ Tools of Choice is not a BSP and is not BACB-governed, so the modeling-only rule does not apply to it | Train caregivers on the BSP โ family/caregiver BSP training is a BCBA responsibility (CPT 97156, not an RBT code) |
| May | May Not |
| Implement BSPs and skill plans exactly as written | Conduct FBAs or functional analyses independently |
| Collect data (continuous, discontinuous, or other per the BSP) | Design, write, or modify BSPs, skill plans, or data systems |
| Conduct preference assessments under BCBA direction | Make independent clinical decisions of any kind |
| Participate in FBA descriptive assessment and ABC data under BCBA direction | Approve, modify, or implement any restrictive procedure without written authorization |
| Model BSP for residential staff (demo only) when directed | Independently change CPT codes, session times, or billing |
| Report observations, data irregularities, and environmental concerns to the BCBA | Provide clinical recommendations to families or guardians without BCBA direction |
| Participate in supervision meetings and team discussions | Conduct or complete any portion of an FBA report |
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Modeling for residential staff. RBTs may model BSP techniques in front of residential staff
only when directed by the BCBA and only as a demonstration. RBTs do NOT deliver staff training, coach residential staff, give corrective fidelity feedback, evaluate competency, or determine readiness โ those are BCBA and BCaBA responsibilities. These restrictions apply to
BACB-governed clinical work. Tools of Choice is
not BACB-governed and is addressed separately in Chapter 6 (
B6.1).
5
Lead RBT โ DBT skills coaching for staff
The Lead RBT is the agency's DBT skills coach for employees. This is provided when an employee is referred after a crisis incident, behavioral difficulty, or emotional-regulation challenge, and it covers distress tolerance, emotional regulation, and interpersonal effectiveness. DBT concepts are introduced to all new hires at orientation.
- Before any session, the Lead RBT obtains a signed consent form and submits it to HR for the personnel file
- DBT coaching is educational and supportive only โ not therapy, not billable, and not documented as clinical treatment
6
Lead RBT โ operational duties
| Duty | Expectation |
| Shared RBT office space | Keep it professional, organized, and confidentiality-compliant. No discussing individuals in unsecured spaces. No visible PHI on desks, screens, or whiteboards. Escalate repeated concerns to the BCBA. |
| Weekly RBT supervision meeting minutes | Take and upload to the Google Drive 2026 Meeting Minutes folder |
| Abilibucks daily operations | Run under BCBA direction (see B9.1) |
7
RBT pickup of DSP shifts
Allowed around RBT hours only when ALL of the following are met:
- Posted and accepted in WhenToWork
- Active DSP certs (CPR, First Aid, Bloodborne Pathogens, LIMA, MANDT, Delegation where applicable)
- Signed and acknowledged all applicable DSP policies
- No conflict with RBT services, documentation, or supervision
- Lead RBT approval (discretionary, based on department needs)
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While working a DSP shift, it is governed by DSP policies for its full duration โ DSP attendance, conduct, and discipline. It is a privilege and may be restricted or revoked.
A full-time Behavior Department position. Holds the MANDT Instructor certification plus an active RBT certification. This is a dual role:
- MANDT Instruction โ delivers all MANDT crisis prevention and intervention training agency-wide and is the primary MANDT resource. The QAP tracks MANDT cert dates and schedules renewals.
- RBT Role โ when not training, operates as a licensed RBT subject to all RBT policies, scope, and supervision
Abilities covers all MANDT Instructor costs โ initial cert, renewals, recert fees, and CE.
| Function | Description |
| MANDT Training Delivery | Delivers MANDT training agency-wide |
| Recertification Management | Tracks employee MANDT expirations and schedules renewals |
| RBT Service Delivery | Operates as an RBT when not training |
| Crisis Consultation | Behavioral crisis resource when on shift |
9
Intersection with Residential Services
Session time is protected.
- During a scheduled session, the RBT's only responsibility is delivering ABA services
- Residential staff direct BSP-interpretation questions to the BCBA โ not to the RBT during a session
- Residential staff may not ask RBTs to do personal care, medication, household, or other residential duties during a session
- In a genuine emergency, all employees act to protect individuals regardless of department
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All Behavior Department employees are mandatory reporters. Operating outside scope may result in corrective counseling or retraining, formal corrective action, BACB reporting, or termination.