Arizona Association for Behavior Analysis Sunrise Report - Proposed Transition of the Existing Licensure and Regulation of Behavior Analysts - October 19, 2023

Sep 20, 2026

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Sunrise Report submitted by the Arizona Association for Behavior Analysis seeks statutory change to modernize how behavior analysts are licensed and regulated in Arizona. The report argues that behavior analysts, regulated by psychologists under the Arizona Board of Psychologist Examiners since 2008, have grown to a critical mass and should be able to self-regulate through an independent licensing board. The proposal aims to reduce regulatory burden by eliminating unnecessary steps, reconfiguring an existing committee into a board, and co-locating within the existing governmental unit to share administrative overhead, without changing the current scope of practice.

LanguageEnglish

CategoryResearch & Report

FormatPDF

Pages9

Reading Time23 min

AccessFree to download

Background

Current Licensing Framework in Arizona

HB 2470 and the Historical Development of Regulatory Oversight

Committee on Behavior Analysts as a Transitional Solution

Additional Processing Steps and Current Ratification Requirements

October 19, 2023 The Honorable Warren Petersen The Honorable Ben Toma Arizona Legislature 1700 West Washington Phoenix, AZ 85007 RE: Sunrise Application for the Proposed Transition of the Existing Licensure and Regulation of Behavior Analysts from the Arizona Board of Psychologist Examiners to an Independent Licensing Board for Behavior Analysts to Be Co-Located Within the Arizona Board of Psychologist Examiners Dear President Petersen and Speaker Toma: Out of an abundance of caution, on behalf of the Arizona Association for Behavior Analysis, this Sunrise Application is being submitted in support of the proposed modernization of the existing statutes governing the licensing and regulation of the behavior analysis profession in Arizona. As you may be aware, behavior analysts have been licensed in Arizona since 2008, under the regulation of the Arizona Board of Psychologist Examiners. Unlike most other health professions in Arizona, behavior analysts are regulated by psychologists, a separate and distinct profession from behavior analysis, with different academic and professional experiences, ethical codes and standards of practice. As the behavior analysis profession has increased to 920 licensees in Arizona, the Arizona Association for Behavior Analysis believes it has reached a critical mass in the profession to be granted the statutory ability to self-regulate, as opposed to the current system of oversight by the well-meaning, but otherwise unrelated profession of psychology. The legislation ultimately anticipated under this Sunrise Application is intended to reduce the footprint of regulation by eliminating unnecessary steps in the licensing and regulation of the behavior analysis profession. In addition, the legislation has been specifically designed to avoid the expansion of state government by reconfiguring an existing committee into a board as well as being co-located within an existing governmental unit in order to share administrative overhead. Moreover, the proposed legislation makes no changes to the scope of practice currently in place for the behavior analysis profession in Arizona. Accordingly, as expressed above, the attached Sunrise Application is being submitted out of the abundance of caution in order to meet any procedural challenges during the legislative discussion. Thank you, in advance, for your consideration. Sincerely, Kyle K. Lininger, Licensed Behavior Analyst President Arizona Association of Behavior Analysis SUNRISE REPORT PROPOSED TRANSITION OF THE EXISTING LICENSURE AND REGULATION OF BEHAVIOR ANALYSTS FROM THE ARIZONA BOARD OF PSYCHOLOGIST EXAMINERS TO AN INDEPENDENT LICENSING BOARD FOR BEHAVIOR ANALYSTS TO BE CO-LOCATED WITHIN THE ARIZONA BOARD OF PSYCHOLOGIST EXAMINERS Submitted by: ARIZONA ASSOCIATION FOR BEHAVIOR ANALYSIS October 19, 2023 Arizona Association for Behavior Analysis Sunrise Report Background The Arizona Association for Behavior Analysis (AzABA) is seeking a statutory change to update the regulatory framework in how behavior analysts are currently licensed and regulated in Arizona. Under current statute (originally enacted in 2008), behavior analysts are licensed and regulated by the Arizona Board of Psychologist Examiners. Unlike most other health professions in Arizona, behavior analysts are regulated by a separate and distinct profession from behavior analysis with different academic and professional experiences, ethical codes and standards of practice. From a historical perspective, in 2008, the Legislature enacted HB 2470 that created the Arizona Board of Behavior Analysts, an independent self-supporting regulatory board. HB 2470 passed with bipartisan votes of 36-23 and 18-7, respectively in the House and Senate. While the Final Read vote in the House was 32-18, seven of the 10 members not present for the vote had previously supported the bill on Third Reading. Governor Napolitano vetoed the legislation due to concerns about

FAQs

What change does AzABA request in the Sunrise Application?

AzABA requests a statutory change to transition behavior analysts’ licensure and regulation from the Arizona Board of Psychologist Examiners to an independent licensing board co-located within that board.

Why does the report argue behavior analysts should move toward self-regulation?

The report states that the profession has grown to a critical mass and that self-regulation would replace oversight by psychology, which is described as distinct from behavior analysis with different ethical codes and standards of practice.

Does the proposed legislation change the scope of practice for behavior analysts?

No. The report explicitly states that the proposed legislation makes no changes to the scope of practice currently in place for the behavior analysis profession in Arizona.

Sep 20, 2026

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