If You Wanted an OSAC for ABA: Why Radical Transparency Terrifies the Behaviour Analysis Industry

If ABA truly wanted public trust, it would embrace radical transparency. This piece explores why the industry resists, what real accountability would require, and why imagining it remains essential.

Introduction

Yesterday, in A Review of the “Review,” I wrote about how the ABA industry uses the aesthetics of peer review not to invite critique, but to police it—to enforce loyalty, manage reputation, and insulate itself from the truths it most needs to hear.

Today, I want to take the next step. If papers like Morris et al. (2025) show us how behaviour analysis defends itself rhetorically, then the structural question follows naturally: What would genuine accountability look like—and why is the industry so deeply resistant to it?

There is, in fact, a model for how scientific fields can confront their own failures with integrity. In forensic science, the Organisation of Scientific Area Committees (OSAC) was created to bring transparency, cross-disciplinary scrutiny, and public accountability to a field that—like ABA—had long been allowed to regulate itself. OSAC is not perfect. But it recognises a simple, radical truth: when methodologies affect lives, those impacted must have a seat at the table.

If the ABA industry genuinely wanted public trust, it would not double down on loyalty tests. It would build something like OSAC—anchored outside the provider ecosystem, governed by diverse stakeholders, open to public comment, separated from commercial interests.

It would invite real accountability.
But that would mean giving up control.

And for an industry that has been structured, from its inception, around controlling others—this is the line it will not cross.

In this piece, I will explore what an OSAC for ABA would require, why the industry as it exists could never accept it, and why imagining it anyway remains an act of necessary, radical hope.

What an OSAC for ABA Would Actually Require

If the Morris et al. paper shows how ABA uses peer review to police loyalty, the question becomes: What would real, structural accountability look like?

Forensic science faced a similar reckoning two decades ago. After high-profile scandals exposed the weaknesses of letting practitioners police themselves, the National Institute of Standards and Technology (NIST) helped create the OSAC. OSAC brought together scientists like me, statisticians, judges, defence attorneys, ethicists, and public advocates to build forensic standards out in the open, not behind closed professional doors.

If ABA were serious about ethical reform, it would need an OSAC of its own.
And it would need to meet standards like these:

Neutral, Government-Backed Anchoring

OSAC is housed within NIST—a public, neutral agency tasked with scientific integrity, not industry advancement. No single group—neither crime labs nor prosecutors—controls it.

ABA, by contrast, is entirely self-owned. Its “standards” are generated by trade associations like CASP, accreditation mills like BHCOE, and closed academic circles under the ABAI umbrella. Every major document—from ethics codes to practice guidelines—is written, reviewed, and enforced by insiders with a direct financial interest in the field’s expansion.

If ABA standards were ever to be anchored in public trust, they would have to leave behind their house-built structures. And that is not a move the industry shows any sign of making.

Balanced Stakeholder Governance

At OSAC, no single stakeholder class—whether forensic scientists, police, defence lawyers, or researchers—may dominate the committees. Structural balance is mandatory.

In ABA, governance is anything but balanced. Provider executives and behaviour analysts hold nearly every seat at BACB, BHCOE, ACQ, and CASP. Autistic adults are tokenised at best, often entirely absent. Disability-rights attorneys, medical ethicists, human-factors engineers, and payors—the very groups that should be shaping safe and equitable practices—are left outside the locked door.

In a genuine accountability framework, autistic people would not be afterthoughts or public-relations shields. They would be co-authors of the standards that govern their lives.

Public Comment and Revision Cycles

OSAC publishes draft standards for public review. Every comment is logged, every revision explained. Transparency is built into the process itself. ABA’s counterpart documents are shrouded. CASP’s 2024 Practice Guidelines require a paid membership just to download. BHCOE’s standards, even those ANSI-certified, rarely show who commented, what critiques were raised, or how revisions were made. Most ABA standards are produced behind closed doors, circulated among providers, and then presented as settled consensus.

Real accountability demands more than glossy ethics codes. It demands open records—and the willingness to show where critique reshaped the work.

Separation of Standards and Accreditation

In forensic science, OSAC writes standards, but independent bodies like ANAB handle accreditation. OSAC itself does not sell compliance certificates. Its sole job is to ensure the standards are scientifically and ethically sound.

In ABA, no such separation exists. Bodies like the Behavioural Health Centre of Excellence (BHCOE) both create the standards and sell the accreditations tied to them. A provider seeking accreditation is evaluated against criteria written by the same organisation that profits from certifying them. This closed loop creates an inherent conflict of interest: the success of the standards is measured not by public trust or outcomes, but by how many certificates can be sold.

An OSAC model would break that loop entirely. It would treat standards as a matter of public interest—not private enterprise.

Cross-Disciplinary Scrutiny

OSAC’s very existence depends on bringing statisticians, human-factors experts, legal scholars, and affected communities into the standards process. In ABA, interdisciplinary engagement is almost nonexistent. Behaviour analysts review behaviour analysts. The perspectives of trauma psychologists, developmental linguists, statisticians, and disability theorists—let alone autistic adults—are systematically excluded.

This insularity is not accidental. It is a necessary condition for maintaining an industry that cannot withstand the scrutiny it would face from the outside.

Taken together, these requirements reveal an uncomfortable truth:

An OSAC-style accountability model would be existentially threatening to ABA as it currently operates. Because it would mean ceding control—to science, to ethics, to those most impacted.

And that is a sacrifice the ABA industry, as it stands, is structurally incapable of making.

Why the ABA Industry Cannot Accept Radical Transparency

If an OSAC-style model demands open governance, interdisciplinary scrutiny, and public accountability, it raises a deeper and more uncomfortable question: why hasn’t ABA moved toward such a model? Why does it instead tighten the circle, police loyalty, and treat critique as existential threat?

The answer is not simply inertia. It is structural. Transparency would not merely threaten reputations—it would undermine the very architecture of the ABA profession itself.

At its heart, ABA is a $2 billion industry, heavily tied to insurance reimbursement. In the United States, insurance mandates treat ABA as the default intervention for autistic children. Provider companies, many of them private equity–backed, depend on maintaining the image of ABA as medically necessary, scientifically validated, and ethically sound. If genuine, independent scrutiny were to reveal systemic flaws, methodological weaknesses, or widespread harm—scrutiny not controlled by behaviour analysts themselves—the consequences would be profound. Insurance mandates could be reconsidered. Public trust could erode. Lawsuits could follow. The industry's very survival depends on managing perception. Radical transparency would rupture that control.

But the resistance to transparency is not purely financial. It is cultural. ABA was built not on collaboration or co-production, but on control. Its methods, its metrics, and its professional formation all prioritise observable compliance over internal experience. Consent, autonomy, and participatory ethics have historically been secondary concerns, if they were considered at all. A field built on externalising goals cannot easily pivot toward internalising accountability. True transparency would require listening to those once positioned as subjects, not clients; partners, not targets. For an industry so deeply invested in control—control of behaviour, control of narrative—such a shift is not merely uncomfortable. It is destabilising.

The political dimension deepens the resistance. Trade associations like CASP and ABAI are not neutral professional societies. They are political machines, lobbying at the state and federal levels to enshrine ABA’s monopoly over autism services. Empowering autistic self-advocacy, centring disability rights, or opening standards-writing to critical interdisciplinary voices would directly threaten these political alliances. The appearance of unanimity—the illusion that all legitimate voices support ABA—underpins the industry’s legislative and financial power. Shattering that illusion would risk the regulatory and funding structures that keep the industry afloat.

Finally, there is an epistemic fragility at the core of the field. ABA’s scientific legitimacy is not built on interdisciplinary engagement. It is built on self-referential citation. Behaviour analysts cite other behaviour analysts. Critical studies, trauma research, and autistic-authored work are treated, at best, as peripheral. Papers like Morris et al. (2025) reveal just how thin this scaffolding can be: a closed system reinforcing itself, mistaking loyalty for rigour, consensus for truth. A truly interdisciplinary standards body would expose how vulnerable this foundation is. It would force the field to confront questions it has long avoided—questions about harm, about trauma, about whose knowledge counts.

In other words, transparency would not just threaten reputations. It would demand a reckoning with the very structures—economic, cultural, political, and epistemic—that the ABA industry depends on for survival. And that is a reckoning the industry, as it stands, cannot survive without fundamentally transforming itself.

What Radical Transparency Would Look Like

It would be easy, after everything I have said, to assume that I am advocating for the abolition of ABA. I am not. Nor am I a defender of it. My relationship to ABA is complicated, uneasy, and deeply personal. I suffered under it—not as much as some, but enough to leave lasting marks. It was not healing. It was not joyful. It was a system that trained me to comply before I understood I had the right to say no.

Yet even with that history, I do not believe that simply tearing down systems is enough. Systems must be transformed—rebuilt in ways that centre those they have harmed, and reimagined toward equity, dignity, and repair. My time serving on the OSAC for digital / multimedia forensic science showed me that such transformations, whilst difficult, are possible. Watching a field wrestle, sometimes clumsily but genuinely, with the need for external oversight, cross-disciplinary input, and public accountability was, for my autistic and curious mind, electrifying. It made me wonder: what if ABA had the courage to do the same?

Imagine it. Imagine an Independent Standards Board for behaviour analysis, housed not within a trade association but anchored in a neutral public agency like the National Institutes of Health (NIH) or the Administration for Community Living (ACL) … if those can survive the current regime. Imagine a board where autistic adults, trauma experts, disability-rights attorneys, developmental psychologists, speech-language pathologists, and statisticians sat as full and equal partners—not token guests.

Imagine standards-writing committees where no more than fifty percent of seats could be held by credentialed behaviour analysts. Where mandatory autistic-majority advisory councils reviewed every proposed guideline. Where comment periods were not pro forma exercises hidden behind paywalls, but open, public, and meaningfully integrated into final drafts. Where every contributor was required to disclose conflicts of interest—and where conflicts were treated not as inevitable, but as critical ethical concerns to be addressed transparently.

Imagine a system where standards development was entirely separated from accreditation and enforcement. Where the body that wrote the rules did not profit from training practitioners or certifying who was compliant. Where accreditation was handled by independent quality bodies—like Underwriters Laboratories (UL) or ANAB—not by the same institutions that benefit from growth in the provider industry.

Such a system would not simply refine ABA. It would transform it into something fundamentally different: a field accountable to those it claims to serve, not just to those it employs.

This is not naïve idealism. I have seen the early, imperfect, but earnest efforts of another field to begin this work. I know the messy, halting progress of trying to open sealed rooms to public light. I also know the cost of refusing to try.

ABA, if it wishes to have any future worthy of the name, must come to terms with the same truth forensic science learned the hard way: Trust cannot be manufactured. It must be earned—through transparency, through humility, and through shared power.

Why We Must Still Imagine It

Even knowing the resistance it would face, imagining an OSAC for ABA is not a wasted exercise. It matters.

It matters because it gives us a yardstick—a way to measure how far current practices fall short, not just in outcome but in principle.

It matters because it reminds us that accountability is not a threat to science. It is the very foundation of it.

And it matters because it models a future where autistic lives are not afterthoughts to be managed or marketing slogans to be waved—but primary, structural forces shaping the standards that govern their own dignity.

Demanding transparency is not naïve. It is the necessary precondition for any future in which autistic existence is not collateral damage. And it is the standard by which any field claiming to serve autistic people must be judged.

Sidebar: How Closed Systems Self-Destruct

The OSAC was not born from a scientific epiphany. It was born from crisis.

The so-called “CSI effect” had inflated public expectations of forensic science, even as wrongful convictions exposed just how little real scientific validation underpinned many forensic methods. President Obama, recognising that “police suck at science” (to borrow the plain phrasing used in policy circles), authorised a push for independent oversight. Trade organisations that had long self-certified their own practices—much like ABA does today—fought bitterly against reform. They lost.

In medicine, it was the same. Patients demanded transparency through the OpenNotes movement after discovering that closed medical records often concealed errors, bias, and harm.

In psychology, the reproducibility crisis shattered trust in research once treated as unquestionable, revealing that insularity breeds decay.

The lesson is clear. Closed systems can delay transparency. They can punish dissenters and police loyalty. But they cannot outlast the weight of their own unreformed failures.

ABA is not immune.
It can either evolve—or be forced to.

Final thoughts …

In A Review of the “Review,” I argued that Morris et al. (2025) was not a work of scholarship, but of reputational policing—a system defending itself through loyalty tests, not inquiry.
Today’s piece extends that argument.
It shows that the problem is not just rhetorical.
It is structural.

There is no OSAC for ABA.
No independent, public, cross-disciplinary body tasked with holding the field accountable.
And that absence is not an accident.
It is the design.

The industry has built itself to resist the very forces that might make harm visible—and therefore repair possible. It governs critique by controlling peer review. It governs standards by keeping them inside the provider class. It governs its future by ensuring those most impacted have no real seat at the table.

But true accountability cannot come from loyalty.
It cannot come from obedience.
It cannot come from closed rooms filled only with those who profit from the system’s survival.

It must come from building structures that let light in.
Structures that are willing to see what harm has been done—and to change because of it.

That is what real reform would require.
That is what autistic dignity demands.

And that is the future worth fighting for—even if, today, the doors remain closed.