In ABA organizations, compliance failures are rarely the result of bad intentions or unethical behavior. More often, they stem from something far less visible: how the compliance function is positioned within the organization.
ABA is uniquely vulnerable to compliance risk. Revenue is tightly linked to clinical decision-making. Services are delivered through delegated models. Documentation, supervision, and billing are deeply intertwined. When compliance is underpowered, conflicted, or treated as an afterthought, risk doesn’t disappear—it simply goes undetected until a payer, regulator, or whistleblower brings it to the surface.
Positioning compliance officers for success isn’t about checking a box or naming a role. It’s about designing systems
