A Call to Action During Oregon’s BCBA Presses Board to Reform RBAI Licensing

Taking Her Case to the Board

Christina Williams, a BCBA practicing in Oregon, plans to spend part of this Friday morning asking a state board to rewrite how Oregon trains its newest behavior analysts.

Williams will speak during the quarterly public meeting of the Oregon Behavior Analysis Regulatory Board. This Oregon Health Authority body licenses the state’s behavior analysts, and she has submitted an open letter outlining five regulatory changes she wants it to consider. The meeting is open to the public and begins at 9 a.m.

“Behavior analysis is at a turning point,” Williams wrote in the letter, which she also posted on LinkedIn. “We are facing justified scrutiny from families, funders, providers, and the public.”

What Williams Is Asking For

Her proposals center on the Registered Behavior Analysis Interventionist (RBAI) certification, the entry tier of Oregon’s behavior analysis workforce. Williams wants the board to raise the standard for initial RBAI training by requiring hands-on clinical experience and to review the approved RBAI training curricula to ensure they reflect evidence-based behavior analysis.

She is also asking the board to create two new license tiers. One is an Interim RBAI license, meant to bridge the gap between competency and full licensure. The other is a Student Analyst license, with a defined scope of practice and set supervision requirements.

Her fifth proposal is structural. Williams wants the board to align accountability with authority, so that responsibility rests with the people and organizations that actually control compliance.

“The Board needs to hear from more than one voice.” – Christina Williams, BCBA (2026)

Where RBAIs Fit in Oregon

Oregon regulates its behavior analysts through the board with statutory authority. The RBAI sits at the bottom of a tiered structure that also includes the Assistant Behavior Analyst and, at the top, the Licensed Behavior Analyst.

The tiers carry different billing rights. Under the state Medicaid rule, a Licensed Behavior Analyst can be paid directly by the Oregon Health Plan. At the same time, Assistant Behavior Analysts and RBAIs are not eligible for direct payment. That leaves the RBAI as a supervised, entry-level role, the same tier that Williams’ training, curriculum, and interim-license proposals would change.

How to Weigh In

Williams framed the meeting as a chance for the field to weigh in. She is urging Oregon BCBAs, RBAIs, graduate students, employers, educators, and family members to review the current rules, attend board meetings, and submit public comment, even if they disagree with her.

“Our regulations should evolve alongside our profession and those regulations are shaped by the people who choose to participate in the process,” she wrote. “You don’t have to agree with my recommendations. In fact, I hope you’ll challenge them, improve them, or propose better solutions.”

There is no formal rulemaking docket to comment on yet. The board’s laws-and-rules page listed no open rulemaking activity as of July 7, 2026; the current rules are set forth in OAR Chapter 824, and the Health Licensing Office routes rule questions to policy analyst Anne Thompson. Friday’s public comment would come ahead of any formal proposal, not on one already filed.

The board convenes Friday at 9 a.m. Whether it takes up any of Williams’ five proposals will depend first on who else shows up.

AT A GLANCE

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