You do not have a
compliance officer.
Every hospital has one. Every payer has one. Your practice has a BCBA reading a statute at eleven at night, hoping. When an auditor, a payer, or a buyer finally tests your structure, that is who is defending it.
Three ways in.
Defense on every front.
Three counterparties will test your structure. Nobody in your building has the job of being ready for them.
Every rule a compliance officer would need to know, in the open.
Six pillars of state by state compliance analysis, sourced to primary law and published free. Entity structure, ownership, licensing, credentialing, facility and HIPAA, Medicaid and insurance. Not summaries of summaries. The statutes themselves, cited, so you can check the work.
Read the knowledge baseFourteen states open
In most states, applied behavior analysis is not reached by corporate practice doctrine. If that is you, the honest answer is that you have no structural problem.
Two states amber
The District of Columbia and Pennsylvania warrant caution. The exposure is real but it is not a bar.
One state a mandate
Illinois. Licensed ownership required, with a divestment deadline of January 15, 2027. If you own a clinic there and you are not a licensee, that is not a rules problem. That is your equity.
Three places it breaks
Compliance is not a legal function. It is an operational one. It fails in three places, and it usually fails in more than one at a time.
Operational integrity
Can you prove you delivered the services you billed for? Not assert it. Prove it, from the record, on the day someone asks.
Clinical integrity
Do your clinical records support the services you billed? This is the gap between good practice and provable practice, and it is where audits land.
Structural integrity
Is the entity itself sound? Ownership, licensure, corporate practice doctrine, fee splitting. The one that stays invisible until a buyer or a regulator looks, and then costs the most.
The developments we are tracking
Live regulatory, payer, and enforcement threads, each read to primary law and dated as it moves.
The attorneys are on record
The ABA Compliance and Legal Series: conversations with healthcare attorneys from Goodwin, Garfunkel Wild, and Bochner.
HIPAA Risk Trends for ABA Providers, with Roger Cohen, Goodwin
Watch on YouTubeOperating ABA Clinics for Payment Scrutiny, with Steve Antico, Garfunkel Wild
Watch on YouTubeEntity Structuring in ABA, with Matthew Shatzkes, Bochner
Watch on YouTube
Compliance Is a System
How ABA clinics really control risk, revenue, and survival. The thinking the whole ABAWiser system is built on.
About the bookFind out what is actually exposed.
Start with the assessment. Or talk to us for thirty minutes and describe the situation. Either way you will know where you stand.