Over the past several months, there has been a lot of discussion about oversight in applied behavior analysis (ABA) in Nebraska. One argument I continue to hear is that existing licensure already provides sufficient protection and accountability.
On the surface, that sounds reassuring. If someone is licensed, families assume safeguards are in place. Clinicians assume standards are being upheld.
But that assumption deserves a closer look.
I reviewed the full list of Licensed Behavior Analysts (LBAs) directly from Nebraska’s state licensing database. There are currently 780 LBAs licensed in Nebraska.
Of those 780 license holders, only 347 list a Nebraska address.
That means less than half — approximately 44 percent — have any in-state address on file.
Even that figure overstates meaningful physical presence. Among the 347 Nebraska addresses, 12 licenses share the exact same address. That strongly suggests centralized administrative offices rather than distributed clinical supervision across the state.
In practical terms, a substantial portion of the licensed workforce overseeing ABA services in Nebraska is either physically out of state or concentrated in a small number of locations.
Licensure alone does not guarantee proximity.
And in ABA, proximity matters.
When a child receives 30 or 40 hours of therapy each week, supervision cannot be a paperwork function. It requires direct observation of sessions, in-person coaching of technicians, collaboration with caregivers, and the ability to intervene quickly when clinical issues arise. High-intensity services involve vulnerable children and complex programming. Oversight must be real, not theoretical.
When the supervising clinician is not physically present in the state, accountability becomes harder to verify and easier to dilute.
This is not an argument against telehealth where it makes sense. Remote consultation has a role in healthcare. The issue is alignment. If a clinician is responsible for supervising intensive, in-person medical treatment delivered to Nebraska children, there should be meaningful accountability inside Nebraska.
Otherwise, enforcement weakens. Quality assurance becomes reactive instead of preventative. And families assume protections exist that, structurally, may not be as strong as they appear.
Before we debate whether additional guardrails are “burdensome,” we should first be clear about what current oversight actually looks like in practice.
The data is publicly available. Anyone can review it.
This is not about limiting access or excluding qualified professionals. It is about alignment. If someone is responsible for supervising intensive, in-person medical treatment delivered to Nebraska children, there should be meaningful accountability here.
Families deserve to know what structures are actually in place — not what we assume are in place.
And clarity should not make anyone uncomfortable if the system is working as intended.
