Open Letter from North Carolina Behavior Analysts

Dear Members of the North Carolina Behavior Analyst Licensure Board:

We, the undersigned North Carolina Behavior Analysts, are writing to respectfully request that the Board strengthen Diversity, Equity, and Inclusion (DEI) protections within its rules and statutes, particularly in light of the Behavior Analyst Certification Board's (BACB) March 2025 announcement regarding the rolling back of their DEI requirements.

As professionals dedicated to the ethical practice of behavior analysis in North Carolina, we believe that robust DEI protections are essential to ensuring that behavior analytic services in our state remain accessible, culturally responsive, and effective for all populations we serve. Additionally, such protections help ensure that our profession attracts and retains diverse practitioners who bring valuable perspectives to our field.

Current Status and Areas for Enhancement
After a careful review of the North Carolina General Statutes for Behavior Analyst Licensure (Chapter 90, Article 43), we acknowledge the following positive elements that provide some foundation for DEIA considerations:

• The non-discriminatory criminal background review process (§ 90744(c)), which requires holistic consideration of multiple factors
• Board composition requirements (§ 90-733) that include public membership and diverse appointment sources
• Ethical conduct provisions (§ 90-742) that prohibit behaviors adjacent to discrimination

However, several critical areas remain that would benefit from enhancement:

• The absence of an explicit DEI statement or non-discrimination clause
• No requirements for cultural competency or diversity training
  Limited mechanisms to address systemic barriers to entry and advancement
• Insufficient pathways to ensure representation from diverse communities

Specific Recommendations
In response to these gaps and the BACB's concerning decision to roll back DEI requirements, we respectfully propose the following additions to the Board's rules and statutes:

1. Explicit Non-Discrimination Clause: Add language that explicitly prohibits discrimination based on race, ethnicity, gender identity, sexual orientation, disability, age, religion, and socioeconomic status in all aspects of licensure, supervision, and service delivery.
2. Cultural Competency Requirements: Establish mandatory continuing education requirements focused on cultural competency, similar to ethics requirements. We recommend requiring a minimum of 3 CEUs in cultural competency and DEI topics per renewal cycle.
3. Demographic Data Collection: Implement systems to collect and analyze demographic data of licensed behavior analysts in North Carolina to identify underrepresentation and track progress over time.
4. Accessibility Initiatives: Create provisions that address barriers to entering the field, such as scholarship programs, mentoring initiatives, or pathways that recognize diverse educational backgrounds while maintaining professional standards.
5. Code of Ethics Enhancement: Strengthen the ethical code to explicitly address cultural responsiveness in assessment, treatment planning, and implementation.
6. DEI Advisory Committee: Establish a standing committee focused on DEI initiatives within the profession that would make regular recommendations to the Board.

Benefits to North Carolina
Implementing these recommendations would:

• Ensure that behavior analytic services remain responsive to North Carolina's increasingly diverse population
• Protect clients from potential discrimination in service delivery
  Position North Carolina as a leader in ethical behavior analytic practice
• Create a more robust professional community by attracting diverse practitioners
  Improve outcomes for clients through culturally informed approaches

We understand that regulatory changes require careful consideration. Members of our professional community would welcome the opportunity to discuss these recommendations further or to participate in any working groups focused on advancing DEI within our profession's regulatory framework.

Thank you for your consideration of this important matter. We look forward to your response.