On the last Monday of April, Lorri Unumb opened the tenth-anniversary conference of the Council of Autism Service Providers in a ballroom at the Mandalay Bay Resort & Casino in Las Vegas. She moved through a presentation on the state of the trade association: 22 full-time employees, a $4.4 million budget, more than 450 member organizations, an accreditation arm now required by a growing list of state Medicaid programs and commercial payers, and a second accreditation body acquired in late December.
Three weeks earlier, on April 6, Kirstin Hall, a board-certified behavior analyst with twenty-three years in the field who runs a private practice in San Diego, had sent formal letters to two of the three professional bodies that govern applied behavior analysis (ABA): the Behavior Analyst Certification Board, which credentials practitioners, and the Association for Behavior Analysis International, which holds the field’s science. A third letter, addressed to the Association of Professional Behavior Analysts, was drafted and published on the project’s website but, Hall said, has not been sent directly to APBA; she has held it pending what she described as APBA’s entanglement with CASP through a co-publication arrangement. The letters and the position statement, written under the banner of a project Hall named the ABA Accountability Project and posted to a public website, asked each body the same question in different forms: who authorized CASP, a 501(c)(6) trade association governed by operators of its own member organizations, to position itself as the authoritative voice of the field, and what role those bodies intended to play in answering for it.
The position statement underlying the letters had been posted to the project’s website in March; Hall told Acuity she has since added additional documentation to the site, including, she said, what she described as input from a clinician with direct standing inside ACQ’s governance structure who has raised concerns about its standards-development process. Acuity has not independently verified the clinician’s identity or standing. As of this writing, none of the three professional bodies has publicly responded to the letters or the statement.
The questions they raise have circulated within the field anyway. Indeed, Unumb had not only read the statement, but was well aware of its contents when she sat down to talk with Acuity Media Network at the CASP conference shortly before lunch.
Ryan’s Law and the path to CASP
Unumb has run CASP since May 2019, when she left a decade-long post as Vice President of State Government Affairs at Autism Speaks. She is a lawyer by training. She began her career as an appellate attorney at the U.S. Department of Justice, then served as a law professor at George Washington University and the Charleston School of Law. Later, she ran advocacy training at the U.S. Department of Justice’s National Advocacy Center and, in the same period, hosted a weekly cable show called The Law with Professor Lorri.
Unumb’s journey in ABA began when her oldest son, Ryan, was diagnosed with autism shortly before his second birthday. The Unumbs were living in Washington, both working as DOJ lawyers. The specialists they consulted told them Ryan needed an intensive ABA program immediately. Insurance, they discovered, would not pay one penny.
The Unumbs sold the house, downsized, moved back to South Carolina to be near family, and lived on Dan Unumb’s salary while Lorri’s went to therapy. In 2005, at her kitchen table in Lexington, she drafted legislation requiring health plans to cover medically necessary autism treatments, including ABA, when prescribed by a physician. After two years of lobbying, the law was passed in 2007. It is known in the autism community as Ryan’s Law. Some version of it now exists in all 50 states, and Unumb is generally credited with the national insurance-reform movement that produced them. She has said publicly that her real frustration during those early years was sitting in support groups and being reluctant to talk about how much ABA was helping her son, because the parents around the table could not afford it.
In 2010, she and Dan founded a nonprofit ABA clinic in South Carolina to serve Ryan and other children whose families needed somewhere to send them. (Renamed the Unumb Center for Neurodevelopment in 2019, it has narrowed its offerings since its larger early years and currently serves 16 children and 8 adults per year.) She founded an annual gathering called the Autism Law Summit, now in its nineteenth year, co-authored the first comprehensive law-school textbook on autism legal issues, and was appointed by South Carolina’s governor to the state commission overseeing several Medicaid waivers. Ryan, who is now 25, remains profoundly impaired, and Unumb described his life and theirs as “changed dramatically” by ABA. He grew up alongside the legislation she wrote and the organizations she built around it.
When CASP’s founders, a group of provider-organization operators who had been meeting informally at autism conferences for years before incorporating their own gathering, decided in 2019 to hire a full-time CEO with policy and legal experience to grow the organization, they brought on Unumb.
What CASP has built
CASP has grown substantially under Unumb’s tenure. When she arrived in 2019, the trade association had a single full-time employee. It now has twenty-two and is hiring more (the Autism Commission on Quality, its accreditation subsidiary, gained a new client services manager the day of the welcome remarks; several more reviewers, Unumb told the room, are coming on this spring). CASP’s organizational membership has grown from 78 provider organizations to more than 450. The composition of that membership has flipped: when CASP incorporated, roughly three-quarters of members were nonprofits and one-quarter were for-profits; today roughly four-fifths are for-profits, a shift Unumb attributes to the growth of the field (the entry of more for-profit operators as the addressable autism services market has expanded) rather than to any active effort by CASP to recruit for-profit members.
In 2020, the Behavior Analyst Certification Board transferred its ABA Practice Guidelines to CASP, which now serves as the field’s clinical reference. (Unumb says the BACB transferred the guidelines because it is a certification body and “really was not an appropriate function for a certification body” to maintain practice standards.) In a separate and unrelated step, CASP launched its accreditation arm, the Autism Commission on Quality, in 2022; ACQ developed and uses its own accreditation standards through its own Standards committee, distinct from the BACB-transferred Practice Guidelines. In 2024, CASP released version 3.0 of the practice guidelines. In December 2025, it acquired Jade Health, the organization behind the Behavioral Health Center of Excellence (BHCOE) accreditation program, a competitor founded in 2015 by BCBA Sara Gershfeld that had issued hundreds of accreditations to ABA organizations across the country. The two accreditation frameworks are now on a path to consolidation under the ACQ name. Massachusetts, the first state to require accreditation for autism therapy providers, began phasing in the requirement under MassHealth in January 2025, with clinic-based providers expected to be accredited by 2027. Indiana, in a March 26, 2026 bulletin issued in the wake of a March 10 Wall Street Journal investigation that documented egregious billing patterns in the state’s ABA program, made accreditation by an ACQ- or BHCOE-recognized body a condition of Medicaid participation by October 1, 2027 (with existing providers required to begin the process by August 1, 2026). Several commercial payers have followed.
The position statement on Hall’s website does not dispute these accomplishments. What it disputes is the structure underneath them. CASP’s own published mission, on its website, describes the association as existing “to support its members by cultivating, sharing, and advocating for provider best practices in autism services.” Hall reads the same trade-association structure differently: a 501(c)(6) entity is, by its IRS classification, “legally obligated to advancing the business interests” of its members, and CASP’s members are predominantly for-profit provider organizations, some backed by private equity. The two framings (501(c)(6) tax classification as a structural constraint, mission statement as a stated purpose) are not contradictory, and CASP and Hall point readers to different lenses for evaluating what the association actually does. What follows in this article is each of Hall’s three structural arguments in turn, with the public record and Unumb’s responses laid out alongside them.
The board: who governs CASP
Hall has worked in autism services for twenty-three years. She holds the BCBA credential issued by the Behavior Analyst Certification Board and the International Behavior Analyst (IBA) designation. She has served on clinical advisory boards that include provider, family, and payer representatives, including for Redwood Coast Regional Center and Elevatus Training: experiences she has cited as informing her view of how multi-stakeholder governance can be structured. She and her husband, Aaron, run a small private practice in San Diego, where Hall is a native, that they have grown organically over the years.
Hall’s position statement characterizes CASP’s board as composed entirely of “executives of large, multi-state provider companies,” whose organizations directly benefit from the standards the board sets, the accreditation criteria it establishes, and the policies it lobbies for. The structural question her statement raises is whether a board so constituted can credibly separate clinical standards from the business interests of the operators making the decisions.
Unumb read the characterization aloud from her marked-up printout and called it “provably patently false.” She went through the directors one by one. Julie Adcock runs a small organization in Tennessee. Steve Muller runs a nonprofit in Iowa. Brian McCann, the board’s former Chair, runs a nonprofit in Virginia, only in Virginia. (He had notified her earlier this year, she said, that he was stepping down after nine years on the CASP board.) Of the thirteen directors, only one, she said, runs an organization that is private-equity-backed. “I welcome constructive feedback always from anyone in the field,” Unumb said. The annotations were extensive; she suspected, she said, that “maybe AI generated a lot of this.” (Hall, told of the characterization, said the position statement’s claims are sourced from CASP’s own public materials, the Form 990, and CASP leadership’s own public statements, and that the research had been “directed, synthesized, and published” by her over twenty-three years in the field.)
The public record supports parts of Unumb’s response and complicates others. Several board members do run large organizations, even if single-state: the Faison Center in Virginia (chaired by board Chair Brian McCann) reports roughly $20 million in revenue and around 400 employees; Balance Autism in Iowa (Steve Muller) reports roughly $24 million in revenue and several hundred employees. Other board members run substantially smaller organizations, including Julie Adcock’s Kaleidoscope Behavior Analysis & Therapy in Tennessee. The accurate characterization is that the board includes operators of both large single-state nonprofits and small clinics; the “multi-state” qualifier in the position statement does not consistently apply, and the “private-equity-backed” characterization applies to one director. CASP staff and members interviewed for this article also noted that even directors and members technically classified as “executives” are, in practice, often owner-operators who run small organizations and themselves cover scheduling, billing, supply runs, and direct clinical sessions.
In short, two of the three descriptors Hall’s statement uses (“multi-state” and “private-equity-backed”) do not consistently hold. That said, the underlying structural question Hall is asking—whether a board composed entirely of operators of member organizations, regardless of those organizations’ scale or funding source, is the right governance structure for the body now stewarding the field’s clinical guidelines and accreditation—is a matter of personal opinion.
The accreditor: who owns ACQ, and what it costs
Hall’s second structural argument concerns CASP’s relationship to ACQ. The accreditation body affiliated with CASP is structured as a single-member LLC, with CASP as the sole member; per the legal Operating Agreement, ACQ’s accreditation activities, including all standards development, are managed by ACQ’s own Standards, Accreditation, and Appeals Committees. The Form 990 CASP filed in September 2025 for fiscal year 2024 is publicly available through ProPublica’s Nonprofit Explorer and reports total revenue of $2,593,034 and total compensation for Unumb of $266,054 ($219,663 in base pay plus $46,391 in other compensation). The same filing notes that CASP “reported conflict of interest transactions” on Schedule L. Hall’s position statement, which cites the Form 990 throughout, describes the disclosed Schedule L item as a $16,550 payment to an organization run by Unumb’s spouse for rent and services; that specific characterization is Hall’s, drawn from her reading of the public filing. The position statement also references a national median behavior-analyst salary of approximately $89,000, presenting it as context for what Hall frames as a resource-distribution question across the field (the comparison is included here because it appears in the position statement and figures in Hall’s argument, not as the article’s own framing). The 990 also breaks out $178,317 in accreditation-fee revenue for the year, attributable to ACQ; Hall’s statement describes the subsidiary as carrying negative net assets of roughly $636,000 and unable, on its own, to cover its costs.
Unumb does not contest the financials. Hall’s statement quotes Unumb as having said publicly that ACQ “wouldn’t have been able to make ends meet” without CASP’s direct support. Asked about the line, Unumb said she did not contest it and pointed out that accreditation bodies, like other start-ups, cannot generate revenue before they have operated long enough to develop standards, build processes, and accredit organizations; some outside funding source is required to launch one. At the CASP conference, addressing the recent state-level accreditation mandates, Unumb said the mandates were “actually not something that we affirmatively lobbied for,” but added that “if a state does want a third-party check on the quality of the provider, we’re here and we’re willing to step up and fill that bill.” When the Wall Street Journal published its investigation in March documenting egregious billing patterns in several state ABA Medicaid programs, CASP responded with a statement saying that “fraud, waste, and abuse occur in ABA,” and offered to help states bring more rigor to their Medicaid programs.
The position statement explicitly draws an analogy to the Joint Commission, which is independent of any provider trade group. The analogy applies more cleanly at the level of corporate ownership than at the level of who conducts the actual reviews: both Joint Commission and CARF, the other major accreditor in adjacent spaces, rely on peer surveyors who are themselves employed by accredited provider organizations, including organizations that compete with the entities they review. What the statement is invoking is governance independence at the entity level, not reviewer independence at the survey level.
The broader framing that no comparable healthcare profession allows the trade association of providers to also own the accreditation body is, on examination, contested. Accreditation bodies in U.S. healthcare have historically formed in close affiliation with provider and professional membership organizations. The Accreditation Association for Ambulatory Health Care, founded in 1979, was sponsored by physician trade groups including the American Academy of Family Physicians, the American College of Obstetricians and Gynecologists, the American Society of Anesthesiologists, and others, and today accredits more than 6,800 ambulatory healthcare organizations. The Commission on Cancer, established in 1922, is structured explicitly as a program of the American College of Surgeons; nearly 1,500 hospitals are CoC-accredited, treating roughly 70 percent of newly diagnosed cancer patients in the United States. The Electronic Healthcare Network Accreditation Commission, founded in 1993, is itself organized as a 501(c)(6) accrediting body representing a self-described “diverse mix of healthcare stakeholders” across the industry. The Commission on Accreditation of Rehabilitation Facilities (CARF), the major behavioral-health accreditor adjacent to ABA, was likewise founded by provider associations. In the broader literature on trade associations and self-regulation, this affiliation pattern is described as the norm rather than the exception. The Certification and Accreditation Law Handbook, a reference text in the credentialing field, treats accreditation as “a mode of self-regulation” through which professions and industries establish quality standards in the public interest, and notes that separate incorporation between accreditor and affiliated membership body is typically not legally required, provided functional autonomy is maintained in substantive accreditation decisions. The handbook and the broader self-regulation literature, including a recent Houston Law Review article on self-regulation in emerging and innovative industries, further observe that periods of rapid consolidation and market growth are often the moments when professions strengthen, rather than abandon, their accreditation and quality-oversight mechanisms, precisely because outside capital and rapid scaling raise the salience of standardized expectations.
Between 2017 and 2022, the position statement notes, citing widely circulated industry data, private equity completed roughly 85 percent of all M&A in autism services. What this context does not resolve is whether the governance safeguards CASP has built around ACQ (separate-entity LLC structure; separate Standards, Accreditation, and Appeals Committees; conflict-of-interest policies; independent review processes) are sufficient given the specific conditions of ABA: a young field, rapidly consolidating outside capital, accreditation now becoming a precondition of payment, and a trade association whose member organizations are among the ones being accredited. Hall’s sharper argument, on examination, is less that the affiliated-accreditor model is unprecedented (it isn’t) and more that the field has not built the independent counterweights other professions built alongside their affiliated accreditors during their own consolidation moments.
In short, Hall is not arguing that CASP should not exist. She is arguing that the consolidation of practice-guideline authorship and accreditation under a single trade association, against the backdrop of accelerating outside capital, is a structure for which the field has not yet built independent counterweights.
The RBT credential: what CASP advocates for, and what it doesn’t
Hall’s third argument is the one she calls the credentialing double standard. The Registered Behavior Technician credential is the BACB’s frontline certification for practitioners who deliver the majority of direct ABA service hours, and it requires 40 hours of training, a competency assessment, and ongoing supervision. CASP stewards and monetizes the BACB-transferred ABA Practice Guidelines, which derive their authority in part from the credentialing rigor of the BACB. Yet on its own advocacy page, Hall’s statement notes, CASP identifies mandatory RBT enrollment requirements as a policy barrier it has worked to defeat at the state level.
The two sides cite different documented episodes. CASP’s own advocacy page lists Indiana Medicaid’s “high risk provider enrollment requirements, including RBTs, by April 1, 2025,” as a state policy CASP’s Indiana State Advocacy Group worked to defeat; the position statement points to this documented episode. Asked about the issue, Unumb described a separate episode involving a commercial payer (one she thought was UnitedHealthcare, though she was not certain) that had proposed requiring RBT certification on a timeline she recalled as roughly thirty days; she said CASP’s members asked the association to push back on the timeline, not the requirement. “I’m hugely in favor of RBT,” she said. Hall, after reviewing CASP’s advocacy page, characterized the Indiana Medicaid episode and the commercial-payer episode as separate, documented instances of CASP advocacy that the position statement reads as a pattern; she withdrew a parallel Tennessee characterization that, on her own re-reading of CASP’s advocacy page, addressed medical necessity definitions rather than RBT enrollment.
What this leaves is two episodes that look different depending on who reads CASP’s advocacy page. To Hall, they are evidence of a pattern in which CASP’s lobbying preserves billing flexibility for organizations that depend on uncredentialed or partially credentialed labor. To Unumb, they are members responding to specific, badly timed payer demands, not opposition to the underlying credential. The advocacy page is public; readers can examine it themselves.
The representation question
Hall’s own practice, by her own account, has fewer than ten employees and has never approached $5 million in annual revenue. “We’ve never seen 5 million,” she said over a video call. “Nowhere close, you know, in 10 years.” CASP’s lowest dues tier is for organizations with under $5 million in annual revenue, and by Unumb’s own slide deck includes the majority of CASP’s 450 member organizations, with members reporting revenue as low as under $1 million; 288 of the 450 fall in that tier. Hall’s argument is not that her practice is ineligible to join, but that even the lowest tier is, in her phrase, “outrageous” for a practice her size, and that a seat at the table, at the dues she could afford, would not translate to influence on a board whose members run substantially larger organizations. She has had offers to be acquired and turned them down. Agencies at her scale, she argued, account for roughly 70 percent of the field by practitioner count and are almost entirely outside CASP’s membership.
How CASP got here
On the governance question, Unumb did not contest the basic facts the statement marshals, though she clarified some specifics. The history Unumb describes, and that the CASP website confirms, runs as follows: in 2009, leaders from ten provider agencies convened in Las Vegas at what became the inaugural Council on Autism Services (CAS) conference, an annual gathering, not yet a trade association. The trade association itself was incorporated separately at the end of 2015, when a partially overlapping cohort of provider operators (only three individuals bridged both groups, according to Unumb’s and other founders’ accounts) decided to formalize a real association. Several of the 2015 incorporators ran nonprofit and school-based programs that took little or no insurance reimbursement (Eden II Programs, Melmark, the New England Center for Children, and others), a fact that complicates the position statement’s framing of the founding cohort as a homogeneous bloc of large multi-state providers. The 2015 founders, Unumb said, “kicked in money from their own organizations” to make incorporation possible. She also acknowledged that the Behavior Analyst Certification Board transferred its ABA Practice Guidelines to CASP in 2020 because, she said, the BACB was “the certification body” and maintaining practice standards “really was not an appropriate function for a certification body.” CASP, she said, “had the bandwidth” to take it on. “It was very pure in its founding,” Lorri told Acuity Media Network.
“Whatever your corporate back end looks like”
Asked about her members’ size and funding mix (small for-profits, large for-profits, nonprofits, the one private-equity-backed organization on her board), Unumb returned, as she did several times in the conversation, to a stated agnosticism: “I like to try to be agnostic as to what you look like, what your funding source is. All I really care is, are you providing quality services to kids with autism, or to people with autism across the lifespan?”
“It didn’t matter to me what your corporate back end looks like,” she went on. “What matters to me is whether you are delivering services in compliance with the generally accepted standards of care (which, right now, are the CASP practice guidelines)? And if you are, however you get there, I don’t care. And if you make a little money on the way to getting there, I don’t care, as long as you’re delivering quality services.”
The same statement, depending on the reader, lands in two different places. To Unumb and CASP’s membership, it is an indifference to corporate form: the position that what matters is the quality of services delivered, not the financial structure of the organization delivering them. To Hall and the position statement, it is, in effect, a description of why a 501(c)(6) board built almost entirely of provider-organization operators is structurally limited in its ability to separate clinical standards from business interests, since the entity’s legal purpose is to advance the business interests of its members. Unumb did not appear to find these readings in tension. The field needs standards, she said in different formulations across the conversation, the standards need stewards, and CASP, in her view, has been willing to do that work.
On the matter of Hall, Unumb said she had reached out in early May, sending Hall a message via Facebook Messenger, which, to her knowledge, was the only channel the two of them had ever used to communicate.
“If she’s willing to talk,” Unumb said, “I’m more than happy to hear suggestions for what we can do to make sure that everybody feels welcome at CASP.”
Hall said she had not, as of her interview with Acuity (in late April), heard from CASP or its leadership beyond a single board member who emailed her and her husband to point out factual errors on the project’s website; when she asked which errors specifically, the board member did not reply. Other practitioners in the field, she said, had reached out to thank her for launching the project and to say they had wanted to do something similar themselves. She said she would take Unumb’s call but added that the project reflects a coalition of practitioners’ concerns, not just her own, and that what the field needs is for CASP to respond publicly to the documented structural concerns rather than to extend an invitation to one author.
By CASP’s post-event count, roughly 1,300 people attended in person; in-person registration had sold out before the event. Unumb was scheduled to host a panel: four autism parents, including herself, discussing the role of ABA professionals in family life.
The 25-year-old at home is, in Unumb’s account of her own work, the through-line. “I just,” she said near the end of lunch, before continuing, “the whole reason I took this job is to make sure that parents tomorrow will be able to find good quality providers to help their children.”
The position statement and the letters, meanwhile, continued to circulate, on chat threads and in private conversations and (for the BACB and ABAI letters) in the inboxes of the two professional bodies they had been sent to. The professional bodies have not publicly responded. The practice guidelines the BACB used to own are now CASP’s. The accreditation programs that the professional bodies did not build are now consolidating under a single trade association, whose member organizations are increasingly required to be accredited by an ACQ- or BHCOE-recognized body. Whether CASP’s structure serves the field at this scale and what its three professional bodies plan to say about it remain open questions. In the meantime, the trade association at the center of the questions continues to grow.
