Comment on FR Doc # 2026-14086

Docket ID: USBC-2026-0133 North American Industry Classification System (NAICS) - Updates for 2027 I strongly support reconsideration of the request for independent NAICS classifications for Behavior Analysts and Assistant Behavior Analysts. I am a Board Certified Behavior Analyst and the Founder and CEO of a multi-location applied behavior analysis organization in Indiana. Through my role, I have seen firsthand the significant growth and evolution of the behavior analysis profession and the challenges created when our profession is classified within broader categories that do not accurately reflect the services we provide or the workforce delivering them. Behavior analysts operate under a distinct service delivery model and production process. Our work is centered on the systematic assessment of behavior, development of individualized behavior-analytic treatment, ongoing analysis of objective data, protocol modification, and clinical oversight of treatment implementation. Assistant behavior analysts also occupy a distinct role within this service model and workforce structure. These activities are materially different from traditional mental health counseling, psychology, education, and other healthcare services under which behavior analysts may currently be inconsistently classified. As an employer of behavior analysts and the leader of an organization providing services across center, school, home, and community settings, I have seen the practical consequences of the absence of a clear classification. Behavior analysis organizations and professionals are inconsistently categorized across systems, making it difficult to accurately identify and measure our workforce, evaluate industry growth, analyze employment trends, and understand the economic impact of the profession. At the organizational level, I employ behavior analysts alongside occupational therapists and speech-language pathologists. Occupational therapy and speech-language pathology professionals are readily identifiable within established occupational and workforce classifications, while behavior analysts remain inconsistently absorbed into broader categories. This makes our behavior-analytic workforce comparatively difficult to identify, measure, and plan for despite representing a distinct clinical discipline with its own professional standards, credentialing structure, and service delivery model. This lack of consistent classification is particularly concerning as demand for behavior-analytic services continues to grow and organizations, policymakers, and workforce systems attempt to understand provider capacity and workforce shortages. Independent NAICS classifications for Behavior Analysts and Assistant Behavior Analysts would provide greater statistical accuracy and better reflect the distinct production processes, professional workforce, and economic activity of behavior analysis. I respectfully encourage the ECPC and OMB to reconsider and include independent classifications for Behavior Analysts and Assistant Behavior Analysts in the 2027 NAICS revision. Thank you for considering the operational perspective of community-based ABA providers. Kristie Koch, MA, BCBA, LBA Founder & CEO School-Based Behavior Consultation