Comment on FR Doc # 2026-14086
Heather KendrickSupportIndividual
Summary: Heather Kendrick, a Board Certified Behavior Analyst, supports the creation of a new, independent NAICS classification (621350) for Offices of Behavior Analysts. She argues that the current classification under mental health practitioners is inaccurate and that a dedicated code is necessary to properly track the economic data and growth of the Applied Behavior Analysis (ABA) field.
Docket ID: USBC-2026-0133
Title: Comment on the North American Industry Classification System (NAICS) — Updates for 2027
To Whom It May Concern,
I am writing as a Board Certified Behavior Analyst (BCBA) licensed in the state of Arizona to strongly support the creation of a new, independent NAICS classification: 621350 Offices of Behavior Analysts and Assistant Behavior Analysts.
Currently, behavior analysts are grouped under NAICS 621330 (Offices of Mental Health Practitioners). While we collaborate closely with other mental health professionals, Applied Behavior Analysis (ABA) is a distinct and independent discipline. It operates under unique regulatory frameworks, state licensure requirements, independent credentialing boards, and specialized billing codes (Adaptive Behavior Services). Grouping our clinics and practices into a generic mental health category limits the accuracy of federal economic data. Without a dedicated NAICS code, it is impossible for policymakers, state agencies, and healthcare researchers to accurately track the establishment numbers, payroll, employment trends, and economic contributions of this rapidly expanding healthcare sector.
As a practitioner servicing Phoenix and the surrounding areas over the last 3 years, I see firsthand the demand for behavior-analytic services. In Arizona and across the nation, our field is experiencing unprecedented growth to meet the needs of individuals with autism and other developmental disabilities. Reliable, independent data is critical for benchmarking, tracking workforce trends, and making informed decisions that impact patient care and business operations.
For these reasons, I respectfully request that the Office of Management and Budget approve the inclusion of NAICS code 621350 in the 2027 update. Thank you for your time and consideration of this important matter.
Sincerely,
Heather Kendrick, BCBA, LBA
Phoenix, AZ