Statistical Policy Directive No. 8: North American Industry Classification System (NAICS)-Request for Comments on Proposed Updates for 2027

Kristie Koch, CEO of School-Based Behavior Consultation, supports the creation of independent NAICS classifications for Behavior Analysts and Assistant Behavior Analysts. She argues that the current broad classifications do not accurately reflect the distinct service delivery model, workforce structure, and economic impact of the behavior analysis profession.

The commenter supports the inclusion of three specific NAICS codes (Foreign Labor Placement, International Student Enrollment, and Workforce Automation/AI Substitution) in the 2027 revision rather than deferring them to 2032. They argue that these codes are necessary to provide federal visibility into current economic forces displacing American workers.

Elizabeth Cunningham, a private citizen, supports the inclusion of three new NAICS codes (561399, 611319, and 518219) in the 2027 revision. She argues that these codes are necessary to provide visibility into the impacts of foreign labor, international student enrollment, and AI-driven job displacement on American workers.

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.

The Council of Autism Service Providers (CASP), a non-profit trade association, requests the addition of a new NAICS classification (621350) for Offices of Behavior Analysts and Assistant Behavior Analysts. They argue that this profession is a distinct, rapidly growing segment of the healthcare economy that is currently obscured within broader mental health categories, making accurate economic tracking and benchmarking difficult.

Carol A. Corrado, a Senior Policy Scholar at Georgetown University, supports the proposed NAICS updates but argues for more specific changes. She recommends splitting NAICS 518210 to separate large-scale computing infrastructure from web hosting, aligning NAICS with NAPCS for cloud services, and providing narrative clarification on where AI model developers should be classified.

Sarah Meloche, a private citizen, supports the inclusion of three new NAICS codes related to foreign labor, international student enrollment, and AI substitution in the 2027 revision. She argues that these codes are necessary to provide data transparency regarding the impact of these factors on American workers.