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Records and audits

Never let your employer be the only place your BCBA fieldwork records live

A watercolor desk with the same set of papers twice: a plain grey office tray holding a pale, faded stack, and beside it a violet folder tied with a navy ribbon holding a crisp copy, with a small brass key resting on the desk.
Table of contents
  1. The retention requirement is yours, not your employer’s
  2. Where it actually bites: the audit gives you 14 days
  3. Five ordinary ways employer-held records disappear
  4. The BACB’s escape hatch also runs on your own copies
  5. What a complete personal copy contains
  6. Do it monthly, because the deadline is already monthly
  7. How FieldworkABA helps
  8. Common questions

Ask a BCBA trainee where their fieldwork records are and the answer is usually a list of places that belong to someone else: a company drive, a supervisor’s inbox, a practice-management system the employer licenses, a folder on a clinic server. That works perfectly well until the day the account is closed, and then it stops working all at once.

This is not an argument about trusting your employer. Plenty of organizations keep excellent records. It is that the BACB wrote the retention requirement for you, personally, and the timeline it sets outlasts most jobs.

The retention requirement is yours, not your employer’s

Two separate obligations sit in the BCBA Handbook, and both name the trainee directly.

The first is written into the supervision contract. The contract has to contain a statement declaring that the trainee and supervisor(s):

“(a) will retain a copy of the contract and supervision documentation for at least seven years from the date of the final supervision meeting, and (b) will provide all documentation to the BACB if requested”

BCBA Handbook, BACB

The second covers the forms themselves:

“Both parties must retain a copy of the completed fieldwork forms for at least seven years after obtaining certification.”

BCBA Handbook, BACB

Note the wording in both: both parties, each. Your supervisor’s copy is not your copy. The monthly verification form prints the point in capitals across the page, in the footer of every single month you sign: supervisor and trainee must each retain a copy of this form for at least 7 years.

Two clocks, then, and they do not run together. Contract and supervision documentation: seven years from the final supervision meeting. Completed forms: seven years from the day you are certified. Change jobs three times along the way and neither clock resets, pauses, or transfers to anyone else.

Where it actually bites: the audit gives you 14 days

Retention rules feel abstract until an audit lands. The Handbook is blunt about how those start:

“The BACB may initiate a fieldwork audit at any time for any reason.”

BCBA Handbook, BACB

An audit can ask for the supervision contract, your Monthly Fieldwork Verification Forms, your documentation system, an audit log, and supervisor-related documents. The response window is short, and the consequences of missing it are spelled out:

“All relevant parties will submit requested documents to the BACB as directed in the audit initiation email within the specified time frame, typically 14 days. Documents submitted after the deadline will not be reviewed or considered in the determination. Note: If the BACB does not receive a response in the specified time frame, the fieldwork will be considered noncompliant.”

BCBA Handbook, BACB

Fourteen days is not enough time to get a former employer to reopen an account. It is often not enough time to reach the right person at a company you left two years ago, let alone have them search a decommissioned system for records of someone who no longer works there. If an application is audited, processing is suspended until the audit is finished, and fieldwork found noncompliant may be disqualified in part or in full.

There is more on how the process runs in the fieldwork audit glossary entry.

Five ordinary ways employer-held records disappear

None of these require anyone to behave badly. They are all routine.

You resign or are let go
Company email, shared drives and single sign-on usually end on the last day, sometimes within the hour. Anything that existed only inside that account goes with it, and the offboarding checklist was not written with your BACB retention obligation in mind.
Your supervisor leaves
Their mailbox is deactivated and their copies go too. They are also much harder to reach afterwards, which matters if a form still needs a signature.
The tracking system is the employer’s
Practice-management and supervision platforms are licensed to the organization. Your records live inside their account, and your login is one an administrator there controls and can close.
The company closes, merges, or is acquired
Systems get consolidated or switched off, usually faster than anyone expects, and historical data for former staff is rarely the migration priority.
The relationship breaks down
A dispute is exactly the moment copies stop being handed over, and exactly the moment you need them most.

The BACB’s escape hatch also runs on your own copies

Most trainees find this one out at the worst possible time.

If a supervisor refuses or is unable to sign your Final Fieldwork Verification Form even though all supervision contract terms have been met, the BACB has a route: the Contested Fieldwork Form. It has a hard boundary:

“This form may only be used to contest signatures on the Final Fieldwork Verification Form and should not be used to contest signatures on Monthly Fieldwork Verification forms or to appeal a determination made by BACB staff.”

Contested Fieldwork Form, BACB

And to use it, the BACB asks you to bring: your signed Monthly Fieldwork Verification Forms, documentation that supervision took place, a documentation system supporting the hours being contested, a signed supervision contract, and evidence that you tried to resolve it with your supervisor first, allowing at least 15 days for them to respond. Submitting it triggers a full fieldwork audit, and the determination goes on your record.

The remedy for a supervisor who will not sign is built entirely out of documents you are expected to already hold. A trainee who kept their own signed monthly forms has a case to make. A trainee whose monthly forms were never signed, or who can no longer reach them, has no equivalent route, because the contested process does not cover monthly forms at all.

What a complete personal copy contains

Working backwards from what an audit or a contested claim can ask for, your own set should hold:

  • The signed supervision contract, plus every amendment, each signed and dated by all relevant parties.
  • Every signed Monthly Fieldwork Verification Form, on the correct BACB version. Outdated or non-BACB forms are not accepted.
  • Your documentation system. For each session: date, start time, end time, fieldwork type, supervisor name, and whether the activity was restricted or unrestricted. For each supervision contact, add the supervision type, individual or group, and a summary of the supervision activity. For each observation: date, start time, end time, fieldwork type, setting name and supervisor name.
  • The Final Fieldwork Verification Form for each supervision experience.
  • A way to reach your supervisor later: their full name, BACB ID and a contact route that is not their work email address, agreed while you are still working together.

One thing deliberately not on that list is client information. The BACB’s documentation requirements ask for dates, times, fieldwork type, supervisor name, activity category and a summary of the supervision activity. They do not ask for client names. Your personal copy is a record of your hours, and it should not become a reason to carry client records out of a workplace.

Do it monthly, because the deadline is already monthly

You do not need a new habit, only one extra step in an existing one. The Handbook requires that the monthly form “must be signed by the last date of the calendar month following the month of supervision,” so there is already a signing rhythm with a fixed deadline.

  1. Get the month signed on time, rather than saving a stack of months for the end of the experience.
  2. Save your own copy in the same sitting, while the form is in front of you and your supervisor is still reachable.
  3. Keep it somewhere tied to your personal email, not an account your employer administers.
  4. Check once a year that the files still open and the set is complete, the way you would check any record you have to keep for seven years.

Retrospective record-keeping is also the thing audits are worst for. Reconstructing a year of hours in a fortnight, from memory and someone else’s calendar, is how compliant fieldwork ends up looking noncompliant.

How FieldworkABA helps

FieldworkABA is a BCBA fieldwork tracker built around the assumption that the records are yours. You register with your own email address, and the account stays with you when the job changes, including when an employer pays for the plan.

The Records Archive holds your verification forms, daily logs and total-hours reports month by month. Download record package builds a single ZIP: a Verification forms folder with one signed form per month, a Daily logs folder with the full activity record for each month, and your total hours report. That is close to the list an audit asks for, in one file, from your own login.

The FieldworkABA Records Archive: a Download record package button beside Total hours report, then one row per month showing the organization, a link to download the verification form, an option to upload a form signed elsewhere, a link to download the daily log, and a status of Signed or Not signed by supervisor.
Every month in one place, with its own status. The record package button collects the whole set, signed forms and daily logs, into a single download.

The status column is the part worth watching month to month. A month marked Not signed by supervisor is the one that turns into a problem later, because the contested route does not cover monthly forms.

Months signed somewhere else still belong in the same place, so a form you signed in a previous tracker or on paper can be uploaded into the archive alongside the rest. And because supervisor access is granted per month and can be withdrawn, a supervisor leaving does not take your records with them; they keep read-only access only to the months they were responsible for.

Keep your own set from month one

Log hours in an account that is yours, get each month signed on time, and download the whole record package whenever you want a copy of your own.

Start Free How record storage works

Common questions

How long do I have to keep my BCBA fieldwork records?
There are two clocks. The supervision contract and supervision documentation must be retained for at least seven years from the date of the final supervision meeting. Completed fieldwork verification forms must be retained for at least seven years after you obtain certification. Neither clock stops when you change employer.
My supervisor keeps a copy. Is that enough?
No. The BACB requires both the trainee and the supervisor to retain their own copies. The monthly verification form states it in capitals across the page: supervisor and trainee must each retain a copy for at least 7 years.
Can I contest a monthly form my supervisor never signed?
No. The BACB's Contested Fieldwork Form may only be used to contest signatures on the Final Fieldwork Verification Form, not on Monthly Fieldwork Verification Forms. That is why months are signed one at a time, by the end of the following month.
Can my fieldwork be audited after I am certified?
Yes. The BACB may audit trainees and supervisors at any time, for any reason, and the retention requirement for completed forms runs for seven years after certification. Documents are typically due within 14 days of the audit email.

Sources

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