The average time for a submitted application to be approved is 3-4 months. This is not a guarantee that it will only take 3-4 months. An applicant is responsible to make sure all required documents, transcripts and verifications are accurately filled out and submitted to the Board's office. An application is incomplete and cannot move forward for substantive review until all required materials have been received, and are accurately filled out.
The time frames for applications are in the Rules:
- R4-26-208, Table 1 for Psychologists, and
- R4-26-417 for Behavior Analysts.
The image, below provides a hypothetical visual depiction of how application time frames work.
Types of Time Frames
Essentially, five (5) types of time frames are tracked. Three for Board staff, and two for applicants.
For Board staff, the time frames are:
- "Administrative Completeness Time Frame" (administrative review) - 30 days
- "Substantive Review Time Frame" (substantive review) - 90 days
- Overall Time Frame - 120 days - the sum of Admin Review and Substantive Review time frames.
For applicants, the time frames are:
Administrative Review"Time to Respond to Notice of Deficiency" (Incomplete Notice) - 240 days. The incomplete notice is sent out during the initial 30 days of administrative review. Once the incomplete notice is sent, the clock stops for the Board. The time frames for Board staff are suspended until all the materials listed in the incomplete notice have been received in the Board's office. The applicant has 240 days to submit all the materials listed in the incomplete notice.
- The applicant has 240 days to submit all the materials listed in the incomplete notice.
- Once all the materials are in, the clock starts ticking again for the Board until a notice of administrative completeness is emailed to the applicant.
- The date the admin complete notice is emailed to the applicant is the date the administrative review stops and the substantive review begins.
- For example, an application was received on 4/03/2023 and the incomplete notice was sent out on 4/10/2023. (7 of the 30 days for admin review have been "used".) The last of the materials in the incomplete notice arrived in the Board's office on 05/02/2023. The administrative completeness notice was emailed on 05/14/2023, twelve (12) days after the application was technically administratively complete. These latter 12 days are counted under the administrative review timeframe, and substantive review started on 05/14/2023 for this application. The tally of admin review days for this application are 7 + 12 = 19 days, which is within the 30 day admin review time frame defined in Rule.
Substantive Review"Time to Respond to Request for Additional Information" 365 days for psychologists, 240 days for behavior analysts. During substantive review, the Application Review Committee (ARC) or the Committee on Behavior Analysts (CBA) meet in Open Meeting (via Zoom) to review complete applications to determine if requirements have been met and the applicant is qualified for whatever they've applied for. The ARC only reviews Psychologist applications, and the CBA only reviews Behavior Analyst applications.
- The ARC or CBA (Committee) may recommend an action to take on an application, but it does not make the final decision. Only the Board can make a final decision on an application. The Board may follow the Committee's recommendation, or it may make a different determination.
- During this review, the Committee may recommend approval, denial, or may determine that more information is needed to be able to make a final decision. Applications that have been recommended for approval to the Board are placed on the Board's Consent Agenda (CA) for the next Board meeting, which is scheduled about a week after the Committee meetings. The CA is a single item on the Board's agenda that includes the names of all the applicants for which the Committees recommended approval. The Board will take a single vote to approve the CA. The names of the applicants are NOT read into the record. However, they are listed on the agenda and in the minutes of the meeting.
- If the Committee determines that more information is needed to make a decision, it will make a "Formal Additional Information Request" or FAIR. When this happens, a FAIR letter is written detailing the Committee's concerns and the additional information the Committee needs to resolve those concerns. The FAIR letter is emailed to the applicant after it is approved by the Committee Chair. The applicant has a specific number of days from the date of the FAIR letter to respond with the materials and explanation(s) requested. The clock stops for the Board the day the FAIR letter is emailed and resumes when all materials are received.
- The applicant's time frame to respond starts on the date the FAIR letter is emailed to the applicant, and stops when all materials are received.
- This can happen more than once. Historically, the Committee will do this no more than three (3) times before forwarding the application to the Board for substantive review if it still has concerns. Historically, the Board may also go through this process up to three (3) times. On agendas, applications that are back for review on an agenda after a FAIR letter was issued will have "FAIR" written next to the applicant's name.
- Substantive review ends when the Board makes a final decision on an application.