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Best Practices in Corporate Practice of Medicine Compliance: What Illinois Providers Need to Know

Monday, August 11, 2025
3:00 PM - 4:30 PM (EDT)

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Event Details

Abstract

With the implementation of the Illinois Behavior Analyst Licensing Act earlier this year, the clock is ticking on the timeline to comply with Section 150 of the act, commonly referred to as a prohibition on Corporate Practice of Medicine (CPOM). As of January 2027, any organization providing applied behavior analysis (ABA) services will need to be fully owned by licensed behavior analysts or other approved licensed clinicians. At present, very few states have CPOM regulations that impact ABA services, but this issue is coming up more frequently in our field, alongside other discussions of regulatory changes. We recognize the controversial nature of this topic, and that individuals and organizations may have strong feelings on both sides of the issue. This presentation is intended to inform ABA service providers of upcoming regulatory changes in Illinois, review best practices in compliance with CPOM prohibitions, and understand the implications of these requirements in Illinois, specifically. The statewide network of ABA providers in Illinois serves tens of thousands of children with autism. It is critical that organizations are aware of the requirements to restructure and how to remain in compliance with new state regulations in order to ensure continuity of care for service recipients.

Learning Objectives

Following this presentation, attendees will be able to:

  1. Describe corporate practice of medicine prohibitions
  2. Describe the relevant provisions in the Illinois Behavior Analyst Licensing Act
  3. Determine the steps their organization will need to take in order to comply

BACB CEU is not offered for this webinar


Cost

  • CASP Members - free
  • non-members - $20

Presenters

Benjamin Bresnick, J.D.

Benjamin D. Bresnick is a Shareholder in the law firm of Hogan Marren Babbo & Rose.

Mr. Bresnick has nearly three decades of legal experience in the healthcare industry  and focuses his practice on providing advice and guidance to university and college medical centers, community hospitals, multispecialty physician groups, licensed providers, and insurance brokers.  

Mr. Bresnick provides guidance on regulatory matters in health care which include Stark, Anti-kickback, Beneficiary Inducement, billing, and privacy matters.  He provides advice to clients on state and federal breach reporting and is regularly called on to conduct complex physician arrangement reviews.  Mr. Bresnick has also provided privacy support to university health systems to ensure compliance with the 21st Century Cures Act and conducted operational due diligence in support of hundred-million-dollar transactions. 

Prior to joining Hogan Marren Babbo and Rose, Mr. Bresnick was a Managing Director and head of the health care privacy practice at a large international consulting firm.  Before his consulting career, Mr. Bresnick was the chief compliance and privacy officer and interim general counsel of a community hospital where he was responsible for controlling legal and regulatory risks across Stark, Anti-kickback, False Claims Act, HIPAA, and EMTALA regulations.   

Rebecca Thompson, PhD, BCBA-D

Dr. Becky Thompson is the Senior Director for Advocacy at LEARN Behavioral. A clinician by training, she is licensed as a Psychologist and Behavior Analyst in both Illinois and Wisconsin. Dr. Thompson started working with individuals on the spectrum in 2000, and has extensive experience providing ABA services and conducting diagnostic evaluations. She is especially passionate about advocating for equitable access to ABA services. Dr. Thompson is proud to serve as the inaugural President of the Illinois Providers for ABA Access & Quality (IPAAQ). She co-leads multiple State Advocacy Groups (SAGs) within CASP and is actively involved in several state professional and trade associations.