Proposed standards — working draft. Not a society-ratified Standard of Care.

A proposed professional floor for people who later adopt it. Not the legal standard of care. Not binding on non-adopters. Not a condition of licensure, BCIA certification, or IQCB certification.

Theoretical participant mark for committee discussion. Not a license. Not a BCIA credential or an IQCB credential. Not society endorsement. Not being issued now.

Working draft · thought experiment for a future committee

How this draft would be organized

A published Standard of Care needs a home that can hold the text, take comment, and — only if a committee later chooses — license a participant mark. It should not try to regulate clinics that never agreed. Nothing on this page forms an entity.

Standards of Care for Neurofeedback Working Group

Theoretical participant mark for committee discussion. Not a license. Not a BCIA credential or an IQCB credential. Not society endorsement. Not being issued now.

1. What this site is

A working-group proposal. Not a license. Not BCIA. Not a society. Not an adopted instrument. Not a nonprofit already in operation.

2. Why structure matters

Ethics codes bind members. Certification is voluntary. Neither is a field-wide Standard of Care. If these Essential Practice Standards are worth keeping, they need an owner that is not also trying to be the certification police.

3. Recommended stack (for later counsel, not filed)

  • Public body: a nonprofit corporation. Either a 501(c)(3) educational standards institute or a 501(c)(6) professional compact.
  • Optional: a nonprofit-owned LLC only to hold the mark.
  • Not recommended: a clinician-owned LLC that invoices clinics; annual liquidated damages; a small-claims collection calendar.

4. Voluntary compact, not field-wide police power

People and clinics would opt in by agreement. Signatories could display a participant mark only while in good standing.

Private remedies would be: written warning; required correction; suspension or withdrawal of a public listing; withdrawal of the mark.

Clinical incompetence, unlicensed practice, and patient harm would still be referred to the state board that already has jurisdiction.

If a contract is later written, disputes about the agreement and the mark could go to mediation and then arbitration. That clause would not waive licensing-board complaints or patient claims.

5. How societies could hold support without adopting-and-enforcing

AAPB, ISNR, and BCIA are not asked to investigate clinics that decline to sign, and this draft is not a condition of their membership or of BCIA certification.

Support, if a later board chooses any of it, could climb this ladder:

  1. Take notice / list the draft as a commentable resource
  2. Affirmation of value
  3. Continuing education
  4. A statement supporting a voluntary floor of practice
  5. Formal endorsement after an open review
  6. Dual listing: existing credentials remain distinct from any future participant mark
  7. Liaison on later revisions

6. What the theoretical seal on this site would mean

The shield / brain / SoC mark is a thought-experiment participant seal. It exists so a committee can see the idea.

Honest later claim, if a compact is formed: “Participant — has agreed to the Essential Practice Standards (working draft).”

Not allowed then or now: “Board certified.” “Licensed by this group.” “BCIA equivalent.” “ISNR approved.” “Guaranteed clinical outcome.”

The mark is not being issued. No clinic should copy it onto marketing as proof of certification.

7. What we are asking a committee

Comment on the draft standards. Decide later, with counsel, whether a nonprofit compact and a licensed mark are worth forming. Do not treat this page as formation papers.

Return to the proposal · Read the draft standards