Standards for public agencies

2020 Edition

Behavior Support and Management (PA-BSM) 1: Oversight of Restrictive Behavior Management Interventions

The agency employs restrictive behavior management interventions under the oversight of its agency head and leadership.
2020 Edition




The agency’s behavior support and management policies and practices promote positive behavior and protect the safety of service recipients and staff.
Full Implementation, Outstanding Performance
A rating of (1) indicates that the agency's practices fully meet the standard and reflect a high level of capacity.  
  • All elements or requirements outlined in the standard are evident in practice, with rare or no exceptions: exceptions do not impact service quality or agency performance. 
Substantial Implementation, Good Performance
A rating of (2) indicates that an agency's infrastructure and practices are basically sound but there is room for improvement.
  • The majority of the standards requirements have been met and the basic framework required by the standard has been implemented. 
  • Minor inconsistencies and not yet fully developed practices are noted; however, these do not significantly impact service quality or agency performance.

Partial Implementation, Concerning Performance
A rating of (3) indicates that the agency's observed infrastructure and/or practices require significant improvement.  

  • The agency has not implemented the basic framework of the standard but instead has in place only part of this framework.  
  • Omissions or exceptions to the practices outlined in the standard occur regularly, or practices are implemented in a cursory or haphazard manner.  
  • Service quality or agency functioning may be compromised.  
  • Capacity is at a basic level.
Unsatisfactory Implementation or Performance
A rating of (4) indicates that implementation of the standard is minimal or there is no evidence of implementation at all.  
  • The agency’s observed administration and management infrastructure and practices are weak or non-existent; or show signs of neglect, stagnation, or deterioration.
Self-Study EvidenceOn-Site EvidenceOn-Site Activities
County/Municipality Administered Agency, State Administered Agency (Central Office), or other Public Entity 
  • BSM policy (see also ASE 2)
  • BSM procedures, including incident review procedures
State Administered Agency (Regional Office)
  • No Self-Study Evidence
  • Documentation of program/clinical director notification of restrictive behavior management interventions
  • Aggregate of the two most recent quarterly reviews of incidents requiring restrictive behavior management interventions
  • Documentation of committee and administrative reviews of restrictive behavior management interventions for the previous six months
All Agencies
  • Interviews may include:
    1. Program directors
    2. Relevant personnel

Fundamental Practice

PA-BSM 1.01

The agency's behavior support and management policies and practices comply with federal, state, and local legal and regulatory requirements.
Examples: The Public Health Service Act, as amended by the Children's Health Act of 2000 and the Use of Restraint and Seclusion in Psychiatric Residential Treatment Facilities Providing Inpatient Psychiatric Services to Individuals Under Age 21 are federal regulations that govern the use of behavior management in the United States. Agencies serving youth involved with the juvenile justice system may be subject to different laws and regulations.
Note: The agency is required to comply with the more stringent standard or regulation. 

Note: COA recognizes that the laws or regulations governing agencies serving youth involved with the juvenile justice system may sometimes authorize practices that conflict with the standards to which COA holds other agencies, and has addressed some of the potential discrepancies throughout the standards in PA-BSM.

Fundamental Practice

PA-BSM 1.02

Behavior support and management policies address:
  1. safety measures to be taken when emergency situations arise, including which restrictive behavior management interventions may be used to protect service recipients from harming themselves or others;
  2. other practices that may be used and under what circumstances; and
  3. prohibited practices, including chemical restraint, corporal punishment, and behavior control methods that interfere with the indivdiual’s right to humane care.


 Medications are treatment for targeted symptomatology and should not be considered an intervention for challenging behaviors. In relation to element (c), chemical restraint does not include situations when a psychopharmacological drug:
  1. is used according to the requirements for treatment authorized by a court; 
  2. is provided using specified criteria in a person’s approved treatment plan as per a physician’s order to provide medical treatment for a specific diagnosis and known progression of symptoms, such as in cases of a PRN; or 
  3. is administered when necessary (PRN) to prevent immediate, substantial, and irreversible deterioration of a person’s mental status when prescribed by a physician or other qualified medical practitioner.
Examples: Refer to COA’s definition of restrictive behavior management interventions at the beginning of this section for a list of interventions that may be included in the behavior support and management policy.
Note: Refer to COA's glossary for a definition of chemical restraint.

Fundamental Practice

PA-BSM 1.03

The agency prohibits the use of behavior management interventions:
  1. by any person other than trained, qualified personnel;
  2. as a substitute for appropriate staffing patterns, for the convenience of personnel or as punishment;
  3. in response to property damage that does not involve imminent danger to self or others; and
  4. when contraindicated in the individual's service or behavior plan. 
Juvenile Justice


 Agencies serving youth involved with the juvenile justice system may be authorized to use restrictive interventions to prevent escapes, or protect property, in order to maintain safety, security, and order. However, they should still only employ restrictive interventions when absolutely necessary. 


PA-BSM 1.04

The agency head and leadership conduct regular reviews of the use of behavior support and management interventions and:
  1. compares agency practices to current information and research on effective practice;
  2. use findings from quarterly risk management reviews of restrictive behavior management to inform staff about current practice and the need for change;
  3. revise policies and procedures when necessary;
  4. determine whether additional resources are needed; and
  5. support efforts to minimize the use of restrictive behavior management interventions.


PA-BSM 1.05

The program or clinical director is notified following each use of a restrictive behavior management intervention and each incident is administratively reviewed no later than one working day following an incident to:
  1. review any preemptive measures taken to avoid the intervention;
  2. determine whether or not the individual’s behavior support and management plan was followed; and
  3. assess the measures’ effectiveness.