ABA Record Copy Fee, Format and Delivery Comparison Worksheet for Families

Use the ABA records fee and format worksheet for families to compare supplied choices consistently before recording which option the family selects.

Use this worksheet before agreeing to a fee, summary, explanation, alternate format, or delivery method. Keep the actual request dates, acknowledgment, and delivery history in the ABA Records Request and Delivery Tracker for Families instead of duplicating them here. Store fee notices, identity documents, records, and payment information in approved secure systems; use short references here.

This worksheet is not a price calculator, billing dispute, legal analysis, or order to produce records in a particular way.

Families and Caregivers / Progress, Quality, Rights and Ethical Care.

What this worksheet can and cannot establish

The worksheet can preserve the responsible entity, access process, requested records, requested and offered formats, readability and accessibility needs, delivery choices, fee estimate, stated components, estimate date, selected option, delivered files, invoice, and unresolved questions.

Important boundary: This worksheet cannot decide whether HIPAA or another law applies. It cannot determine covered-entity or designated-record-set status, requester or personal-representative authority, what is readily producible, accessibility compliance, secure transmission, permitted cost, reasonable cost, state-law interaction, deadline, violation, or remedy. It cannot negotiate or calculate a legally required fee, direct an organization's production method, or replace privacy, records, accessibility, security, payer, regulator, state-law, or legal review.

The BACB Ethics Code for Behavior Analysts addresses confidentiality, documentation, accurate billing, understandable communication, and compliance with applicable requirements within its professional scope. This tool does not determine whether a certificant, provider, or plan complied with the code.

Classify the transaction before comparing options

ProcessWhat the family may be asking forWhy it stays separateInspect recordsView information without receiving a copyCopy fees and delivery may not be the sameReceive a copy through an access processObtain records for the individual or personal representativeThe responsible entity must classify the requestSummary or explanationReceive a new summary or explanation instead of or with recordsAgreement and charges may differProvider-to-provider sharingSend information for treatment or another stated purposeThis may not be the individual's copy requestAuthorization-based disclosureSend information under a signed authorizationAuthorization scope and revocation are separatePayer or school requestRespond to another organization's documentation processDifferent instructions and fee rules may applyOrdinary document copyObtain forms, policies, or materials outside a health-record access processDo not assume HIPAA fee rules govern it

Ask the organization to name the process it is using. Record that answer and its source. Do not apply one organization's quote, portal capability, fee schedule, or legal status to another.

Use current sources as questions, not automatic conclusions

Current 45 CFR 164.524 addresses form, format, manner, summaries or explanations, and limited cost-based fees when the HIPAA access rule applies. It describes the requested form and format if readily producible, or an agreed readable alternative. Under its conditions, the section identifies specified copying labor, supplies, postage, and an agreed summary or explanation as fee components.

The HHS right-of-access guidance discusses electronic copies, readily producible formats, advance notice of approximate fees, and permissible calculation methods. HHS's FAQ on fees for copies of PHI explains that the guidance remains effective only to the extent consistent with the cited federal court order and distinguishes copying labor from search and retrieval. The HHS Your Medical Records page gives a public summary of access and charges.

These sources do not establish that a particular ABA organization or transaction is covered, that a requested format is readily producible, or that a quoted charge is permitted or reasonable. Ask the responsible records or privacy office to explain the current option and source.

Create the comparison identity block

Request fieldFamily entryPerson whose information is involvedRequester and authority presentedOrganization and legal entityRequest reference and submission dateRecord categories and date rangeProcess named by the organizationDate the organization says the request became completeRecords or privacy contactCurrent fee or access instructions and dateSecure location of notices and estimates

Lock one person, organization, record scope, and date range across the options. A paper copy of 60 pages and an electronic copy of three files are not comparable if they cover different material. Ask the organization to confirm any scope difference before comparing price or speed.

Record what the family actually needs

Need or preferenceFamily entryPaper, electronic, inspection, or another formPreferred file formatDevice or software used to open filesScreen-reader, magnification, language, or communication needColor, image, table, signature, or handwriting readability needPreferred delivery routeSecurity concern or questionTime-sensitive reason, if the family chooses to share itAcceptable alternative to discuss

The DOJ ADA effective-communication resource explains general effective-communication principles for entities covered by the ADA. It does not decide which entity, format, accommodation, or outcome applies. Ask for an accessible option without placing diagnosis details or passwords in this worksheet.

“Electronic” is not one format. A portal preview, searchable PDF, image-only PDF, spreadsheet, machine-readable export, encrypted message, and physical drive may behave differently. Name both the requested file format and the functional need, such as searchable text or screen-reader compatibility, then record the organization's response.

Compare offered form, format, and delivery options

OptionRecords and date rangeForm and formatDelivery routeOpens on family device?Accessibility notesEstimated timingQuote referenceABC

Ask whether each option covers the same records. Record whether the organization says the requested format is readily producible and, if not, which readable alternative it offers. Do not claim a technical capability based only on the file extension or a staff member's guess.

Discuss secure delivery with the responsible security or privacy contact. A family preference, warning, encryption label, portal icon, or successful download does not by itself prove legal compliance or eliminate risk. Use the organization's approved route and protect credentials.

Break down each quoted fee exactly as stated

Quoted componentOption AOption BOption CSource or explanationCopying laborPaper suppliesElectronic media requested by familyPostage requested by familySummary or explanation chosen in advanceOther amount listedTax or payment-processing item, if listedTotal estimateEstimate date and expiration, if stated

Copy each label, amount, currency, and unit from the quote. Do not silently relabel an “administrative fee” as copying labor or decide that a component is allowed. Ask for the calculation method or breakdown when useful, then preserve the attributed answer.

Under the federal rule, when it applies, the listed fee categories are limited. HHS guidance further explains that search, retrieval, verification, system maintenance, and general compliance work are not copying labor for this calculation. State law can interact with federal requirements. This worksheet flags a question for qualified review; it does not resolve that interaction.

Check the arithmetic without certifying the charge

Arithmetic fieldFamily entryStated unit, such as pages, minutes, media, or postageStated quantityStated rateQuantity multiplied by rateAdded fixed componentsFamily's arithmetic resultOrganization's quoted totalDifference to ask about

Simple arithmetic can surface a transcription difference. Preserve the quoted amount unchanged and calculate on a separate line. The comparison cannot prove that the unit, rate, category, or total is legally permitted or reasonable.

If the family asks for a summary or explanation, record whether it chose that item in advance and agreed to the stated fee. A summary may omit detail that exists in the underlying records. Compare the offered scope and purpose before choosing.

Log questions and the selected option

EventDatePerson or officeExact question, answer, or choiceEvidence locationNext actionOptions receivedApproximate fee receivedBreakdown requestedFormat or accessibility question answeredDelivery or security question answeredFamily selected an optionOrganization confirmed scope and estimatePayment or waiver question routed

Write “records office states” or “family selected,” rather than presenting an answer as a universal rule. When the family cannot afford a quoted amount, ask whether the organization offers a no-cost route, inspection, portal access, waiver, narrower scope, or another current option. Record the attributed response without promising availability or advising the family to abandon needed records.

Reconcile delivery, usability, and the final charge

Reconciliation fieldExpectedActualDifference or open questionRecord categories and date rangeNumber of files, pages, or other unitsForm and formatDelivery routeAccessibility and readabilityEstimateFinal invoice or chargePayment receipt or account status

Open every file through the family's normal device or assistive technology. A file that downloads may still be unreadable. A readable file may still omit requested records. A matching invoice does not certify that the charge or process complied with law.

If the final charge differs, ask the billing, records, or privacy contact to explain the difference and correct a simple error if appropriate. Keep a billing question separate from a privacy complaint or legal claim. Do not send payment-card details through an unapproved worksheet.

Close without certifying the process

Before closing, confirm the entity and request scope, preserve the current quote, record the selected option, store the delivery evidence and invoice, test the files, and assign every remaining question. Link this worksheet to the records request tracker rather than duplicating the entire request history.

Mark the comparison “closed” only after the selected scope, option, delivery, usability check, and final charge are recorded. Closure does not certify covered-entity status, authority, readily-producible capability, accessibility, security, fee legality, reasonableness, state-law compliance, completeness, violation, or remedy.

Fictional example: comparing a portal copy and mailed paper

This example describes no real learner, family, provider, plan, record, quote, or charge.

Jordan requests a fictional provider's existing assessment and progress records for child Casey. Cedar Finch ABA confirms that its records office is treating the request as an individual access request and offers two options covering the same date range: a searchable PDF through its secure portal or a mailed paper copy.

Jordan records the provider's statements without deciding whether HIPAA applies. The portal option has no stated fee. The paper estimate lists copying labor, paper supplies, and postage. Jordan needs screen-reader-compatible text, so the worksheet asks whether the PDF has searchable text and usable reading order. The office supplies a small test file through its approved route, and Jordan confirms it works with the family's device.

Jordan selects the portal option and saves the confirmation. When the records arrive, one file is image-only. The provider replaces that file with a readable version. Jordan records the first delivery and replacement rather than marking the original file “accessible.” The final charge remains zero, matching the quote.

The example does not establish that the provider is a covered entity, that the PDF format was legally required, that the paper quote was permitted, or that every requested record was included. It shows how to compare attributed options and verify the family's real-world result.