To design ABA software implementation governance and decision rights, assign accountable owners for sponsorship, clinical standards, workflow, privacy, security, data, integration, accessibility, training, finance, legal review, vendor management, go-live, safe stop, rollback, exceptions, and change approval. Give each decision one accountable role, define consultation and evidence, and publish escalation paths. Ownership funds and oversees the program but does not create clinical, legal, or technical competence.

Define Theo's implementation governance and decision rights

Theo builds governance around decisions rather than recurring meetings. The charter states who can approve a clinical template, accept residual security risk, release an interface, sign a contract, pause a clinic rollout, authorize rollback, communicate an incident, and close a defect. Committee discussion supports those owners without diluting accountability.

Build the technology implementation charter and RACI

The record captures charter ID; scope, objectives and excluded work; sponsor; product owner; clinical, operations, privacy, security, data, integration, accessibility, training, finance, legal, HR and vendor owners; decision catalog; accountable, responsible, consulted and informed roles; evidence and quorum; conflict and recusal; client and workforce input; risk acceptance; exception; go-live, stop and rollback authority; incident command; change control; escalation; cadence; minutes; action; due date; and sunset. Structured fields support comparison, routing, alerts, evidence expiry, and validation. Narrative preserves clinical reasoning, client and family experience, accessibility, uncertainty, disagreement, legal deferral, source limits, and why an accountable owner accepted, restricted, remediated, deferred, or rejected the item.

Apply Theo's procurement or rollout workflow

Theo inventories material decisions, assigns authority based on role and governing sources, and tests the charter through scenarios. Each workstream records evidence and unresolved risk. Cross-domain conflicts escalate without letting the most senior person automatically override a qualified clinical, privacy, security, or legal boundary. Changes to decision rights are versioned and communicated.

Protect the implementation governance and decision rights boundary

Owners and governing bodies allocate resources, approve policy, receive risk information, and hold leaders accountable. Ownership alone does not establish clinical authority, licensure, privacy-officer authority, security competence, or legal privilege. Each qualified role retains the decisions assigned by applicable law, professional scope, contract, and policy.

Keep authority and evidence attributable

Theo assigns each clinical, privacy, security, technical, accessibility, finance, contract, workforce, and operational decision to a qualified owner. Software and vendors may surface evidence or propose an action. They cannot accept the practice's risk, grant professional authority, replace client involvement, or approve their own control effectiveness.

Make unknowns and conditions visible

Theo records each unknown, assumption, exception, dependency, workaround, safeguard, owner, deadline, escalation, and retest. An unanswered question stays unknown. A conditional acceptance states the exact remediation, operating restriction, evidence, expiry, and consequence of missing it.

Work through Theo's fictional example

Theo maps 28 fictional implementation decisions. Twenty-two have one accountable owner, required evidence, consultation, escalation, and stop or rollback rule. One has two accountable owners, one leaves clinical templates to IT, one lets the vendor accept security risk, one has no accessibility owner, one omits family input, and one lacks incident command. Four repair. Two remain with executive governance. This synthetic example tests workflow and denominator logic. It establishes no clinical, privacy, security, accessibility, contract, insurance, payer, employment, record, financial, or legal conclusion for a real practice or vendor.

Calculate Theo's measures honestly

Initial decision-rights completeness is 22 of 28, or 78.6%. Twenty-six decisions reach approved ownership or documented hold, or 92.9%. Decisions, roles, meetings, risks, actions, workstreams, and product changes retain separate denominators.

Address the main implementation governance and decision rights risk

A committee can create the appearance of shared control while no one has clear authority to stop unsafe work, accept risk, approve clinical content, or complete a correction.

Test Theo's control against hard cases

Theo tests clinical template conflict, privacy objection, security exception, integration defect, inaccessible workflow, budget overrun, vendor delay, client harm report, incident, go-live pause, rollback, and product change. Each test retains product and version, configuration, data, user, starting state, expected safeguard, observed result, defect, owner, retest, and disposition. Failed, skipped, and unknown cases remain visible with reasons.

Run Theo's independent acceptance test

Theo gives a reviewer the charter, decision catalog, evidence rules, escalation map, and scenario results. The reviewer removes the sponsor from one scenario and must still identify valid authority and action. Multiple accountable owners or vendor-owned practice risk fails.

Maintain the technology implementation charter and RACI

Theo assigns a review cadence and triggers for requirement, product, version, configuration, workflow, integration, subprocessor, data use, law, contract, incident, staffing, access, cost, and ownership changes. The implementation governance and decision rights page remains draft until every named external review finishes.

Use public organizational guidance within scope

Theo uses the CASP Organizational Guidelines public overview only for high-level business, clinical-operations, and risk-management context. CASP sells the detailed guidelines. The technology implementation charter and RACI is an editorial model built for this task and does not imply CASP approval of a product or architecture.

Map business-associate duties and contract terms accurately

Current HHS Business Associates guidance describes function-based roles, subcontractors, agreements, and exceptions. HHS sample BAA provisions address HIPAA concepts and explicitly caution that sample language alone may be insufficient as a binding state-law contract. HHS cloud guidance preserves CSP business-associate status even for encrypted ePHI without a key. Theo scopes every relationship.

Connect procurement and rollout to risk analysis

HHS risk-analysis guidance requires a regulated covered entity or business associate to assess risks and vulnerabilities to all ePHI it creates, receives, maintains, or transmits. Theo feeds findings from the implementation governance and decision rights into current risk analysis and risk management rather than treating a contract, demo, score, or training record as certification.

Use current Security Rule safeguards

Current 45 CFR 164.308 covers administrative safeguards, 45 CFR 164.312 covers technical safeguards, and 45 CFR 164.316 covers policies, procedures, and specified documentation retention. Theo checks each applicable standard and implementation specification for the deployed workflow without claiming the rule requires one product or design.

Review consumer-health and AI data promises separately

The FTC Health Breach Notification Rule guidance has its own entity, PHR, multiple-source, and exclusion tests. FTC staff also tells AI companies to uphold privacy and confidentiality commitments, including promises about training and undisclosed uses. Theo treats that staff post as enforcement-oriented guidance, not a new universal AI statute.

Use voluntary frameworks as organizing aids

The NIST Cybersecurity Framework 2.0 helps organizations manage cybersecurity risk. The NIST AI RMF page describes AI RMF 1.0 as voluntary and says it is being revised. The OIG General Compliance Program Guidance is voluntary and nonbinding. Theo uses these sources to organize evidence for the technology implementation charter and RACI, never as legal safe harbors.

Build accessibility into procurement and rollout

Theo checks the DOJ Title III overview and web-accessibility guidance within their scopes. The ASHA AAC Practice Portal says AAC users should always have access to their communication tools. Demonstrations, contracts, training, support, and rollout cover keyboard, screen-reader, language, device, AAC, and alternative-channel needs.

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