Applied Behavior Analyst Licensing Laws and Practice Requirements by State

These days, a licensed behavior analyst is the only acceptable type of ABA provider for people in need of these services. But behavioral analysts generally worked without certification or licensing up until 1993, when Florida became the first state to offer a certification path. The evolution of ABA licensing hasn’t followed a straight line, though, and hasn’t resulted in a perfectly uniform set of licensing laws across all states.

Creating a system for licensing and establishing a licensing board to maintain standards and to act as arbiter and authority adds overhead and compliance costs. However, licensure has also improved the standing of the field of applied behavior analysis, bolstered the professional stature of practitioners, and given them a better chance at receiving compensation from insurance companies for the services they provide.

Still, faced with the task of establishing ABA licensing requirements and standards, many states balked at the difficulty and expense—even Florida eventually stepped away from managing their own program.

Into the gap stepped the Behavior Analyst Certification Board (BACB), a national non-profit established in 1998 to meet the professional credentialing needs of governments, insurers, and analysts themselves. In the years to follow, the licensed behavior analyst would become a fixture in many states as licensing laws began to take shape one state at a time.

BACB both offers independent credentialing, in the form of the Board-Certified Behavior Analyst (BCBA®) series of certifications, and provides assistance to regulatory bodies by establishing a model for regulatory legislation in the form of the BACB Model Act.

The Model Act provides the legislative language that states often draw from when creating ABA license requirements. It outlines standards for the licensed behavior analyst and suggested qualifications for behavior analysts (including BCBA® certificates) that state legislators can use to base their own individual laws on.

Amid a growing need for professionally qualified and officially licensed behavior analysts, driven largely by a growing body of knowledge about Autism Spectrum Disorder – and insurance companies demanding that the profession be regulated – many states have begun joining the movement to implement licensing laws.

The Making of a Licensed Behavior Analyst – State Boards Establish ABA License Requirements

State licensing departments are responsible for establishing the requirements for issuing behavior analyst licenses on a state-by-state basis. There is no national licensing scheme for the profession.

As with many other state licensed professions – from advanced practice nursing to certified public accounting – many state licensing departments delegate the actual responsibility for determining qualifications to a regulatory board made up of experienced professionals from the same field. A typical state board will include both behavior analysts and other medical professionals to provide a well-rounded evaluation of prospective candidates for licensure.

In some states, existing medical or psychological licensing boards have taken on the role of evaluating behavior analysts and setting certain ABA license requirements. In others, new boards have been created from scratch to handle the task.

In states where no ABA board is in place, the licensing department itself issues licenses, usually based on an evaluation process that relies more on experience and education than examination and certification.

FIND SCHOOLS
Sponsored Content

Meeting ABA License Requirements – What Does it Take To Get Licensed as a Behavior Analyst?

Generally, some combination of a degree and a specified number of classroom hours in behavior analysis studies would qualify a candidate for licensing. Many states, particularly those that have adopted the BACB Model Act closely, require a BCBA® certification.

The BCBA® recognizes three options for candidates applying for the certificate:

  • An acceptable graduate degree from an accredited university, including coursework in behavior analysis
  • Between 1,500 and 2,000 hours of supervised fieldwork
  • Passing the BCBA® exam

OR

  • An acceptable graduate degree from an accredited university
  • A full-time faculty position teaching behavior analysis
  • Between 1,500 and 2,000 hours of supervised fieldwork
  • Passing the BCBA® exam

OR

  • An acceptable doctoral degree conferred at least ten years prior to applying for a license
  • Ten years of postdoctoral experience
  • 500 hours of supervised fieldwork
  • Passing the BCBA® exam

ABA Licensure by State: Find Detailed Information on ABA License Requirements in Your State

In nearly every state, even those that do not require the BCBA®, a master’s degree is the standard minimum qualification to become a licensed behavior analyst. Click on your state for detailed information on the ABA license requirements where you live.

State-by-State Licensing Overview

All states fall into one of four categories in terms of how they approach behavior analyst licensing:

Generally, those states that adopted licensing requirements sooner have more detailed and clear-cut requirements, so we have listed the year the laws were adopted together with a link to the regulatory body responsible for issuing the license.

Many states have not yet passed legislation for regulating behavioral analysts. Others have done so only very recently and the practical process for obtaining a license is still being worked out.

Although some states, such as Florida, do not regulate the actual practice of behavioral analysts, they may have statutory regulations against individuals assuming the title without BCBA® certification.

Other states, such as Delaware, may not regulate behavioral analysts separately but may have other legislation, such as autism care requirements, which outlines requirements for behavior analyst certification when practicing in certain contexts.

License Available, BCBA® Required

Alabama

Hawaii

Kentucky

Massachusetts

Mississippi

Missouri

Nevada

Oklahoma

Tennessee

Virginia

Wisconsin

License Available, BCBA® Optional

Arkansas

Applied Behaviorists fall under state laws for becoming a Licensed Professional Counselor (LPC). Behavioral Analysts are a recognized specialization area, with BACB guidelines followed for their evaluation.

New York

Pennsylvania

The Pennsylvania State Board of Medicine oversees the regulation and licensure for behavior analysts in the state through the Behavior Specialist license.

North Dakota

Washington

FIND SCHOOLS
Sponsored Content

States Without Licensure

California

Assembly Bill 1715 was introduced and later withdrawn in 2016; no further bills have been proposed.

Colorado

A 2020 Sunrise Review by the Colorado Office of Policy, Research and Regulatory Reform (COPRRR) within the Colorado Department of Regulatory Agencies (DORA) found that ABA falls under the umbrella of the “legal” definition of psychotherapy, although ABA practitioners are not required to register as Unlicensed Psychotherapists unless they engage in the practice of psychotherapy.

Delaware

Although behavior analysts are not regulated directly in Delaware, state regulations for autism service providers both define the profession and accept BACB certification as the sole qualification for service providers.

District of Columbia

While no licensing requirements or direct regulation is in place for behavior analysts in the District of Columbia, the District’s Department on Disability Services, Developmental Disabilities Administration recognizes Board Certified Behavior Analysts as being among those authorized to provide behavior support services that is eligible for Medicaid reimbursement when performed under the supervision of psychiatrists, psychologists, APRNs, or Licensed Independent Clinical Social Workers (LICSW) as described in DC Official Code Section 1919.

Florida

SB1212 was introduced in 2014 to introduce licensing requirements but died in committee. No new legislation has been introduced.

In 1998, the Florida Behavior Analysis Certification Program, part of the Florida Department of Children and Families/APD, was created to certify Florida’s behavior analysts. This program was eliminated in October 2003. Individuals certified under this program are permitted to continue using the Florida Certified Behavior Analyst® (FL-CBA®) designation, although the designation is only recognized within the state.

Idaho

No governing body or licensing laws are in place or pending at this time.

Maine

Maine insurance codes require that behavior analysts have national board certification in order to receive compensation from insurers.

New Hampshire

New Hampshire House Bill 569 (better known as Connor’s Law) states that state-regulated health insurance plans must cover ABA therapy by a “person professionally certified by the National Behavior Analyst Certification Board or performed under the supervision of a person professionally certified by the national Behavior Analyst Certification Board.”

New Mexico

Under the New Mexico Health Care Authority, professionals who deliver applied behavior analysis (ABA) services through the Medical Assistance Program system must hold a Board Certified Behavior Analyst® (BCBA®) or BCBA-Doctorate® (BCBA-D®) certification.

South Carolina

As of 2019, Medicaid requires all supervisory and direct therapy ABA providers to be credentialed through the Behavioral Analyst Certification Board (BACB) to qualify for insurance reimbursement.

West Virginia

In response to an application submitted to the Joint Standing Committee on Government Organization by the Board Certified Behavior Analysts of West Virginia, a 2012 Sunrise Report found that the oversight of behavior analysts by the Behavior Analyst Certification Board (BACB) provided adequate protection for citizens of West Virginia.