Applied Behavior Analyst Licensing Laws and Practice Requirements by State

Behavioral analysts generally worked without certification or licensing up until 1993, when Florida became the first state to offer a certification path.

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 licensing standards and requirements, 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.

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 licensing laws. It outlines standards 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 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.

Who Determines License Requirements for Behavior Analysts?

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 also. In others, new boards have been created from scratch to handle the task.

In states where no profession-specific board is in place, the licensing department itself issues licenses directly based less on an evaluation process that relies more on experience and education.

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 specific 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
  • A defined period of supervised practical experience
  • Passing the BCBA® exam

OR

  • An acceptable graduate degree from an accredited university
  • A full-time faculty position teaching behavior analysis
  • Passing the BCBA® exam

OR

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

In nearly every state, even those that do not require the BCBA®, a master’s degree is the standard minimum qualification required to become a licensed applied behavior analyst. A doctoral degree or educational specialist degree will also serve.

State-by-State Licensing Overview

As of 2016, states fall into four categories of approaches to 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 and Connecticut, 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

Alaska

Arizona

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.

Kansas

Specific alternatives to BACB certification have not yet been established for meeting license requirements.

Louisiana

Maryland

Specific alternatives to BACB certification have not yet been established for meeting license requirements.

Michigan

Michigan requires that behavior analysts be licensed under existing psychology licensing rules for the state.

New York

Specific alternatives to BACB certification have not yet been established for meeting license requirements.

North Carolina

North Carolina requires that behavioral analysis practitioners either be licensed as or practicing under psychologists.

North Dakota

Ohio

Ohio offers certification rather than licensing for behavioral analysts.

Oregon

Rhode Island

Utah

Specific alternatives to BACB certification have not yet been established for meeting license requirements.

Vermont

Washington

Specific alternatives to BACB certification have not yet been established for meeting license requirements.

Legislation Proposed to Create a Licensure Requirement

California

Two different measures (AB 1715 and AB 479) introducing licensing for behavioral analysts were introduced to the state legislature in 2015 and 2016, but have not passed into law yet. One measure would require BACB certification for practitioners while the other would make it optional.

Connecticut

Connecticut does not currently require licensure for behavioral analysts. However, HB799 prohibits non-certified individuals from using that title. SB1089 was introduced to the legislature in 2014 to require behavioral analyst licensing and is modeled on the BACB Model Act.

Illinois

Bill SB1895 was introduced in 2015 and remains under consideration and implements most of the provisions of the BACB Model Act.

South Dakota

HB1141 was introduced in 2016 to require licensing for behavioral analysts. BACB certification is among several qualifications acceptable under the proposed law.

Texas

HB 2703 was introduced in 2015 to create a licensing requirement for behavioral analysts and is approximately halfway through the process of becoming law. It adopts much of the BACB model act, including BACB certification as a license requirement.

No Governing Body or Licensing Requirement

Colorado

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

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.

The state does have a certification program, however. Florida was the first state to certify behavioral analysts, beginning in 1993 under the auspices of Department of Children and Families. The program administration was assumed by BACB in 2003 and practitioners in Florida are prohibited from calling themselves “Florida Certified Behavior Analysts” unless they participate in the program.

Georgia

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

Idaho

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

Indiana

Though no state licensing laws are in place, Indiana prohibits individuals from describing themselves as behavior analysts without possessing BCBA® certification.

Iowa

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.

Minnesota

Minnesota does not license behavior analysts but does outline required qualifications for analysts providing rehabilitation treatment services. This does not include national certification but does require advanced schooling.

Montana

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

Nebraska

A proposal to license behavioral analysts was considered but rejected in 2011. Currently, no governing body or licensing laws are in place.

New Hampshire

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

New Jersey

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

New Mexico

As part of a state plan for defining service provided to special needs individuals, New Mexico recognizes either BCBA® certified practitioners or licensed psychologists as reimbursable for behavioral analyst services.

Pennsylvania

Pennsylvania does not have a separate licensing category for behavioral analysts, but a license for behavior specialists accepts BACB certification as a credential. Licenses are issued by the Department of State Medical Licensing Board.

South Carolina

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

West Virginia

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

Wyoming

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