A Comprehensive Resource for Behavior Analysis Supervisors and Practitioners
Overview
This guide provides a state-by-state summary of behavior analyst licensure laws, supervisor licensure requirements, and the state departments that oversee regulation. As of January 2026, most states with licensure laws require that supervisors hold a same-state license when providing ABA services in that jurisdiction, in addition to BACB certification.
Important: State laws change regularly. This document should be reviewed annually and verified against official state licensing board websites before finalizing supervision agreements or employment decisions.
Key Principles
Same-State Licensure Requirement
In most licensing states, the supervising BCBA must hold that state’s behavior analyst license to legally supervise ABA services delivered within that state, even if they hold BACB certification. BACB certification is typically used as a qualifying credential for state licensure, not as a substitute for it.
Supervisor Qualifications Across States
- Generally require an active, unrestricted state behavior analyst license
- BCBA or BCBA-D certification as primary qualifying credential
- Continuing education and renewal requirements
- Good standing with no disciplinary action or sanctions
Telehealth and Cross-State Practice
While telehealth provisions vary by state, most require that if services are delivered to clients in a particular state, the supervising BCBA must hold that state’s license, unless an explicit exemption or temporary practice allowance applies.
States with Behavior Analyst Licensure (Listed by Category)
CATEGORY 1: License Available, BCBA® Required
These states explicitly require BCBA certification as the primary qualification for licensure.
Alabama
- Licensure Law Enacted: 2014
- Regulatory Body: Alabama Department of Mental Health, Division of Developmental Disabilities
- Supervisor Requirement: Must hold Alabama behavior analyst license; BCBA alone is insufficient
- Supervision Notes: Supervisor must be licensed in Alabama to supervise practice within the state
Hawaii
- Licensure Law Enacted: 2015
- Regulatory Body: Hawaii Department of Commerce & Consumer Affairs, Professional & Vocational Licensing
- Supervisor Requirement: Must hold Hawaii behavior analyst license
- Supervision Notes: BCBA qualifies candidate for licensure but does not permit practice in Hawaii
Kentucky
- Licensure Law Enacted: 2010
- Regulatory Body: Kentucky Applied Behavior Analyst Licensing Board (Public Protection Cabinet)
- Supervisor Requirement: Must hold Kentucky behavior analyst license
- Supervision Notes: Some transitional provisions exist for early licensees; current expectation is Kentucky licensure for all supervisors
Massachusetts
- Licensure Law Enacted: 2013
- Regulatory Body: Board of Registration of Allied Mental Health and Human Services Professionals
- Supervisor Requirement: Must hold Massachusetts behavior analyst license
- Supervision Notes: BCBA used as qualifying credential; supervision of practice in MA requires state licensure
Mississippi
- Licensure Law Enacted: 2015
- Regulatory Body: Mississippi Autism Board and Mississippi Licensing Board for the Practice of Applied Behavioral Analysis
- Supervisor Requirement: Must hold Mississippi behavior analyst license
- Supervision Notes: Supervisors must be licensed in state to oversee ABA services
Missouri
- Licensure Law Enacted: 2010
- Regulatory Body: Missouri Behavior Analyst Advisory Board
- Supervisor Requirement: Must hold Missouri behavior analyst license
- Supervision Notes: BCBA is the primary qualifying credential for state licensure
Nevada
- Licensure Law Enacted: 2009
- Regulatory Body: Board of Psychological Examiners
- Supervisor Requirement: Must hold Nevada behavior analyst license
- Supervision Notes: Behavior analyst regulation falls under the Psychology Board
Oklahoma
- Licensure Law Enacted: 2009
- Regulatory Body: Oklahoma Licensed Behavior Analyst Board
- Supervisor Requirement: Must hold Oklahoma behavior analyst license
- Supervision Notes: Among the earliest licensing states; well-established regulatory framework
Tennessee
- Licensure Law Enacted: 2014
- Regulatory Body: Applied Behavior Analyst Licensing Committee
- Supervisor Requirement: Must hold Tennessee behavior analyst license
- Supervision Notes: Supervisors of TN-based services must be licensed in Tennessee
Virginia
- Licensure Law Enacted: 2012
- Regulatory Body: Board of Medicine – Applied Behavior Analyst Licensure
- Supervisor Requirement: Must hold Virginia behavior analyst license
- Supervision Notes: One of the earlier adopters; clear supervisor licensure requirement
Wisconsin
- Licensure Law Enacted: 2010
- Regulatory Body: Wisconsin Department of Safety and Professional Services – Behavior Analyst Section
- Supervisor Requirement: Must hold Wisconsin behavior analyst license
- Supervision Notes: BCBA is the qualifying credential; state licensure required to practice and supervise
CATEGORY 2: License Available, BCBA® Optional or Integrated
These states offer licensure but may allow alternative qualifying credentials or have BCBA as one pathway among others.
Arizona
- Licensure Law Enacted: 2008
- Regulatory Body: Arizona Board of Psychologist Examiners (Behavior Analyst Committee)
- Supervisor Requirement: Must hold Arizona behavior analyst license for supervising ABA in Arizona
- Supervision Notes: BCBA widely accepted; state licensure is separate requirement
Connecticut
- Licensure Law Enacted: 2013
- Regulatory Body: Connecticut Department of Public Health
- Supervisor Requirement: Must hold Connecticut behavior analyst license
- Supervision Notes: Supervisors of practice in CT must be state-licensed; BCBA qualifies for licensure
Florida
- Licensure Status: Title-use restriction only (no active licensure board as of 2025)
- Regulatory Body: No current state board; formerly Florida Department of Children and Families
- Supervisor Requirement: While not requiring state licensure, insurers typically require BCBA; many employers and payors require licensure from another state
- Supervision Notes: Practice is largely regulated through insurance requirements and insurance credentialing; BCBA-D recommended
Georgia
- Licensure Law Enacted: 2008
- Regulatory Body: Georgia Board of Behavior Analysts (Professional Licensing Boards Division, Secretary of State)
- Supervisor Requirement: Must hold Georgia behavior analyst license
- Supervision Notes: Clear same-state requirement for supervising Georgia-based services
Illinois
- Licensure Law Enacted: 2013
- Regulatory Body: Illinois Department of Financial & Professional Regulation (IDFPR) – Division of Professional Regulation
- Supervisor Requirement: Must hold Illinois behavior analyst license
- Supervision Notes: Supervisors must be state-licensed to oversee ABA services delivered in Illinois
Indiana
- Licensure Law Enacted: 2012
- Regulatory Body: Indiana Medical Licensing Board
- Supervisor Requirement: Must hold Indiana behavior analyst license
- Supervision Notes: Behavior analyst regulation overseen by medical licensing board
Iowa
- Licensure Law Enacted: 2015
- Regulatory Body: Iowa Board of Behavioral Analysis
- Supervisor Requirement: Must hold Iowa behavior analyst license
- Supervision Notes: Among more recent licensure states; clear supervisor requirements
Maryland
- Licensure Law Enacted: 2009
- Regulatory Body: Maryland Board of Professional Counselors and Therapists
- Supervisor Requirement: Must hold Maryland behavior analyst license
- Supervision Notes: BCBA accepted toward licensure; state licensure required for practice
Michigan
- Licensure Law Enacted: 2021
- Regulatory Body: Michigan Department of Licensing and Regulatory Affairs (LARA)
- Supervisor Requirement: Must hold Michigan behavior analyst license
- Supervision Notes: Relatively recent licensure adoption; implementation still evolving
Minnesota
- Licensure Law Enacted: 2015
- Regulatory Body: Minnesota Board of Behavioral Analysis
- Supervisor Requirement: Must hold Minnesota behavior analyst license
- Supervision Notes: Supervisors must be licensed in Minnesota to oversee state-based services
Missouri (see Category 1)
New Jersey
- Licensure Law Enacted: 2020
- Regulatory Body: State Board of Applied Behavior Analyst Examiners (Division of Consumer Affairs)
- Supervisor Requirement: Must hold New Jersey BA license once fully implemented
- Supervision Notes: Relatively recent law; BCBA alone is not sufficient; state license required
New York
- Licensure Law Enacted: 2014
- Regulatory Body: New York State Education Department, Office of the Professions – State Board for Applied Behavior Analysis
- Supervisor Requirement: To supervise ABA practice in New York (including graduate permit holders), supervisor must be a Licensed Behavior Analyst (LBA) in New York
- Supervision Notes: BCBA certification alone is NOT sufficient. New York requires its own LBA credential. Supervisors must be New York LBAs.
North Carolina
- Licensure Law Enacted: 2013
- Regulatory Body: North Carolina Behavior Analyst Licensure Board
- Supervisor Requirement: Must hold North Carolina behavior analyst license
- Supervision Notes: Supervisors must be licensed in NC for services delivered in state
North Dakota
- Licensure Law Enacted: 2011
- Regulatory Body: North Dakota State Board of Psychologist Examiners
- Supervisor Requirement: Must hold North Dakota behavior analyst license
- Supervision Notes: Behavior analyst regulation falls under psychology board
Ohio
- Licensure Law Enacted: 2011
- Regulatory Body: Ohio Board of Psychology – Behavior Analyst Licensure
- Supervisor Requirement: Must hold Ohio behavior analyst license
- Supervision Notes: Board rules distinguish BCBA vs. non-BCBA applicants; licensure required
Oregon
- Licensure Law Enacted: 2015
- Regulatory Body: Oregon Behavior Analysis Regulatory Board (Oregon Health Licensing Office)
- Supervisor Requirement: Must hold Oregon behavior analyst license
- Supervision Notes: Supervisors must be licensed by the Oregon regulatory board
Pennsylvania
- Licensure Status: No dedicated behavior analyst license; practice regulated under “Behavior Specialist” license
- Regulatory Body: Pennsylvania State Board of Medicine
- Supervisor Requirement: Must hold appropriate Pennsylvania license (Behavior Specialist or equivalent qualifying credential)
- Supervision Notes: Supervisors must hold the appropriate PA license; BCBA alone is not a Pennsylvania practice credential
Rhode Island
- Licensure Law Enacted: 2012
- Regulatory Body: Rhode Island Department of Health – Behavioral Analysis Unit
- Supervisor Requirement: Must hold Rhode Island behavior analyst license
- Supervision Notes: Supervisors must be licensed in Rhode Island
South Dakota
- Licensure Law Enacted: 2022
- Regulatory Body: South Dakota Board of Behavior Analysis
- Supervisor Requirement: Must hold South Dakota behavior analyst license
- Supervision Notes: Among the most recent licensure states
Texas
- Licensure Law Enacted: 2015
- Regulatory Body: Texas Department of Licensing and Regulation (TDLR) – Behavior Analyst Program
- Supervisor Requirement: Must hold Texas behavior analyst license
- Supervision Notes: Supervisors overseeing ABA in TX must be licensed behavior analysts in Texas
Utah
- Licensure Law Enacted: 2017
- Regulatory Body: Utah Division of Professional Licensing – Behavior Analyst Program
- Supervisor Requirement: Must hold Utah behavior analyst license
- Supervision Notes: Supervisors must be licensed in Utah to oversee state-based services
Washington
- Licensure Law Enacted: 2015
- Regulatory Body: Washington State Department of Health – Behavior Analyst Program
- Supervisor Requirement: Must hold Washington behavior analyst license
- Supervision Notes: Supervisors typically must hold Washington license; some alternate qualification paths exist
CATEGORY 3: No State Licensure for Behavior Analysts
These states have not enacted behavior analyst licensure laws but may have insurance or Medicaid requirements.
Arkansas
- Status: Behavior analysts fall under Licensed Professional Counselor (LPC) regulations
- Regulatory Body: Arkansas Board of Examiners in Counseling
- Notes: Behavioral Analysts recognized as a specialization; BACB guidelines followed; practice not separately licensed
California
- Status: No current licensure or dedicated regulation
- Notes: Assembly Bill 1715 (introduced 2016) was withdrawn; no recent licensure bills proposed
Colorado
- Status: No dedicated licensure; falls under general psychotherapy oversight
- Notes: 2020 Sunrise Review found ABA falls under legal definition of “psychotherapy”; practitioners not required to register as unlicensed psychotherapists unless they engage in psychotherapy practice
Delaware
- Status: No separate behavior analyst regulation
- Notes: State regulations for autism service providers recognize BACB certification as sole qualification for service providers; autism care statutes reference BACB certification
District of Columbia
- Status: No licensing requirements or direct regulation
- Notes: DC Department on Disability Services recognizes BCBA as authorized to provide behavior support services eligible for Medicaid reimbursement when supervised by psychiatrists, psychologists, APRNs, or LICSWs
Idaho
- Status: No governing body or licensing laws
- Notes: No regulation or pending legislation at this time
Maine
- Status: No state licensure
- Notes: Insurance codes require national board certification (BCBA) for insurer compensation
New Hampshire
- Status: No state licensure
- Notes: Connor’s Law requires state-regulated health insurance plans to cover ABA provided by BCBA-certified professionals or under BCBA supervision
New Mexico
- Status: No state licensure
- Notes: Medicaid requires providers delivering ABA through Medical Assistance Program to hold BCBA® or BCBA-D® certification
South Carolina
- Status: No state licensure
- Notes: As of 2019, Medicaid requires all supervisory and direct therapy ABA providers to be credentialed through BACB
West Virginia
- Status: No state licensure
- Notes: 2012 Sunrise Report found that BACB oversight provided adequate protection; no state licensing structure implemented
Summary Table: Quick Reference
State Licensure? Supervisor Must Hold State License? Regulatory Body Alabama Yes (2014) Yes AL Dept. of Mental Health Arizona Yes (2008) Yes AZ Board of Psychologist Examiners Arkansas LPC-based No separate BA license AR Board of Examiners in Counseling California No N/A N/A Colorado No N/A N/A Connecticut Yes (2013) Yes CT Dept. of Public Health Delaware No N/A N/A District of Columbia No N/A N/A Florida Title-use only Varies by payor No active state board Georgia Yes (2008) Yes GA Board of Behavior Analysts Hawaii Yes (2015) Yes HI Dept. of Commerce & Consumer Affairs Idaho No N/A N/A Illinois Yes (2013) Yes IL Dept. of Financial & Professional Regulation Indiana Yes (2012) Yes IN Medical Licensing Board Iowa Yes (2015) Yes IA Board of Behavioral Analysis Kentucky Yes (2010) Yes KY Applied Behavior Analyst Licensing Board Maine No N/A N/A Maryland Yes (2009) Yes MD Board of Professional Counselors and Therapists Massachusetts Yes (2013) Yes MA Board of Allied Mental Health Professionals Michigan Yes (2021) Yes MI LARA Minnesota Yes (2015) Yes MN Board of Behavioral Analysis Mississippi Yes (2015) Yes MS Licensing Board for Practice of ABA Missouri Yes (2010) Yes MO Behavior Analyst Advisory Board Nevada Yes (2009) Yes NV Board of Psychological Examiners New Hampshire No N/A N/A New Jersey Yes (2020) Yes (when fully implemented) NJ State Board of Applied Behavior Analyst Examiners New Mexico No BCBA required by Medicaid N/A New York Yes (2014) Yes – NY LBA required NY State Education Dept., Office of Professions North Carolina Yes (2013) Yes NC Behavior Analyst Licensure Board North Dakota Yes (2011) Yes ND State Board of Psychologist Examiners Ohio Yes (2011) Yes OH Board of Psychology Oklahoma Yes (2009) Yes OK Licensed Behavior Analyst Board Oregon Yes (2015) Yes OR Behavior Analysis Regulatory Board Pennsylvania Behavior Specialist license Yes – PA license required PA State Board of Medicine Rhode Island Yes (2012) Yes RI Dept. of Health South Carolina No BCBA required by Medicaid N/A South Dakota Yes (2022) Yes SD Board of Behavior Analysis Tennessee Yes (2014) Yes TN Applied Behavior Analyst Licensing Committee Texas Yes (2015) Yes TX Dept. of Licensing & Regulation (TDLR) Utah Yes (2017) Yes UT Division of Professional Licensing Virginia Yes (2012) Yes VA Board of Medicine Washington Yes (2015) Yes WA Dept. of Health West Virginia No N/A N/A Wisconsin Yes (2010) Yes WI Dept. of Safety & Professional Services
Best Practices for Multi-State Supervision
Verify Licensure Status Before Hiring or Contracting Supervisors
- Confirm supervisor holds the required state license in each state where services will be delivered
- Verify current, active status (not expired or suspended)
- Document verification in supervisor credentialing file
- Request current licensure copies for compliance files
Establish Clear Supervision Agreements
- Specify which states the supervisor will oversee services in
- Confirm supervisor’s licensure in each specified state
- Include renewal and maintenance requirements in contract
- Outline process for addressing license renewal near expiration
Maintain Compliance Documentation
- Keep copies of all supervisor licenses by state
- Track renewal dates and send reminders
- Document that services align with state-specific requirements
- Review this guide annually and update policies as laws change
Address Telehealth and Remote Services
- Determine state where client receives services (primary jurisdiction)
- Confirm supervisor holds license in that state
- Document client location in clinical records
- Verify insurance/payor requirements for supervisor licensure
- Stay informed about any temporary telehealth exceptions or waivers
Resources for Ongoing Compliance
Official Regulatory Organizations
- BACB (Behavior Analyst Certification Board): bacb.com – National certification, model act, licensure updates
- BACB Licensure Map: bacb.com/u-s-licensure-of-behavior-analysts/ – Updated state-by-state information
Finding Your State’s Regulatory Board
Most states’ behavioral analyst boards are located within:
- Department of Health
- Department of Licensing & Regulation
- Medical or Psychology Board
- Consumer Affairs Division
Search your state’s official government website for “[State] + Behavior Analyst Licensing Board” or check with your state’s Department of Health.
Annual Review Checklist
- [ ] Review BACB licensure map for new licensing states
- [ ] Verify current regulations in states where you operate
- [ ] Confirm all supervisor licensure status and renewal dates
- [ ] Update internal policies and supervision agreements
- [ ] Train staff on current multi-state requirements
- [ ] Document compliance verification in personnel files
Important Disclaimers
This guide is provided for informational purposes and represents conditions as of January 2026. Laws and regulations change frequently, and this document may not reflect the most current information.
Before finalizing any supervision arrangement or employment decision:
- Verify directly with your state’s behavior analyst regulatory board
- Check official state licensing board websites
- Consult with your organization’s compliance or legal team
- Review current payor (insurance/Medicaid) requirements
- Confirm any updates since this guide was created
This guide does not constitute legal or regulatory advice. Organizations should maintain active monitoring of licensure requirements and regulatory changes in their operating states.
Document Last Updated: January 2026
Recommended Review Date: January 2027
For questions or to report updates needed to this guide, contact your state’s behavior analyst licensing board or the BACB at bacb.com.
