Special Learning · Field guide · Pennsylvania · September 3, 2026
Posted on r/ABA, April 4, 2023, by someone hiring in eastern Pennsylvania: “We need BCs, BCBAs, MTs, BHTs, and RBTs like asap. We have 40 kids on our waitlist. You don't have to be ABA-certified, especially if you're looking for a BHT/RBT position, they train.” source
How to become a BHT or BHT-ABA in Pennsylvania's IBHS program
That hiring post is right, and the regulation says exactly how. Pennsylvania's Intensive Behavioral Health Services (IBHS) rules, 55 Pa. Code Chapter 5240, list six ways to qualify as a behavioral health technician, and only some of them involve a certification. They also say what training you owe once you are hired, how much supervision you are entitled to, and what it takes to move up. Most of it is written for agency licensing staff. This page is written for the person who wants the job, or already has it.
It covers the two IBHS staffing tracks and their role names, the six routes into a BHT or BHT-ABA job, what the BACB's January 2026 RBT change did to the 40-hour certificate, the training hours after hiring, the supervision you should expect, the ladder up to consultant, analyst and clinical director, and what a BCBA or RBT moving into Pennsylvania already satisfies. Every rule is cited to the section it comes from. If you already hold a role and just want your hours, jump to the training hours or the clock on one page.
1. Two tracks, and the regulation's own role names
Asked on r/ABA, May 3, 2025: “Wondering if anyone else works in the IBHS division in PA. This covers a variety of companies. I'm just wondering what the average pay is. I make $49 as a new BCBA, which is a huge set up from when I was just a BC.” source
The regulation sets who may hold each role, how they are trained and how they are supervised. It does not set pay, and we don't publish pay figures we haven't sourced. What it does settle is the alphabet soup in that post. IBHS staffing runs on two tracks, and each track has its own qualification section and its own training section: (§§ 5240.71, 5240.73, 5240.81, 5240.83)
| Individual services track | ABA services track | |
|---|---|---|
| Who may be hired | § 5240.71 | § 5240.81 |
| Training once hired | § 5240.73 | § 5240.83 |
| Supervision | § 5240.72 | § 5240.82 |
| Front-line role | Behavioral health technician (BHT) | BHT-ABA |
| Clinician roles | Behavior consultant (BC) and mobile therapist (MT) | Behavior analytic services; behavior consultation–ABA; assistant behavior consultation–ABA |
The shorthand you will hear in agencies, “BC-ABA” and “BSC-ABA,” is not in the regulation. The regulation's own names are behavior analytic services, behavior consultation–ABA services, assistant behavior consultation–ABA services and BHT-ABA services. (§ 5240.81(d)–(g)) When a job posting says BC-ABA, ask which of those four the agency means, because the qualifications differ.
What the front-line roles are allowed to do is also written down. A BHT-ABA's job is “implementing the ITP,” and an assistant or BHT-ABA “may not provide interventions requiring skills, experience, credentials or licensure that the individual does not possess.” (§ 5240.87(d), (e)) The technician follows the plan; the analyst writes it. That sentence protects you as much as it protects the child.
From hired to independent, and every year after
Four steps for a BHT or BHT-ABA — and the number Pennsylvania’s own rules put on each one.
Qualify — one of six routes
An RBT, BCaBA or BCAT certification; another NCCA- or ANSI-accredited behavior certification; a high-school diploma plus a 40-hour RBT training whose certificate names a BCBA or BCaBA as responsible trainer; or two years of experience (behavioral health for a BHT; ABA plus 40 hours of training for a BHT-ABA).
Before you work independently (new to BHT work)
30 hours of training on eight named topics — mandated reporting, crisis and de-escalation, behavior management, child development, serious emotional disturbance, ethics and confidentiality, first aid and universal precautions, psychotropic medications — plus 6 hours of onsite supervision while you deliver services.
Your first six months (new to BHT work)
24 more hours on eleven topics — documentation, systems of care, functional behavioral assessment, culture and language, family engagement and family systems, community resources, cross-systems work, communication and conflict resolution, IEP basics, restrictive procedures. College coursework can substitute where your transcript shows the topic.
Every year after that
20 hours of training tied to your job functions and your training plan (a BHT-ABA’s must relate to ABA). One hour of supervision a week at 37.5 hours or more (twice a month below that), at least one hour a month individual and face-to-face, and an hour of direct observation every four months, or every two if you qualified by the 40-hour route. Certification and license maintenance hours may be applied to the 20.
Every number on this chart is Pennsylvania’s, not ours. Each one is cited to the section of 55 Pa. Code that sets it, so you can check it and quote it back. If your personnel file does not show the supervision, that is the agency’s licensing problem, not yours.
2. Six ways to qualify as a BHT (individual services)
Since January 1, 2021, a person providing individual services as a BHT must meet one of the following: (§ 5240.71(d))
- “Have a certification as a BCaBA.”
- “Have a certification as an RBT.”
- “Have a certification as a BCAT.”
- “Have a behavior health certification or behavior analysis certification from an organization that is accredited by the National Commission for Certifying Agencies or the American National Standards Institute.”
- “Have a high school diploma or the equivalent of a high school diploma and have completed a 40-hour training covering the RBT Task List as evidenced by a certification that includes the name of the responsible trainer, who is certified as a BCBA or BCaBA.”
- “Have a minimum of 2 years of experience in the provision of behavioral health services.”
Plain read: you do not need a college degree, and you do not need to be an RBT. Route 5 is a high-school diploma plus a documented 40-hour training whose certificate names a BCBA or BCaBA as the responsible trainer. Route 6 is two years of behavioral-health experience with no training requirement attached at all. That is what the hiring post meant by “they train.”
3. Six ways to qualify as a BHT-ABA (ABA services)
The ABA-track list is nearly identical, with one difference at the end. A BHT-ABA must meet one of the following: (§ 5240.81(g))
- “Have a certification as a BCaBA.”
- “Have a certification as an RBT.”
- “Have a certification as a BCAT.”
- “Have a behavior analysis certification from an organization that is accredited by the National Commission for Certifying Agencies or the American National Standards Institute.”
- “Have a high school diploma or the equivalent of a high school diploma and have completed a 40-hour training covering the RBT Task List as evidenced by a certification that includes the name of the responsible trainer, who is certified as a BCBA or BCaBA.”
- “Have a minimum of 2 years of experience in providing ABA services and a minimum of 40 hours of training related to ABA approved by the Department or provided by a continuing education provider approved by the Behavior Analyst Certification Board.”
The difference: on the ABA track, the experience route asks for two years of ABA experience plus 40 hours of approved ABA training. On the individual-services track, two years of behavioral-health experience is enough on its own. If you are moving from a wraparound BHT job into an ABA team on experience alone, that 40 hours is the gap to close.
4. The 2026 RBT change, and what Pennsylvania says about your certificate
Route 5 in both lists says “a 40-hour training covering the RBT Task List.” The regulation names no edition of that Task List; the word “edition” does not appear in either section. (§§ 5240.71(d)(5), 5240.81(g)(5), read in full) Meanwhile the BACB retired the Task List name altogether. Effective January 1, 2026, RBT training follows the RBT Test Content Outline (3rd ed.) and the RBT 2026 40-Hour Training Requirements and Curriculum Outline. (BACB RBT Handbook, updated 06/2026)
So which one does a Pennsylvania licensing inspector want to see? The state answered that on April 2, 2026, in a letter from the Office of Mental Health and Substance Abuse Services (OMHSAS) to every IBHS provider. The letter is guidance, not a regulation amendment, and it is unusually plain. It says:
- “Training content is now referred to as the RBT Test Content Outline (3rd ed.), replacing the previous RBT Task List (2nd ed.). The regulations now have outdated language by referring to the RBT task List.”
- “Training materials referencing the 2nd edition Task List or certificates dated before January 1, 2026, are now considered outdated.”
- “OMHSAS is taking this time to affirm that meeting the BACB standards, referenced as certification in the three regulatory requirements above, is the standard OMHSAS is looking for.”
- “Existing BHT/BHT-ABA staff should be updating their training to be in compliance with 3rd edition training within one year of holding a 2nd edition training certificate.”
- “BHT/BHT-ABAs switching agencies now may not have the newly required training. If staff were trained under the 2nd edition Task List at a previous agency, it does not preclude them from being hired in 2026, but the new provider should have a plan in place for the BHT/BHT-ABA staff to acquire the new 3rd edition training within the year.”
- “New hires without prior BHT/BHT-ABA experience ... should be trained using the 3rd edition curriculum.”
- “Licensing staff will review these new RBT certificates for compliance.”
PA DHS/OMHSAS letter to IBHS providers, April 2, 2026.
What that means for you. If your 40-hour certificate is dated before January 1, 2026 or was built on the 2nd edition, it still got you hired and it does not disqualify you. But the state expects you to complete a 3rd-edition training within a year, and your agency is expected to have a plan for that. If you are starting from scratch in 2026, take a 3rd-edition course from the start.
The sentence to look for on a new certificate. The BACB now requires 2026 training certificates to carry this exact language, and the OMHSAS letter says licensing staff will check for it: “This training program is designed to meet the 2026 training eligibility requirement for RBT certification. The training is offered independent of the BACB.” Pennsylvania adds its own requirement on top: the certificate must also name the responsible trainer, who must be a BCBA or BCaBA. (§ 5240.81(g)(5); OMHSAS letter, April 2, 2026) A certificate missing either the sentence or the trainer's name is the thing an inspector will flag.
5. Becoming an RBT: the BACB's own list
You do not have to be an RBT to work as a BHT or BHT-ABA in Pennsylvania (routes 5 and 6 above). But an RBT certification qualifies you outright (route 2), it travels to other states, and most ABA employers prefer it. The BACB's eligibility list, in its own words: (BACB RBT Handbook, Eligibility Requirements, updated 06/2026)
- Age: “You must be at least 18 years old when you submit your RBT certification application.”
- Education: “You must have at least a high school-level education or the equivalent.”
- Background checks: a criminal background check and an abuse registry check, each “no more than 180 days before paying for your RBT certification application,” and each “comparable to those required for home health aides, child care professionals, and teachers in the community where you will provide services.” The BACB does not require fingerprinting; your state or employer may.
- Training: “a 40-hour training that meets the requirements described in the RBT 2026 40-Hour Training Requirements and Curriculum Outline in no less than 5 days and no more than 180 days.” The BACB itself does not provide the training or recommend providers.
- Initial Competency Assessment: after the 40 hours and “no more than 90 days before you submit an RBT certification application,” you demonstrate the tasks on the RBT Initial Competency Assessment: Effective January 1, 2026 with a responsible assessor.
- Then you apply, and take and pass the RBT exam.
Once certified, an RBT must keep up the BACB's ongoing requirements, including supervision, and the OMHSAS letter says Pennsylvania expects that too: “Staff who hold active RBT certification must follow current BACB requirements for ongoing certification.”
6. Training hours once you're hired
Qualifying to be hired and training after you are hired are two different sections, and the second one is where most confusion lives.
If you have never worked as a BHT before
Both tracks send a new BHT or BHT-ABA to the same on-ramp: (§ 5240.73(c), (d); § 5240.83(d)(1))
- At least 30 hours before working independently, covering eight topics: the Child Protective Services Law and mandated reporting; crisis intervention, de-escalation and safety planning; behavior management and coaching; child and adolescent development; serious emotional disturbance and related needs; professional ethics, conduct and confidentiality; first aid, universal precautions and safety; and psychotropic medications and their side effects.
- At least 24 more hours within the first six months, covering eleven topics: documentation; systems of care; an overview of functional behavioral assessment; ethnic, cultural and linguistic considerations; engaging children and families, including family systems theory; skills for working with families; community resources and youth-serving systems; cross-systems collaboration; communication and conflict resolution; basic IEP and special-education information; and the safe use of restrictive procedures under § 5240.6.
Two details matter. First, this on-ramp binds only someone who “has not previously provided BHT services.” If you have done the job before, at any agency, you are outside it and inside the annual requirement below. Second, college coursework can substitute for individual topics if your transcript shows the topic was covered. (§ 5240.73(f))
Every year after that
| Role | Annual hours | Who may provide it | Section |
|---|---|---|---|
| BHT (individual services) | 20 | Department-approved only | § 5240.73(e) |
| BHT-ABA | 20, related to ABA | Department-approved. The regulation also accepts a BACB ACE provider. | § 5240.83(d)(2) |
| Behavior consultant or mobile therapist | 16 | Department-approved only | § 5240.73(b) |
| Assistant behavior consultation–ABA | 20, plus 20 before working independently if you hold no behavior-analysis certification | Department-approved. The regulation also accepts a BACB ACE provider. | § 5240.83(c) |
| Behavior analytic services; behavior consultation–ABA | 16 | Department-approved. The regulation also accepts a BACB ACE provider. | § 5240.83(b) |
All of it must relate to your specific job functions and follow the individual training plan your agency is required to keep for you. (§ 5240.13)
If you hold a certification or a Pennsylvania license, your maintenance hours count. “An individual who is certified may count hours of training required to maintain certification towards the training requirement,” and the same for licensure. (§ 5240.73(g), (h); § 5240.83(e), (f)) An RBT's professional-development hours and a BCBA's continuing-education units are not a second pile of hours on top of the IBHS requirement; the regulation lets them be applied to it.
7. The supervision you are entitled to
Supervision in IBHS is a minimum written into the regulation, not a favor from your supervisor. For a BHT on the individual-services track and a BHT-ABA on the ABA track the numbers are the same: (§ 5240.72(b); § 5240.82(c))
- One hour of supervision every week if you work at least 37.5 hours a week, or one hour twice a month if you work less. At least one hour a month must be individual and face-to-face.
- Six hours of onsite supervision while you deliver services, before you work independently, if you have never done the job before.
- Direct observation of you working with a child: one hour every four months, or one hour every two months if you qualified through the 40-hour training route rather than a certification.
- Each session must cover the interventions being implemented, the child's progress toward the treatment-plan goals, whether the plan needs adjusting, and your skill in implementing it.
Face-to-face supervision may happen over secure, real-time two-way video. (§ 5240.72(e); § 5240.82(g)) A supervisor may carry at most 12 full-time-equivalent staff, of whom no more than nine may be BHTs or BHT-ABAs, and group supervision is capped the same way. (§ 5240.72(c), (d); § 5240.82(d), (e)) On the ABA track, “a supervisor shall be available to consult with staff during the hours that ABA services are being provided, including evenings and weekends.” (§ 5240.82(f)) Every session goes into your personnel file with the date, modality, format, start and end time, a narrative summary, and both signatures. (§ 5240.82(h)) If your file does not show that, the agency has a licensing problem, not you.
Who may supervise you on the ABA track: someone qualified as a clinical director or for behavior analytic or behavior consultation–ABA services, or an assistant behavior consultation–ABA provider who holds a BCaBA or an equivalent accredited undergraduate certification. (§ 5240.82(c))
8. Moving up: assistant, consultant, analyst, clinical director
Each rung has its own subsection in § 5240.81, and most rungs have more than one way in.
Assistant behavior consultation–ABA (§ 5240.81(f))
One of: the qualifications for a Pennsylvania behavior specialist license except its experience requirement (see section 9); a BCaBA or equivalent accredited undergraduate certification plus a bachelor's degree in psychology, social work, counseling, education or a related field; or six months of ABA experience plus that bachelor's degree plus 12 college credits in ABA.
Behavior consultation–ABA (§ 5240.81(e))
A Pennsylvania license as one of the named professions (psychologist, professional counselor, marriage and family therapist, clinical social worker, social worker, behavior specialist, certified registered nurse practitioner, or another profession whose scope includes overseeing ABA) plus one of: a BCaBA or equivalent; one year of full-time ABA experience and 12 ABA credits; or one year of full-time ABA experience under a BCBA's supervision and 40 hours of approved ABA training. A licensed psychologist with one year of ABA experience and 40 hours of training also qualifies.
Behavior analytic services (§ 5240.81(d))
A Pennsylvania license as one of the professions above and “a certification as a BCBA or other graduate-level certification in behavior analysis” that is NCCA- or ANSI-accredited. Both halves are required. This is the role that carries clinical direction of the ABA case, writes and revises the treatment plan, and oversees its implementation. (§ 5240.87(a))
Clinical director of an agency providing ABA services (§ 5240.81(c), in force since July 1, 2022)
One of: a Pennsylvania license in one of the named professions plus a BCBA or equivalent graduate-level certification plus two years of ABA experience; a licensed psychologist with five years of full-time experience overseeing an ABA program and 40 hours of approved ABA training; or a licensed psychologist with a graduate degree or graduate certificate in ABA.
Clinical roles on the individual-services track (§ 5240.71(a)–(c))
A behavior consultant qualifies through a behavior specialist license, a BCBA or equivalent, a graduate degree in ABA, or a graduate degree in psychology, social work, education or counseling with either a year of children's mental-health experience or a clinical practicum. But if the behavior consultant is treating children diagnosed with autism for that autism, the regulation requires a Pennsylvania license in one of the named professions. (§ 5240.71(b)) Mobile therapists must hold a Pennsylvania clinical license or a social-work or behavior-specialist license with a practicum-based graduate degree, or a graduate degree with at least nine clinical credits plus experience or a practicum. (§ 5240.71(c))
9. The behavior specialist license, and why a BCBA alone is not a Pennsylvania license
You will notice the word licensed keeps appearing next to the word certified. They are different things in Pennsylvania, and the regulation asks for both at the analyst and consultant levels. A BCBA is a certification issued by the BACB. A license is issued by the Commonwealth. Pennsylvania has no behavior-analyst license; the BACB's own table of state licensure laws does not list Pennsylvania. What Pennsylvania has is the behavior specialist license, issued by the State Board of Medicine under 49 Pa. Code Chapter 18. A BCBA who moves to Pennsylvania with no state license meets the certification half of § 5240.81(d) and not the license half.
The criteria for the behavior specialist license: (49 Pa. Code § 18.524)
- A master's or higher degree with a major in school, clinical, developmental or counseling psychology; special education; social work; speech therapy; occupational therapy; professional counseling; behavioral analysis; nursing; or another related field.
- “At least 1 year of experience involving functional behavior assessments of individuals under 21 years of age, including the development and implementation of behavioral supports or treatment plans.”
- “At least 1,000 hours of in-person clinical experience with individuals with behavioral challenges or at least 1,000 hours of experience in a related field with individuals with autism spectrum disorders.”
- 90 hours of coursework in evidence-based practices, from an accredited college or university, or training that the Behavior Analyst Certification Board or the Bureau of Autism Services has approved, broken down as: 3 hours of professional ethics approved by the Bureau; 18 hours autism-specific; 16 hours on assessments; 16 hours on instructional strategies and best practices; 8 hours on crisis intervention; 8 hours on comorbidity and medications; 5 hours on family collaboration; and 16 hours on addressing specific skill deficits. The coursework may be face-to-face or online. (§ 18.524(d), (e))
Note that the assistant behavior consultation–ABA route in § 5240.81(f)(1) borrows this list minus the 1,000-hour requirement, which is why a new master's graduate with the 90 hours of coursework and a year of FBA experience can start at the assistant level while working toward the license.
10. Already an RBT or BCBA and moving to Pennsylvania?
- A current RBT qualifies as a BHT and as a BHT-ABA outright. (§ 5240.71(d)(2); § 5240.81(g)(2)) The regulation lets you apply your BACB maintenance hours to the annual IBHS training requirement. (§ 5240.73(g); § 5240.83(e)) Keep your certification current; the OMHSAS letter says the state expects it.
- A current BCaBA qualifies as a BHT or BHT-ABA outright, and, with a bachelor's degree in a listed field, at the assistant behavior consultation–ABA level. (§ 5240.81(f)(2)) With a Pennsylvania license in a named profession, at the behavior consultation–ABA level. (§ 5240.81(e)(1)(i))
- A current BCBA satisfies the certification half of behavior analytic services and of the clinical director role, but both also require a Pennsylvania license in one of the named professions. (§ 5240.81(c), (d)) On the individual-services track, a BCBA alone qualifies as a behavior consultant, unless the work is treating children diagnosed with autism for that autism, which again requires the license. (§ 5240.71(a)(2), (b)) The regulation lets you apply your continuing-education units to the IBHS annual requirement. (§ 5240.83(e))
- If you supervise, the regulation's caseload caps and documentation rules in section 7 apply to you from day one.
11. Where Special Learning fits
Special Learning is a BACB Authorized Continuing Education (ACE) provider, number OP-14-2437, with Maria Nicolaou as the ACE Coordinator of record. Authorization as an ACE Provider does not imply endorsement or approval of the ACE event content by the BACB. That matters in Pennsylvania for a specific reason. The Department's own document on how IBHS training gets approved tells agencies to first check whether a training “is already considered approved by the Department,” and its list of “IBHS Trainings that Do Not Require Department Review and Approval” includes “Trainings offered by a Behavior Analyst Certification Board (BACB) Authorized Continuing Education (ACE) provider.” (PA DHS, IBHS Department Approval Training Process)
Our Pennsylvania IBHS training is built specifically for the PA IBHS training requirements and designed for BHT staff serving PA IBHS programs. It is clinically reviewed and signed off. We have two plain-English pages for the agency side of this, one on training hours by role under § 5240 and one on who needs which training, plus a free IBHS readiness checklist for agencies. Each agency remains responsible for verifying that its staff training meets its own licensure obligations. If your agency asks whether a Special Learning course fits a specific line in your training plan, send them this page and the Department's document; the agency makes that call against its own plan.
If you are looking for a 3rd-edition 40-hour RBT course, ask any provider two questions before you pay: does the certificate carry the BACB's required 2026 sentence, and does it name a BCBA or BCaBA as the responsible trainer. Those are the two things a Pennsylvania inspector will look for. (§ 5240.81(g)(5); OMHSAS letter, April 2, 2026)
12. The clock, on one page
| When | What | Section |
|---|---|---|
| Before you are hired | Meet one of the six BHT or BHT-ABA routes | § 5240.71(d); § 5240.81(g) |
| Before working independently (new to BHT work) | 30 hours of training on eight topics; 6 hours of onsite supervision | § 5240.73(c); § 5240.72(b)(2); § 5240.82(c)(2) |
| First 6 months (new to BHT work) | 24 more hours on eleven topics | § 5240.73(d) |
| Every week (or twice a month if under 37.5 hours) | One hour of supervision; at least one hour a month individual and face-to-face | § 5240.72(b)(1); § 5240.82(c)(1) |
| Every 4 months (every 2 months if you qualified by the 40-hour route) | One hour of direct observation | § 5240.72(b)(3); § 5240.82(c)(3) |
| Every year | 20 hours of training (BHT and BHT-ABA); 16 for consultants, therapists and analysts | § 5240.73(b), (e); § 5240.83(b), (d) |
| Within one year of a 2nd-edition certificate | Complete 3rd-edition RBT training (state guidance, not regulation text) | OMHSAS letter, April 2, 2026 |
| Ongoing, if you are an RBT | Current BACB requirements, including supervision and professional development | OMHSAS letter; BACB RBT Handbook |
13. Sources
- 55 Pa. Code Chapter 5240, Intensive Behavioral Health Services: staff training plan § 5240.13; individual-services qualifications, supervision and training §§ 5240.71, 5240.72, 5240.73; ABA-services qualifications, supervision and training §§ 5240.81, 5240.82, 5240.83; ABA service roles § 5240.87. Consolidated text effective through 56 Pa.B. 3438 (June 6, 2026). https://www.pacodeandbulletin.gov/Display/pacode?file=/secure/pacode/data/055/chapter5240/chap5240toc.html
- 49 Pa. Code § 18.524, Criteria for licensure as behavior specialist (State Board of Medicine). https://www.pacodeandbulletin.gov/Display/pacode?file=/secure/pacode/data/049/chapter18/s18.524.html
- PA Department of Human Services, Office of Mental Health and Substance Abuse Services. Letter to IBHS providers on BACB training updates, April 2, 2026. https://www.pa.gov/content/dam/copapwp-pagov/en/dhs/documents/healthchoices/hc-providers/documents/2026-04-02-bacb-training-updates-for-ibhs-providers.pdf
- PA Department of Human Services. IBHS Department Approval Training Process. https://www.pa.gov/content/dam/copapwp-pagov/en/dhs/documents/healthchoices/hc-providers/documents/IBHS%20Department%20Approval%20Training%20Process.pdf
- PA Department of Human Services. Intensive Behavioral Health Services (IBHS) page. https://www.pa.gov/agencies/dhs/resources/medicaid/bhc/ibhs
- Behavior Analyst Certification Board. Registered Behavior Technician Handbook, updated June 2026 (Eligibility Requirements; Applying to Become an RBT). https://www.bacb.com/rbt/
- Behavior Analyst Certification Board. U.S. Licensure of Behavior Analysts (state table). https://www.bacb.com/u-s-licensure-of-behavior-analysts/
Written for Special Learning. Clinical review: Camila Sandoval (AI), Chief Clinical Officer. Regulations, the OMHSAS letter, the Department's approval-process document and the BACB handbook were read at source on September 2 and 3, 2026; the state's documents are the record and this page is the map. This page explains the rules; it isn't legal advice, and your agency's license and your own certification body govern your obligations. Report an error to info@special-learning.com and we will fix the page, not argue with you.