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ABA licensure by state

Do you need a license to practice ABA in the District of Columbia? What District law says

The short answer

District of Columbia law provides for licensing behavior analysts through the Board of Psychology. The Board's September 25, 2026 minutes report that behavior analyst regulations were under internal review at DC Health. Confirm current licensing requirements and application availability with DC Health, Board of Psychology, before you rely on this.

What we found

On October 30, 2026, we read the District of Columbia Official Code, Title 3, Chapter 12 (the Health Occupations Revision Act) on the D.C. Council's code site, including every section that mentions behavior analysis. We read the section headings for the District's psychology regulations (17 DCMR Chapter 69), DC Health's Psychology Licensing page, and the Board of Psychology's posted agendas and minutes from January 2025 through September 25, 2026. We did not find an adopted regulation for behavior analysts, and we did not find a behavior analyst application on DC Health's pages.

What the District of Columbia does have

### A 2024 law that creates a behavior analyst license The Health Occupations Revision General Amendment Act of 2024 (D.C. Law 25-191) added behavior analysis to the Health Occupations Revision Act. The Code defines the practice this way:

"“Practice of behavior analysis” means the design, implementation, and evaluation of environmental modifications to produce socially significant improvement in human behavior, including the use of direct observation, measurement, and functional analysis of the relationship between environment and behavior."

The Board of Psychology regulates it:

"The Board shall regulate the practice of psychology, the practice by psychology associates, and the practice of behavior analysis."

The law sets these qualifications:

"The Board of Psychology shall license as a behavior analyst a person who, in addition to meeting the requirements of subchapter V of this chapter and any requirements the Mayor may establish by rule, has: (1) Successfully completed a criminal background check; (2) Obtained a current certification issued by the Behavior Analyst Certification Board; and (3) Received a master's degree or higher from a behavior analysis educational program that is accredited by the Behavior Analyst Certification Board; provided, that the Board shall waive this educational requirement if the applicant was certified by the Behavior Analyst Certification Board on or before July 19, 2024."

The law also tells the Mayor to write the rules:

"Within one year of July 19, 2024, the Mayor shall issue rules for the licensure and scope of the practice of behavior analysis, which shall include at a minimum: (A) A code of ethics for the practice of behavior analysis; (B) Criteria for the educational and clinical training of licensed behavior analysts; (C) Criteria for a professional competency examination and testing of applicants for a license to practice behavior analysis; and (D) Continuing education requirements for license renewal."

Source: D.C. Official Code § 3-1207.71; § 3-1202.11; § 3-1201.02.

### What the license-required section says The section that lists which occupations need a District license, registration or certification begins:

"A license issued pursuant to this chapter is required to practice acupuncture, advanced practice registered nursing, assisted living administration, audiology, ..."

It goes on to name other health occupations, including "health services psychology, general applied psychology," and, for registration, "psychology associate, ... school psychologist, speech-language pathology assistant." We read the whole section. It does not name behavior analysis, assistant behavior analysts or behavior technicians. The only other places in Chapter 12 that mention behavior analysis are the definition, the Board of Psychology section and the eligibility section quoted above.

Source: D.C. Official Code § 3-1205.01.

### Where the Board of Psychology's rules stand The Board of Psychology's posted record shows the rules being drafted. Its September 25, 2026 agenda says the draft "included a new section of Title 17 of the DC Municipal Regulations which provides for licensure of behavior analysts, consistent with D.C. Official Code sec. 3-1207.71 and 3-1202.11(f)." It also says: "On July 16, 2026, the Board voted to approve the health services psychologist, general applied psychologist and school psychologist, behavior analysts and psychology associates." The Board's attorney reported at that September 25 meeting:

"... the psychology associate and behavior analyst regulations are currently under internal review at DC Health and will be moving forward. The regulations will be reviewed by other agencies and the Mayor's Office. Finally, it will be under public comment period."

The Board's September 9, 2025 agenda listed an item to review "the Registered Behavior Technician, Licensed Assistant Behavior Analyst and Licensed Applied Behavior Analyst Regulations." The agenda does not give their contents. None of the Chapter 69 section headings we reviewed names behavior analysts. The Board's next scheduled meeting is November 13, 2026.

Source: Board of Psychology agenda, September 25, 2026; minutes, September 25, 2026; agenda, September 9, 2025.pdf); DC Health, Board of Psychology meeting page; 17 DCMR Chapter 69.

### Insurance coverage for children District law requires health insurers to cover habilitative services for children under 21. The chapter says:

"A health insurer shall: (1) Provide coverage of habilitative services for children under the age of 21 years and may do so through a managed care system; (2) Not be required to provide reimbursement for habilitative services actually delivered through early intervention or school services; ..."

It defines "congenital or genetic birth defect" to include "Autism or an autism spectrum disorder." It defines habilitative services as "services, including occupational therapy, physical therapy, and speech therapy, for the treatment of a child with a congenital or genetic birth defect to enhance the child's ability to function." The chapter does not name behavior analysts or ABA. Separately, the District's essential health benefits benchmark section says habilitative services include "applied behavioral analysis for the treatment of autism spectrum disorder." Neither provision names a license or a credential for the provider.

Source: D.C. Official Code § 31-3271; § 31-3272; § 31-3171.09.

### Medicaid In a public notice dated August 18, 2023, the Department of Health Care Finance (DHCF) said it had submitted a State Plan amendment that would allow Medicaid reimbursement for autism treatment services for children and youth, "including applied behavior analysis (ABA) therapy, psychological services, physical therapy, occupational therapy, and speech language pathology and audiology services." Ask DHCF for the current Medicaid provider requirements.

Source: DHCF Transmittal 23-35, August 18, 2023.

Training the staff you supervise

If you run a program in the District of Columbia and need new technicians or aides trained in the basics, this is what our Intro to ABA Level 1 course covers.

The Intro to ABA Level 1 course teaches methods and techniques of Applied Behavior Analysis (ABA) for parents and caregivers, teachers, paraprofessionals and behavior technicians who work with a child every day. Topics include what autism is, what ABA is, pairing, errorless teaching and prompting, and active student responding. Complete the course and pass its 40-question final exam with a score of at least 80%. Completing this course earns a Special Learning certificate of completion. That certificate is not a continuing education (CE) certificate. It is basic training in ABA methods for daily practice, not a professional credential. It is not the 40-hour training required for the RBT credential. We do not claim the District of Columbia state approval or continuing education credit for this course.

Two ways to start

Last reviewed: October 30, 2026.

See every state's ABA licensure rules