ABA licensure in Maryland: who needs a license, how to get one and how to keep it
The short answer
Maryland generally requires a license from the State Board of Professional Counselors and Therapists before practicing behavior analysis, subject to statutory exceptions. The license title is "licensed behavior analyst." Applicants must meet the Board's certification, education and application requirements. Confirm with the Maryland Board of Professional Counselors and Therapists before you rely on this.
What the law says
Maryland regulates behavior analysts under Health Occupations Article, Title 17, Subtitle 6A, and COMAR 10.58.16. The Board of Professional Counselors and Therapists administers it, with a Behavior Analyst Advisory Committee inside the Board.
Who must be licensed.
"Except as otherwise provided in this subtitle, beginning January 1, 2015, an individual shall be licensed by the Board before the individual may practice behavior analysis in the State." (§ 17-6A-10(a))
"Except as otherwise provided in this subtitle, a person may not practice, attempt to practice, or offer to practice behavior analysis in this State unless licensed by the Board." (§ 17-6A-27(a))
What counts as practice.
"'Practice of behavior analysis' means the design, implementation, and evaluation of systematic instructional and environmental modifications to produce socially significant improvements in human behavior." (§ 17-6A-01(f)(1))
The definition "includes" functional assessment and analysis and "interventions based on scientific research and the direct observation and measurement of behavior and environment." It "does not include psychological testing, diagnosis of a mental or physical disorder, neuropsychology, psychotherapy, cognitive therapy, sex therapy, psychoanalysis, hypnotherapy, counseling, or any subdiscipline of psychology as treatment modalities." (§ 17-6A-01(f)(2)-(3))
Exemptions the statute names. We found two:
"This section does not apply to a student enrolled in an educational program that meets the criteria of § 17-6A-11(c)(2) of this subtitle while engaged in an unpaid, clinical educational experience of behavior analysis." (§ 17-6A-10(b))
"This subtitle does not limit the right of an individual to practice a health occupation that the individual is licensed, certified, or otherwise authorized to practice under this article." (§ 17-6A-02(b))
We found no exemption in the Act for school employees or for family members.
Title.
"Unless authorized to practice behavior analysis under this subtitle, a person may not: (1) Represent to the public that the person is a licensed behavior analyst; or (2) Use any title, abbreviation, sign, card, or other representation that the person is a licensed behavior analyst." (§ 17-6A-28)
Penalties. Under § 17-6A-29, a person who violates the subtitle "is guilty of a misdemeanor and on conviction is subject to a fine not exceeding $10,000 or imprisonment not exceeding 1 year or both," and a person who violates § 17-6A-27 "is subject to a civil fine of not more than $50,000 to be assessed by the Board."
Telehealth. COMAR 10.58.16.13A says "in order to practice telehealth a telehealth practitioner shall be licensed in Maryland when providing telehealth services to a client located in the State."
Source: Md. Code, Health Occupations §§ 17-6A-01, 17-6A-02, 17-6A-10, 17-6A-27, 17-6A-28, 17-6A-29 (Maryland General Assembly); COMAR 10.58.16 (Library of Maryland Regulations).
How to get licensed
The statute sets the qualifications. An applicant must be "of good moral character" and "at least 18 years old," and must:
"(1) Have a current certification by the Behavior Analyst Certification Board or its successor organization; (2) Have received a master's degree or higher from a behavior analysis educational program that is accredited by the Behavior Analyst Certification Board or its successor organization; (3) Demonstrate oral and written competency in English as required by the Board; and (4) Meet any other requirements established by the Board." (§ 17-6A-11(c))
"The Board shall waive the education requirements under subsection (c)(2) of this section if an individual was certified by the Behavior Analyst Certification Board on or before December 31, 2014, and is currently in good standing." (§ 17-6A-11(d))
The rule restates this as a current certification as a board-certified behavior analyst or board-certified behavior analyst-doctoral, "verified by the Board with the Behavior Analyst Certification Board." (COMAR 10.58.16.04A(3))
Application. The statute requires an application "on the form that the Board requires," payment of "the application fee set by the Board," and a criminal history records check under § 17-501.1. (§ 17-6A-12) COMAR 10.58.16.05 adds "an official transcript, demonstrating that the applicant has met the minimum degree requirement of the Behavior Analyst Certification Board, or its successor, at the time of certification" and a copy of the applicant's BACB certificate "demonstrating that the applicant is currently certified in good standing."
The Board's behavior analyst page says "NEW - Applicants must obtain a CHRC before submitting their application" and asks for a copy of the CHRC receipt with the application. It directs applicants to its online application and payment portal. Section 17-6A-13(a)(2) requires issuance within 30 days after receipt of a complete application if the applicant meets the subtitle's requirements. For an initially incomplete application, subsection (a)(3) requires issuance within 50 days after receipt of the additional information if the applicant is determined to meet those requirements. The Board's page separately tells applicants to allow at least 30 to 45 business days for processing a completed initial application. Ask the Board about the timing for your application.
Source: Md. Code, Health Occupations §§ 17-6A-11, 17-6A-12, 17-6A-13; COMAR 10.58.16.04 and .05; Board of Professional Counselors and Therapists, Behavior Analyst License.
Assistants, RBTs and technicians
We found no Maryland license or registration for assistant behavior analysts or registered behavior technicians in the Act or in COMAR 10.58.16. The Board's rules do describe them, as people who work under a licensed behavior analyst:
"'Board-certified assistant behavior analyst' means an individual who: (a) Is credentialed by the Behavior Analyst Certification Board or a successor organization; and (b) Practices under the supervision of a licensed behavior analyst in accordance with the Behavior Analyst Certification Board's description of the role and functions of a board-certified assistant behavior analyst and supervision requirements." (COMAR 10.58.16.02B(3))
"'Registered behavior technician' means an individual who: (a) Is credentialed as a registered behavior technician by the Behavior Analyst Certification Board or a successor organization; and (b) Practices behavior analysis under the close, ongoing supervision of a licensed behavior analyst in accordance with requirements set by the Behavior Analyst Certification Board." (COMAR 10.58.16.02B(11))
The rules also define a "paraprofessional" as someone who "practices behavior analysis under the supervision of a licensed behavior analyst," is not a board-certified assistant behavior analyst, and "may be a registered behavior technician." (COMAR 10.58.16.02B(9)) All of these fall under the rule's term "supervisee."
The supervising licensee carries the responsibility. Under a tiered service model, "a supervisee shall deliver assessment and treatment protocols as directed by and under the close and ongoing supervision of a licensed behavior analyst," and the licensed behavior analyst "shall be responsible for all aspects of clinical direction, supervision, and case management, including activities of supervisees." (COMAR 10.58.16.12C(2)) COMAR 10.58.16.14A(1) requires a licensee to comply with the Behavior Analyst Certification Board requirements regarding supervision of supervisees.
Source: COMAR 10.58.16.02, .12 and .14.
Renewal and state-required training
Cycle. COMAR 10.58.16.06A says a licensed behavior analyst "may renew the license every 2 years on the date specified by the Board" by completing a renewal application, submitting evidence of current BACB certification, having that certification verified with the BACB, submitting to a criminal history records check, and submitting evidence of compliance with any continuing education requirements the Board sets.
Continuing education. COMAR 10.58.16.07 says:
"A licensed behavior analyst shall complete continuing education units in accordance with the requirements of the Behavior Analyst Certification Board or its successor organization."
"A licensed behavior analyst shall document completion of continuing education requirements and retain this documentation for the succeeding 4 years for possible inspection by the Board."
The Board's continuing education page says: "The BACB currently requires 32 CEUs per two-year BCBA recertification cycle, including 4 CEUs in ethics and 3 CEUs in supervision, when applicable. Please follow your BACB recertification cycle dates." It adds: "The general 40-hour continuing education requirement for other Board credentials does not apply to LBAs." We found no Maryland-specific required topic, such as a jurisprudence or human trafficking course, for behavior analysts in the Act or in COMAR 10.58.16. The BACB sets its own requirements, so check the BACB's current rules as well.
Inactive status and lapsed licenses. A licensee can apply for inactive status, and must renew inactive status every year (COMAR 10.58.16.08). A licensee who "has not renewed" and is not inactive "may not practice behavior analysis" (COMAR 10.58.16.06B). The Board "shall reinstate" a lapsed license if the person meets the requirements and applies "within 5 years after the license expires." After five years, the person may become licensed again "by meeting the current requirements for obtaining a new license." (§ 17-6A-16(b)-(c); COMAR 10.58.16.10)
Source: COMAR 10.58.16.06, .07, .08 and .10; Md. Code, Health Occupations §§ 17-6A-15, 17-6A-16; Board of Professional Counselors and Therapists, Continuing Education Information.
Training the staff you supervise
If you run a program in Maryland 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 Maryland state approval or continuing education credit for this course.
Two ways to start
- For one person: try the first two sessions free for 7 days; account creation is required, with no payment information requested. The full course costs $199, paid once, with no subscription or recurring charge. Activate your license code within 90 days of purchase; the published completion window is 10 weeks after activation. You may request a later start date, no later than three months after purchase. Start the free sessions
- For your team: tell us how many people need training and when, and we will send a quote; each participant who completes the course and passes its 40-question final exam with a score of at least 80% earns an individual certificate of completion. Ask for a team quote
Last reviewed: October 30, 2026.