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ABA licensure by state

ABA licensure in Massachusetts: who needs a license, how to get one and how to keep it

The short answer

Massachusetts issues licenses for applied behavior analysts and assistant applied behavior analysts through the Board of Registration of Allied Mental Health and Human Services Professions. The sources reviewed here describe licensing qualifications but leave uncertainty about when ABA work requires a license. Confirm with the Board before you rely on this.

What the law says

The statute defines the two licenses and the practice they cover.

"''Licensed applied behavior analyst'', an individual who, by training, experience and examination, meets the requirements for licensing by the board and is duly licensed to engage in the practice of applied behavior analysis in the commonwealth." (M.G.L. c. 112, § 163)

"''Practice of applied behavior analysis'', the design, implementation and evaluation of systematic instructional and environmental modifications, using behavioral stimuli and consequences, to produce socially significant improvements in human behavior, including the direct observation and measurement of behavior and the environment, the empirical identification of functional relations between behavior and environmental factors, known as functional assessment and analysis, and the introduction of interventions based on scientific research and which utilize contextual factors, antecedent stimuli, positive reinforcement and other consequences to develop new behaviors, increase or decrease existing behaviors and elicit behaviors under specific environmental conditions that are delivered to individuals and groups of individuals; provided, however, that the ''practice of applied behavior analysis'' shall not include psychological testing, neuropsychology, diagnosis of mental health or developmental conditions, psychotherapy, cognitive therapy, sex therapy, psychoanalysis, psychopharmacological recommendations, hypnotherapy or academic teaching by college or university faculty." (M.G.L. c. 112, § 163)

Who must hold it. The statute's general license requirement, section 164, lists four titles, none of them a behavior analyst title, and bars practice "as a licensed mental health professional" without a license or an exemption:

"no individual who is not licensed or exempted from licensure under said sections shall advertise the performance of or use a title or description of: (1) licensed mental health counselor ... (2) licensed marital or marriage and family therapist ... (3) licensed rehabilitation counselor ... or (4) licensed educational psychologist ..." (M.G.L. c. 112, § 164)

The penalty section names the behavior analyst titles:

"Any individual not licensed under sections one hundred and sixty-three to one hundred and seventy-two who on March first, nineteen hundred and eighty-nine holds himself out to be or advertises himself as a licensed marriage and family therapist, rehabilitation therapist, educational psychologist, licensed behavior analyst, licensed assistant behavior analyst or mental health counselor in violation of this chapter shall be punished by a fine not exceeding five hundred dollars for the first offense and five hundred dollars for each subsequent offense; provided, however, that the board may also proceed in the superior court to enjoin and restrain any unlicensed individual violating any section of this chapter." (M.G.L. c. 112, § 171)

We did not find a sentence in sections 163 to 172 that says in so many words that practicing applied behavior analysis without a license is a violation. The Board's rule says licensees are bound by its provisions: "All licensed applied behavior analysts and licensed assistant applied behavior analysts are charged with having knowledge of 262 CMR and are required to practice applied behavior analysis in accordance with its provisions." (262 CMR 10.01) Ask the Board whether your work needs the license.

Exemptions. Section 164 says these individuals "shall be exempt from the requirements of this section":

"(2) an employee or other agent of a recognized academic institution or alcohol or drug education or awareness program, employee assistance program, or of a federal, state, county or local government institution, program agency, or facility, or a school committee, school district, school board or board of regents while performing those duties constituting employment by such an institution, program, agency or facility; provided, however, that such individuals are performing those activities solely within the agency or under the jurisdiction of such agency ..."

"(3) an employee of an organization which is nonprofit or licensed by the commonwealth, and which is determined by the board to provide adequate supervision while performing those duties constituting employment by such an agency; provided, however, that such individuals are performing those activities solely within the agency or under the jurisdiction of the organization."

"(4) a student in the discipline of an allied mental health and human services profession or an intern or trainee in an allied mental health and human services profession receiving qualified supervision approved by the board, and whose training status is designated by such titles as ''mental health intern'', ''family therapy intern'', or a person who is issued a temporary permit by the board to engage in the activities for which licensure is required."

Section 164 does not expressly name behavior analysts, so these excerpts do not establish whether its exemptions apply to ABA practice.

Section 164 also exempts "a licensed psychologist, a licensed social worker, a licensed occupational therapist, or a licensed physician or registered nurse." (M.G.L. c. 112, § 164)

The Board. The Board of Registration of Allied Mental Health and Human Services Professions issues the license. Its rule for behavior analysts is 262 CMR 10.00.

Source: M.G.L. c. 112, § 163 (Massachusetts Legislature); § 164; § 171; 262 CMR 10.00 (Mass.gov).

How to get licensed

Applied behavior analyst. The statute says the Board "may issue a license to an applicant as an applied behavior analyst" who shows good moral character and no conduct that would be grounds to refuse a license under section 169, and who:

"(1) has successfully completed a doctoral degree program from a recognized educational institution in which the doctoral program included a minimum of 60 graduate credit hours in courses related to the study of behavior analysis or a master's degree program from a recognized educational institution wherein the master's program included a minimum of 30 graduate credit hours in courses related to the study of behavior analysis, or for individuals with a masters or doctoral degree in another field of human services, successful completion of a board-approved certificate program in behavior analysis from a recognized educational institution combined with the successful completion of an approved course sequence formally approved by the board;

(2) has successfully completed a practicum or supervised experience in the practice of behavior analysis that meets the standards established by the board; and

(3) has successfully passed a board-approved examination related to the principles and independent practice of applied behavior analysis." (M.G.L. c. 112, § 165)

The rule repeats these steps and adds detail. The applicant completes a Board application, "signed under the penalties of perjury, and accompanied by the prescribed application fee". (262 CMR 10.03(1)) The rule sets credit-hour content areas for the degree (262 CMR 10.03(3)) and three kinds of experience: 1500 hours of independent fieldwork with at least 75 hours supervised, 1000 hours of practicum with at least 75 hours supervised, or 750 hours of intensive practicum with at least 75 hours supervised, which may be combined. (262 CMR 10.03(5)) For supervision in Massachusetts after January 1, 2018, the rule says it "must be provided only by a licensed applied behavior analyst who is qualified to supervise by the BACB." (262 CMR 10.03(5)(e)3)

The BACB. The BACB is named in the rule's definitions and in the supervision standard. For new applicants, the rule's requirements are the degree, the practicum or supervised experience and the Board-approved examination. Applications received before June 5, 2017 had a separate route: the rule says an applicant "is a BCBA" could qualify if of good moral character. (262 CMR 10.03(6)(a))

Licensure without examination. Under the statute, the Board "shall issue a license without examination" to "an applicant licensed as a professional in a comparable field in another state whose requirements for the license are determined by the board to be equivalent to or exceed the requirements of the commonwealth" (M.G.L. c. 112, § 166). The rule adds a reciprocity route for an applicant who holds an applied behavior analyst license or the equivalent from another state, in good standing, if the other state's standards are "substantially equivalent to or exceeds" Massachusetts'. (262 CMR 10.03(7))

Domestic violence and sexual violence training. The Board's continuing education rule says: "applicants and licensees shall participate in domestic violence and sexual violence training as a condition for licensure, renewal, revival or reinstatement of licensure." (262 CMR 7.03(2), citing M.G.L. c. 112, § 264)

Source: M.G.L. c. 112, § 165; § 166; § 264; 262 CMR 10.00; 262 CMR 7.00.

Assistants, RBTs and technicians

Assistant applied behavior analysts are licensed. The statute defines the license:

"''Licensed assistant applied behavior analyst'', an individual who, by training, experience and examination, meets the requirements for licensing by the board and is duly licensed to engage in the practice of applied behavior analysis under the supervision of a licensed applied behavior analyst or a physician or psychologist qualified to practice applied behavior analysis if it is consistent with the accepted standards of their respective professions." (M.G.L. c. 112, § 163)

To qualify, an applicant needs good moral character and:

"(1) has successfully completed a bachelor's degree program from a recognized educational institution wherein a minimum of 135 classroom hours of instruction specifically in behavior analysis or possesses a bachelor's degree combined with successful completion of a board-approved course sequence or course work which otherwise meets professional standards, as determined by the board;

(2) has successfully completed a practicum or supervised experience in the practice of behavior analysis that meets the eligibility requirements established by the board; and

(3) has successfully passed a board-approved examination related to the principles and practice of applied behavior analysis." (M.G.L. c. 112, § 165)

The rule sets the bachelor's coursework (nine or twelve credit hours in listed content areas) and experience of 1000 hours of independent fieldwork with at least 50 hours supervised, 670 hours of practicum with at least 50 hours supervised, or 500 hours of intensive practicum with at least 50 hours supervised. (262 CMR 10.04(3) and (4)) The rule also has a reciprocity route for assistants. (262 CMR 10.04(6))

RBTs and technicians. We found no Massachusetts license or registration for registered behavior technicians or other behavior technicians in M.G.L. c. 112, sections 163 to 172, or in 262 CMR 7.00, 9.00 and 10.00. These sources do not mention the RBT credential.

Source: M.G.L. c. 112, § 163; § 165; 262 CMR 10.00.

Renewal and state-required training

Cycle. The statute says: "Licenses shall be valid for two years and must be renewed biennially." It sets this renewal schedule: "On or before September thirtieth of the year preceding the expiration of a license, the secretary of the board shall forward to the holder of the license a form of application for renewal thereof. Upon the receipt of the completed form and the renewal fee on or before November thirtieth, the secretary shall issue a new license for the year commencing January first." (M.G.L. c. 112, § 168)

Continuing education. The Board's rule says: "All licensees are required, as a condition of license renewal, to complete a minimum of 30 Contact Hours of continuing education activities per licensure/renewal period (every two years). These Contact Hours must be obtained from Board-recognized Entities." (262 CMR 7.03(1)) The rule defines a contact hour as "an organized learning experience lasting 50 consecutive minutes" and says "Board-recognized Entities" are "Entities that the Board has designated as appropriate to approve sponsors of continuing education activities." (262 CMR 7.02) The licensee attests to compliance on the renewal form, the Board "may audit licensees", and sponsors keep attendance records for five years. (262 CMR 7.04) Failure to comply "is grounds for disciplinary action ... and may result in the non-renewal of the license." (262 CMR 7.03(3))

Required topic. Domestic violence and sexual violence training is a condition of renewal. For an applicant for renewal, revival or reinstatement, the rule describes an applicant:

"who has previously completed a program or course approved by the Board shall not be required to participate in a subsequent program or course of domestic violence and sexual violence training except where the Board, in its discretion, requires completion of such a program or course as a condition of renewal, revival, or reinstatement of licensure." (262 CMR 7.03(2)(b))

The Board identifies the programs that meet the standard. (262 CMR 7.03(2)(a))

Lapsed licenses. The rule says a license that has lapsed for one renewal cycle or less may be reinstated by paying the back license fee, a late fee and the current fee, showing the required continuing education credits and completing any other Board requirements. (262 CMR 9.01(1)) The rule sets other steps for a license lapsed for more than one cycle. (262 CMR 9.01(2))

Source: M.G.L. c. 112, § 168; 262 CMR 7.00; 262 CMR 9.00.

Training the staff you supervise

If you run a program in Massachusetts 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 Massachusetts 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