PA IBHS Training Requirements

Q: How many hours of training does a new BHT need in Pennsylvania IBHS?

Under 55 Pa. Code § 5240.73(c), an individual who has not previously provided BHT services must complete at least 30 hours of Department-approved training before providing services independently. Under § 5240.73(d), the same individual must complete at least 24 more hours within the first 6 months of providing BHT services. After that, § 5240.73(e) requires at least 20 hours annually.

Q: What is the difference between the 30-hour and the 24-hour PA IBHS training?

They are two different requirements with two different deadlines and two different topic lists. The 30 hours under § 5240.73(c) come BEFORE the person works independently and cover eight topics including Child Protective Services Law and mandated reporting, crisis intervention, behavior management, child and adolescent development, serious emotional disturbance, professional ethics, first aid and safety, and psychotropic medications. The 24 hours under § 5240.73(d) come WITHIN THE FIRST 6 MONTHS and cover eleven different topics including documentation, systems of care, functional behavioral assessment, cultural considerations, family engagement, community resources, cross-systems collaboration, communication and conflict resolution, IEP and special education basics, and safe use of restrictive procedures.

Q: Which RBT Task List edition does Pennsylvania IBHS expect in 2026?

The 3rd edition. The regulation itself is silent — 55 Pa. Code § 5240.71(d)(5) and § 5240.81(g)(5) are word-for-word identical, require a 40-hour training covering the RBT Task List evidenced by a certification naming the responsible trainer who is certified as a BCBA or BCaBA, and neither names an edition. But OMHSAS has since spoken in guidance. In its April 2, 2026 letter to IBHS providers, OMHSAS states that training content is now the RBT Test Content Outline (3rd ed.), that 'training materials referencing the 2nd edition Task List or certificates dated before January 1, 2026, are now considered outdated,' that existing staff should update to 3rd edition training within one year of holding a 2nd edition certificate, and that new hires without prior BHT experience should be trained on the 3rd edition curriculum. OMHSAS also names the exact sentence a 2026 certificate must carry — 'This training program is designed to meet the 2026 training eligibility requirement for RBT certification. The training is offered independent of the BACB.' — and says licensing staff will review certificates for it. Do not read the regulation's silence as edition not mattering in 2026.

Q: Can BACB continuing education count toward PA IBHS training hours?

Yes on both tracks, by two different routes. For ABA services under § 5240.83, the regulation states the two routes as alternatives and names continuing education providers approved by the Behavior Analyst Certification Board explicitly: training 'approved by the Department OR provided by a continuing education provider approved by the Behavior Analyst Certification Board.' For individual services under § 5240.73, that section asks for Department-approved training — and DHS's published process document already considers a BACB ACE provider's training approved. The limits are topical, not track-based: the 30-hour pre-service requirement at § 5240.73(c) mandates eight topics, two of which Pennsylvania restricts to named organizations we are not among — Child Protective Services Law / mandated reporting, and first aid, universal precautions and safety. Separately, § 5240.73(g) and § 5240.83(e) both provide that an individual who is certified may count hours of training required to maintain certification toward those training requirements. Your OMHSAS licensing representative is the final authority on any individual staff record.

Q: Which staff do the PA IBHS training requirements apply to?

Chapter 5240 splits training on two axes. § 5240.73 covers staff who provide INDIVIDUAL services — behavior consultants, mobile therapists, and BHTs. § 5240.83 covers staff who provide ABA services — behavior analytic and behavior consultation-ABA staff, assistant behavior consultation-ABA staff, and BHT-ABA staff. Separately, § 5240.71 and § 5240.81 set the QUALIFICATIONS to be hired at all, which is where the 40-hour RBT Task List rule lives.

What Pennsylvania IBHS agencies must train, by role and by deadline — the 30-hour initial, the 24-hour six-month, the 20-hour and 16-hour annuals, and the 40-hour RBT Task List rule. Quoted from 55 Pa. Code § 5240, with the section number beside every number.

The short answer. A Behavioral Health Technician who has not provided BHT services before needs 30 hours before working independently and 24 more hours within the first six months, then 20 hours every year. Behavior consultants and mobile therapists need 16 hours every year. Those are the individual-services numbers, from 55 Pa. Code § 5240.73.

On the ABA services side (§ 5240.83), the annual figures are 16 hours for behavior analytic and behavior consultation–ABA staff and 20 hours for assistant behavior consultation–ABA and BHT–ABA staff — and the ABA track names two acceptable routes for that training: approved by the Department or provided by a continuing education provider approved by the Behavior Analyst Certification Board.

Separately from training hours, § 5240.71(d)(5) and § 5240.81(g)(5) set a hiring qualification: a 40-hour training covering the RBT Task List, certified by a named BCBA or BCaBA. Neither section names an edition.

Hours before a new BHT works independently — § 5240.73(c)

More hours within the first 6 months — § 5240.73(d)

Hours annually for BHT staff — § 5240.73(e)

Hours annually for BC / MT staff — § 5240.73(b)

The mistake that costs agencies the most: Chapter 5240 splits on two axes

Almost every wrong answer about IBHS training comes from reading one section and assuming it governs everybody. It does not. Chapter 5240 divides twice — once between individual services and ABA services, and again between who you may hire and what you must train them on afterwards.

	Individual services	ABA services
Staff qualifications who may be hired at all	§ 5240.71	§ 5240.81
Training requirements hours once hired	§ 5240.73	§ 5240.83

If you look up training hours in § 5240.73 and stop there, you will miss the 40-hour RBT Task List qualification entirely — because it lives on the other axis, in § 5240.71 and § 5240.81. And if your ABA-services staff are being held to § 5240.73's language, they are being held to the wrong section.

Individual services — 55 Pa. Code § 5240.73

Who	Hours	When	Section
Behavior consultation or mobile therapy staff	16 hours	Annually	§ 5240.73(b)
BHT with no prior BHT experience	30 hours	Before providing services independently	§ 5240.73(c)
BHT with no prior BHT experience	24 hours	Within the first 6 months of providing BHT services	§ 5240.73(d)
Any BHT	20 hours	Annually	§ 5240.73(e)

The eight topics in the 30-hour initial — § 5240.73(c)

(1) Sections 6301—6386 of 23 Pa.C.S. (relating to Child Protective Services Law) and mandated reporting requirements. (2) Crisis intervention skills, including risk management, de-escalation techniques and safety planning. (3) Behavior management skills and coaching. (4) Child and adolescent development. (5) Overview of serious emotional disturbance and other behavioral and psychosocial needs of the children, youth and young adults with whom the individual works. (6) Professional ethics, conduct and confidentiality. (7) First aid, universal precautions and safety. (8) Psychotropic medications, including common side effects. 55 Pa. Code § 5240.73(c), verbatim. Source text retrieved from the Pennsylvania Code & Bulletin, 2026-07-31.

The eleven topics in the 24-hour six-month requirement — § 5240.73(d)

(1) Documentation skills. (2) Systems of care principles. (3) Overview of functional behavioral assessment. (4) Ethnic, cultural and linguistic considerations of the community served. (5) Strategies and interventions to engage children, youth or young adults and parents, legal guardians or caregivers in services, including family systems theory. (6) Skills and techniques for working with families. (7) Overview of community resources and child and youth-serving systems and processes. (8) Cross-systems collaboration. (9) Communication and conflict resolution skills. (10) Basic individual education plan and special education information. (11) Safe use of restrictive procedures in accordance with § 5240.6 (relating to restrictive procedures). 55 Pa. Code § 5240.73(d), verbatim. Source text retrieved from the Pennsylvania Code & Bulletin, 2026-07-31.

Two provisions agencies routinely miss

College coursework can substitute. § 5240.73(f) allows an individual providing BHT services to substitute completed college coursework for required training topics in subsection (c) or (d), by giving the agency an official transcript and other documentation showing the coursework addressed a required topic.

Certification and licensure hours can count. § 5240.73(g): “An individual who is certified may count hours of training required to maintain certification towards the training requirement in subsections (b)—(e).” § 5240.73(h) says the same for an individual licensed in the Commonwealth. If you employ RBTs, BCBAs or licensed clinicians, the hours they already complete to keep those credentials are addressed directly by the regulation.

Training built for these content areas

Special Learning has sold PA IBHS training for years. These courses are built to the content areas § 5240.73 names. Live pricing is on each course page.

PA (IBHS) Initial Training for BHTs and Behavior TechsBuilt for the § 5240.73(c) topic list. Two of those eight topics — CPSL/mandated reporting and first aid — must come from a Pennsylvania-named organization, not from us.
PA (IBHS) Additional 24-Hour Training for Providers without HistoryBuilt for the § 5240.73(d) topic list, the within-6-months requirement.
PA (IBHS) Mandated — BHT 20 Hour TrainingBuilt for the § 5240.73(e) annual BHT content areas.
PA IBHS BHT 20-Hour Training — Mental Health ProfessionalsThe same annual content areas, framed for mental health professional staff.
PA (IBHS) Training PackageThe multi-course package for agencies onboarding more than one person.

Each agency remains responsible for verifying that its staff training meets its own licensure obligations.

ABA services — 55 Pa. Code § 5240.83

The ABA-services track carries its own hours, and its wording differs in a way that matters: it names two acceptable routes for the training, not one.

Who	Hours	When	Section
Behavior analytic / behavior consultation–ABA staff	16 hours	Annually	§ 5240.83(b)
Assistant behavior consultation–ABA staff without a qualifying certification	20 hours	Before independently providing ABA services	§ 5240.83(c)(1)
Assistant behavior consultation–ABA staff	20 hours	Annually	§ 5240.83(c)(2)
BHT–ABA staff	30 + 24 hours	Per § 5240.73(c), (d) and (f)	§ 5240.83(d)(1)
BHT–ABA staff	20 hours	Annually	§ 5240.83(d)(2)

… shall complete at least 16 hours of training annually that is approved by the Department or provided by a continuing education provider approved by the Behavior Analyst Certification Board that is related to the individual’s specific job functions and is in accordance with the individual training plan required under § 5240.13… 55 Pa. Code § 5240.83(b), verbatim (emphasis added). The same two-route wording appears in § 5240.83(c)(1), (c)(2) and (d)(2).

§ 5240.83(e) and (f) carry the same counting provisions as the individual-services track: a certified individual may count hours required to maintain certification toward subsections (b)—(d), and a licensed individual may count hours required to maintain licensure.

The 40-hour RBT Task List rule — and which edition Pennsylvania expects in 2026

This one is a hiring qualification, not a training-hours requirement, which is why it is missed so often. § 5240.71(d)(5) and § 5240.81(g)(5) are word-for-word identical:

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. 55 Pa. Code § 5240.71(d)(5) and § 5240.81(g)(5), verbatim — identical text in both sections.

Neither section names an edition — but OMHSAS has since spoken, and the answer for 2026 is the 3rd edition

We read both sections in full from the raw source text and counted: the words “edition” and “2nd” appear zero times in either one. The regulation requires a 40-hour training covering the RBT Task List and is silent on edition.

Do not read that silence as edition not mattering. OMHSAS wrote to all IBHS providers on April 2, 2026 and said so directly — the regulation’s own wording is now out of date:

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, BACB Training Updates for IBHS Providers, April 2, 2026, verbatim.

What the same letter tells you to plan for: staff trained on the 2nd edition at a previous agency can still be hired in 2026, but the new provider should have a plan for them to complete 3rd edition training within the year; existing staff should update within one year of holding a 2nd edition certificate; and new hires without prior BHT/BHT-ABA experience should be trained on the 3rd edition curriculum from the start.

Check the sentence on the certificate. OMHSAS names the exact language a 2026 certificate must carry and says licensing staff will review 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.” If a 40-hour certificate in your staff files does not carry it, that is the thing to fix before your next licensing visit.

Contact ra-pwibhs@pa.gov with questions on this guidance, per OMHSAS.

Where Special Learning stands, stated plainly

Special Learning is a continuing education provider approved by the Behavior Analyst Certification Board — BACB ACE Provider #OP-14-2437.

Pennsylvania’s Department of Human Services publishes a list of IBHS trainings that do not require Department review and approval — trainings it “already considers approved.” Trainings offered by a BACB ACE provider are on that list. (DHS, Process for Department Approval of Trainings Required by the IBHS Regulations, Jan. 2020, published at pa.gov.) For ABA services the regulation says it directly: § 5240.83 accepts training “approved by the Department or provided by a continuing education provider approved by the Behavior Analyst Certification Board.” Pennsylvania approves trainings, not providers, so we do not call ourselves a “Department-approved provider” — but our training does not need to be submitted for Department review.

Two topics have to come from somewhere else, whatever else you take from us. For the 30-hour pre-service requirement at § 5240.73(c), Pennsylvania accepts Child Protective Services Law / mandated reporting only from a Department-listed organization — the Pennsylvania Family Support Alliance, the Pennsylvania Chapter of the American Academy of Pediatrics, the University of Pittsburgh’s Child Welfare Resource Center, or another organization on the Commonwealth’s list — and first aid, universal precautions and safety only from the American Heart Association, American Red Cross, National Safety Council, ASHI, Medic First Aid or the Emergency Care & Safety Institute. We are not on either list. Our modules on those two topics are knowledge training and do not replace them.

What we do say: our PA IBHS courses are built to the content areas Chapter 5240 names, and several of our course titles state on their face where a course is supplemental rather than a full hour requirement — because an agency buying against its own licence exposure needs to know that before it buys, not after.

Not sure which requirement you are on? Email us and we will tell you plainly, including when the answer is that this product is not the right one for you.

The regulation's own counting provisions (§ 5240.73(g)–(h), § 5240.83(e)–(f)) address how certification and licensure hours interact with these requirements. Read them against your own staff mix.

Each agency remains responsible for verifying that its staff training meets its own licensure obligations.

Frequently asked questions

How many hours of training does a new BHT need in Pennsylvania IBHS?

Under § 5240.73(c), an individual who has not previously provided BHT services must complete at least 30 hours of Department-approved training before providing services independently. Under § 5240.73(d), the same individual must complete at least 24 more hours within the first 6 months of providing BHT services. After that, § 5240.73(e) requires at least 20 hours annually.

What is the difference between the 30-hour and the 24-hour PA IBHS training?

They are two requirements with two deadlines and two different topic lists. The 30 hours under § 5240.73(c) come before independent practice and cover eight topics. The 24 hours under § 5240.73(d) come within the first six months and cover eleven different topics. Both lists are quoted verbatim above. A course covering one does not cover the other.

Which RBT Task List edition does Pennsylvania IBHS expect in 2026?

The 3rd edition. § 5240.71(d)(5) and § 5240.81(g)(5) require a 40-hour training covering the RBT Task List, certified by a named BCBA or BCaBA, and neither names an edition — but OMHSAS’s April 2, 2026 letter to IBHS providers states that materials referencing the 2nd edition Task List, and certificates dated before January 1, 2026, are now considered outdated, and that staff should be on 3rd edition training within a year. It also names the exact sentence a 2026 certificate must carry, which licensing staff will check.

Can BACB continuing education count toward PA IBHS training hours?

Yes on both tracks, by two different routes. ABA services (§ 5240.83) — the regulation states the two routes as alternatives and names continuing education providers approved by the Behavior Analyst Certification Board explicitly. Individual services (§ 5240.73) — that section asks for Department-approved training, and DHS’s published process document already considers a BACB ACE provider’s training approved. The limits are topical, not track-based: the 30-hour pre-service requirement at § 5240.73(c) mandates eight topics, two of which Pennsylvania restricts to named organizations we are not among. Separately, § 5240.73(g) and § 5240.83(e) both allow a certified individual to count hours required to maintain certification toward those requirements. Your OMHSAS licensing representative is the final authority on any individual staff record.

Is Special Learning’s training accepted under Pennsylvania’s IBHS regulations?

In the categories that matter, yes — and here is the exact basis. Special Learning is a BACB ACE Provider (#OP-14-2437). Pennsylvania DHS publishes a list of IBHS trainings that do not require Department review because they are already considered approved, and “trainings offered by a BACB ACE provider” is on it. Pennsylvania approves trainings rather than providers, so we do not describe ourselves as a “Department-approved provider” — but our training does not need to be submitted for Department review. Two topics are the exception, and they are named above: CPSL/mandated reporting and first aid must come from organizations Pennsylvania names, and we are not among them. Your OMHSAS licensing representative is the final authority on any individual staff record.

Which staff do the PA IBHS training requirements apply to?

§ 5240.73 covers staff providing individual services — behavior consultants, mobile therapists, BHTs. § 5240.83 covers staff providing ABA services. § 5240.71 and § 5240.81 set the qualifications to be hired at all, which is where the 40-hour RBT Task List rule sits.

How to read this page against your own agency

Take your staff roster and sort it twice: first by individual services vs ABA services, then by how long each person has been doing the work. The first sort tells you whether § 5240.73 or § 5240.83 governs their hours. The second tells you whether someone is in the 30-hour pre-independence window, the 24-hour six-month window, or the annual cycle. § 5240.13 requires an individual training plan; these hours are meant to sit inside it.

Then check the counting provisions before you buy anything. If a BHT on your roster is an RBT, or a consultant is a BCBA, § 5240.73(g) and § 5240.83(e) speak directly to the hours they already complete. Reading those two sentences before purchasing is the cheapest thing on this page.

Regulatory text on this page is quoted from 55 Pa. Code Chapter 5240 as retrieved from the Pennsylvania Code & Bulletin. A regulation is a dated fact: verify current text at pacodeandbulletin.gov before relying on it. This page is general information about published regulations, not legal advice and not a compliance determination.