State staff requirements

Virginia ABA staff requirements, with sources

This page is for people who run an ABA team in Virginia. It lists the training, supervision and credential rules for behavior technicians and analysts that we found at a state source. Each rule shows the law or policy it comes from and the date we last checked Virginia. Where we couldn't confirm a rule, we say so instead of guessing.

This version covers U.S. states. If you're outside the U.S., email contact@special-learning.com with your country and we'll tell you when yours is ready.

Checked: August 20, 2026

What the state requires

1
Virginia does not require RBT certification for the technician tier. Technician-coded services may be delivered by five routes: an LMHP-Resident/RP/Supervisee under their board's supervision; an LABA under LBA supervision; unlicensed personnel under LBA/LABA supervision (per 18VAC85-150-10 et seq.); personnel under a Licensed Clinical Psychologist's supervision; or an LBA/LMHP acting as the technician. One route names no certification, training hours, or credential at all.
Source: vamedicaid.dmas.virginia.gov/bulletin/applied-behavior-analysis-aba-policy-and-regulatory-clarifications
2
Only LBAs, LABAs, and Licensed Clinical Psychologists have delegation authority to have non-licensed staff deliver ABA under their supervision; LCSWs, LPCs, and LMHP residents/supervisees may not supervise unlicensed staff delivering ABA.
Source: vamedicaid.dmas.virginia.gov/bulletin/applied-behavior-analysis-aba-policy-and-regulatory-clarifications
3
Family training (CPT 97156/97157) is required, with direct family involvement documented at least weekly in the Individual Service Plan.
Source: vamedicaid.dmas.virginia.gov/bulletin/applied-behavior-analysis-aba-policy-and-regulatory-clarifications

What changed recently

A DMAS bulletin effective December 16, 2025 (issued to ABA providers, Acentra Health, and the Cardinal Care MCOs after DMAS found 'actions that are not in compliance with existing ABA rules') restated and clarified the technician-tier and supervision rules. This is a correction to our earlier reading (the bulletin predates our May 29, 2026 reading by more than five months), not a state policy change.

This page is general information, not legal advice. Rules change, so confirm with the state before you act on it.