Fieldwork in a licensing state is regulated practice. New York requires a $10 graduate permit under a New York LBA, re-issued for each new supervisor and expiring after three years. Other states exempt trainees: Virginia for up to five years, and Texas, Washington, Illinois, Nevada and Louisiana with conditions, usually a trainee title and a supervisor licensed in that state.
Fieldwork for BACB certification means working with real clients, and in a licensing state that is the practice of applied behavior analysis. States handle trainees through exemptions or permits, and nearly all of them attach two conditions: the trainee must be identified as a trainee, and the supervisor must be someone the state recognizes, usually a licensee in that state.
The BACB adds the consequence that makes this matter: "a trainee who later applies for licensure in a jurisdiction where the individual supervising their fieldwork experience was required to be licensed may experience barriers in obtaining a license in that jurisdiction" (December 2025 Newsletter). Hours supervised by someone who should have been licensed can come back to haunt the trainee years later.
How does New York's graduate permit work?
New York is the strictest state we have read. A graduate of an acceptable program who is "performing activities and services in New York State to complete supervised experience and/or examination requirements for certification by the Behavior Analysis Certification Board" must obtain a graduate permit and work under a New York licensed behavior analyst (Office of the Professions). The key details:
- The fee is $10 and is not refundable.
- If you change supervisors or add one, you need a re-issued permit, with a new application completed by you and each supervisor; no new fee is charged.
- Graduate permits expire three years from issue.
- The supervising LBA must be licensed and registered in New York, employed by a setting authorized to provide ABA, and must file a sworn statement of compliance. The supervisor notifies the patient or responsible person that a graduate is providing services and gives them a chance to object (Education Law § 8807).
New York also has a separate limited permit, for an applicant who meets every licensure requirement except the exam or experience. It lasts one year, may be renewed once at the department's discretion, costs $70 each time, and requires supervision (NYSED FAQ).
How do other states treat trainees?
Virginia
Two exemptions. Students in a defined course, internship, practicum or program at an institution of higher education, supervised by faculty or a licensed behavior analyst, identified as a "behavior analyst student," "intern" or "trainee." And unlicensed individuals pursuing supervised experiential training toward BACB certification or licensure, supervised by a licensed behavior analyst approved by the BACB to supervise, provided "no more than five years have elapsed from the date on which the supervised experiential training began" (Va. Code § 54.1-2957.17(B) and (C)).
Washington
Matriculated students in a defined course or program, supervised by faculty or a licensed behavior analyst, using a trainee title; and individuals pursuing supervised experiential training for licensure or national certification, supervised by a licensed behavior analyst or a professional who meets the national certifying entity's supervisor requirements (RCW 18.380.030(4) and (5)). For CBT trainees, the trainee exemption ends once the department receives the completed training form, according to the Department of Health.
Texas
Students, interns and fellows whose work is part of a defined program, directly supervised by a licensed behavior analyst or an instructor in a course sequence approved by the certifying entity, and designated as a student, intern, fellow or trainee. Also unlicensed persons pursuing supervised experience consistent with the certifying entity's requirements (TDLR).
Illinois
Matriculated students at an approved, nationally accredited university, or postdoctoral fellows, in a defined program, directly supervised by a licensed behavior analyst or licensed clinical psychologist; and unlicensed individuals pursuing field experience supervised by a licensed behavior analyst or licensed psychologist (225 ILCS 6/20(c)(6) and (7)).
Nevada
A matriculated student at an accredited college or university may practice under the direct supervision of a licensed behavior analyst as part of an ABA program, internship or fellowship, must identify as a student, intern, trainee or fellow, and may not call themselves a behavior analyst or RBT (NRS 641D.130).
Louisiana
Students, interns or postdoctoral fellows in a defined program of study or supervised field or clinical experience, conducted under the extended authority of the assigned faculty member and supervised by a licensed behavior analyst, using a trainee title (R.S. 37:3715(6), as amended by Act 481 of 2014). Unlicensed individuals pursuing experiential training must be supervised by a licensed behavior analyst (R.S. 37:3715(8) as enacted).
Ohio
Ohio's exemption covers "a matriculated graduate student or postdoctoral trainee whose activities are part of a defined program of study or professional training" (Ohio Rev. Code 4783.02(B)(8)).
What should trainees and supervisors check?
- Is the supervisor licensed in the state where the client is? Remote supervision across state lines is the common failure. See remote supervision across state lines.
- Does the state need a permit? New York does, and it must be re-issued for each new supervisor.
- Is there a time limit? Virginia's exemption ends five years after the supervised training began; New York's permit after three.
- Does the trainee use a trainee title? Nearly every exemption requires it.
- Is the paperwork kept? The BACB audits fieldwork documentation, and states can ask who supervised.
Where can we help trainees and supervisors?
For supervisors, the issue is usually their own license: a BCBA supervising trainees in a new state needs a license there, which our License by Endorsement ($599 per state) or Full State License Application ($749 per state) services prepare for your review and submission. For trainees, a $149 Readiness Review maps permits and exemptions for each state where you will accrue hours. We do not provide fieldwork or supervision. Our psychology sister site covers the parallel issue for psychology trainees in supervising trainees across state lines. When you pass the exam, see what happens to your RBT or BCaBA.
Common questions
- Do I need a permit to do BCBA fieldwork in New York?
- Yes, if you are a graduate of an acceptable program completing supervised experience or exam requirements in New York. The graduate permit costs $10, requires supervision by a New York licensed behavior analyst, must be re-issued for each new supervisor, and expires after three years.
- Does my fieldwork supervisor need a license in my state?
- In most licensing states, the trainee exemption requires supervision by someone that state recognizes, usually its own licensee. The BACB warns that trainees whose supervisors should have been licensed may face barriers when applying for licensure later.
- How long can I work as a trainee in Virginia?
- Virginia's exemption for unlicensed individuals pursuing supervised experiential training applies only if no more than five years have passed since the supervised training began, under Va. Code § 54.1-2957.17(C).
- What is a New York limited permit for behavior analysts?
- A permit for an applicant who meets all licensure requirements except the exam or experience. It lasts one year, may be renewed once at the department's discretion, costs $70, and requires supervision.
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