Reinstating a Lapsed Behavior Analyst License

Licenses lapse for ordinary reasons: a parental leave, a move, a renewal notice sent to an old email, a missed CE requirement. Practicing on a lapsed license is the real risk. Virginia says practice with a lapsed license "may be grounds for disciplinary action" (18VAC85-150-70), and Louisiana says no one may practice or supervise in Louisiana while a license, certificate or registration is lapsed (board rule 402). If you are reading this because a renewal slipped, stop practicing in that state until the license is active again, then work out which tier you are in.

How do the tiers work in each state?

Texas

TDLR's renewal page sets three tiers. Expired 90 days or less: renew for 1.5 times the normal fee. More than 90 days but less than 18 months: twice the fee. At least 18 months but less than three years: the executive director must approve the application, and the fee is twice the normal fee. The late fee replaces, rather than adds to, the regular renewal fee. Texas also requires current BACB or QABA certification and the human trafficking prevention course at renewal.

Nevada

A license or registration whose biennial fee is not paid within 60 days of the due date "is automatically suspended" (NRS 641D.370). Within two years the board may reinstate it on payment of the current renewal fee and the restoration fee. After two years, the board must also find the person competent to practice. If continuing education was the problem, NAC 641D.140 says the board will not consider reinstating a suspended or unrenewed license until the CE is complete.

Virginia

A license not renewed by the first day of the month after it was due is lapsed. Within two years, renew with the renewal fee, the late fee ($50 for a behavior analyst, $30 for an assistant) and documentation of CE (18VAC85-150-70). After more than two years it becomes a reinstatement: an application, a $180 fee for a behavior analyst or $90 for an assistant, and evidence of competency, which can be continued practice elsewhere as a licensee or with BCBA or BCaBA certification, 16 hours of CE for each lapsed year (10 for assistants) up to three years, or passing the certification exam again (18VAC85-150-90). The board may add requirements.

Washington

Failure to renew "invalidates the license or certification and all privileges granted" by it. If it has lapsed longer than three years, the person must demonstrate competence through continuing competency requirements or other standards (RCW 18.380.070). WAC 246-805-990 sets a $175 late renewal penalty and a $175 expired license reissuance fee for a behavior analyst ($90 each for an assistant, $75 each for a technician).

Louisiana

Licenses renew annually by June 30. A license not renewed is lapsed effective July 1. It may be reinstated with board approval, the renewal fee and a late fee (rule 402). Where continuing education caused the lapse, renewal within two years requires proof of all CE through the reinstatement date and payment of fees due; after two years, the fee equals the application fee plus the renewal fee (rule 809).

Oregon

An Oregon authorization may sit inactive for up to three years and be renewed with the renewal and late fees. After three years inactive it is expired, and you reapply from the start (OAR 824-050-0010).

Illinois

A person with an expired or inactive license may have it restored by applying, filing proof of fitness, and paying the fee; evidence of active practice in another jurisdiction helps. Without it, IDFPR decides fitness and may require a period of evaluated experience or an exam (225 ILCS 6/50).

Is BACB reinstatement the same thing?

No, and confusing them is common. The BACB's reinstatement is short. A BCBA who completed all CE but missed the recertification date has 30 days to reinstate and pay the $50 late fee; CEUs cannot be added during that period. After 30 days, the certification expires. Within five years of expiration, a former BCBA may requalify by passing the exam again after earning 16 CEUs for each year since expiration; after that, they apply as new (BCBA Handbook, updated June 2026).

Because so many states require current certification, a BACB lapse can trigger a state problem even when the state license itself is current. Restore the certification first, then the license.

Should you choose inactive status instead of letting a license lapse?

Often, yes, if you know you will be away. Virginia offers an inactive license at a lower renewal fee ($70 for a behavior analyst), with a competency showing to reactivate (18VAC85-150-80 and 90). Nevada allows inactive status for up to three years with a $100 fee (NAC 641D.180 and 641D.200). The BACB offers voluntary inactive status for up to four years for a $50 fee, with eight CEUs required to return after two to four years. Check that the state and BACB statuses fit together; Texas only renews an inactive certificant's license on inactive status.

What does a reinstatement file usually need?

• the state's reinstatement or late renewal application and fees;
• proof of current BACB certification;
• CE certificates covering the lapsed period, where the state requires them;
• verifications of practice or licensure elsewhere, if offered as competency evidence;
• sometimes a new background check; Nevada, for example, runs a criminal history check before restoring an inactive license to active status (NAC 641D.180).

Where should you start?

We work out which tier you are in, assemble the CE and verification evidence, and prepare the reinstatement package for you to review, sign and submit. A $149 Readiness Review is the usual starting point, because it tells you which tier and which documents apply in each state. To keep it from happening again, our Annual Renewal and CE Compliance service is $299 per license, per year. See keeping several renewals on one calendar and BACB recertification and state renewal.