
Generally, you need a license in each licensing state where your telehealth client is located. The BACB says serving someone in another jurisdiction may require a license there. Texas allows up to 20 days a year without one; New York also requires its license when the behavior analyst is located in New York. There is no ABA compact.
For licensing purposes, a telehealth session happens where the client is, and sometimes where you are too. The BACB's December 2025 newsletter says behavior analysts providing services or supervision to people in other states "must familiarize themselves with the laws and regulations of the jurisdiction(s) where their supervisees, trainees, and clients are providing or receiving services," and that serving someone who resides in another jurisdiction "may require a behavior analyst to be licensed in that jurisdiction." There is no interstate compact for behavior analysts and no telehealth shortcut in the licensing states we have checked, so in practice each licensing state a client logs in from is a state you need to be licensed in, unless that state has an exemption that fits.
Why does the client's location matter more than yours?
Because the state's licensing law protects the people in that state. The BACB puts it as "It's not just about where behavior analysts live," but "also where they practice." A BCBA licensed in Georgia who coaches a family in Tennessee over video should assume Tennessee's law applies to that session, since Tennessee is where the client receives the service.
The BACB also notes why this has become pressing: telehealth "has created many opportunities for behavior analysts to provide services in areas that may have historically had limited access (e.g., rural areas)." The same opportunity creates the licensing exposure. Families near a state line, families who move mid-treatment, and agencies that staff one clinical team across a region all run into it.
How do individual states handle ABA telehealth?
Texas
TDLR's telehealth page for behavior analysts says you "can provide telehealth services that are within the scope of your Texas license" and must meet the same standard of care as in person. An out-of-state behavior analyst may provide temporary services for not more than 20 days in a calendar year under Tex. Occ. Code 506.057, after telling the client or parent they are not Texas licensed and the services are time-limited. Texas also sets telehealth duties: verify the identity of the client receiving the service, give information about follow-up care, obtain consent for treatment, data collection and data sharing, and keep consent records for at least five years.
New York
New York's rule reaches both ends of the call. Its telepractice guidance for licensed behavior analysts says "a practitioner must hold a New York license, or be otherwise authorized to practice, when providing professional services to a patient/client located in New York or when the practitioner is located in New York." A BCBA living in New York and serving only New Jersey families still needs a New York license under that guidance, and a New Jersey license for the New Jersey clients. See getting a New York LBA license.
Ohio
Ohio's statute authorizes telehealth by its own credential holders: "A certified Ohio behavior analyst may provide telehealth services in accordance with section 4743.09 of the Revised Code" (Ohio Rev. Code 4783.20). The authority runs through the Ohio certificate. See Ohio's behavior analyst certificate.
Florida
Florida has no behavior analyst license, but it does have a telehealth statute that reaches behavior analysts. Its definition of "telehealth provider" includes individuals "licensed or certified under s. 393.17," the provision for behavior analysts certified through the state's disability services agency (Fla. Stat. 456.47(1)(b)). The same statute has an out-of-state telehealth provider registration, and it covers behavior analysts certified under s. 393.17. A registrant must hold an active, unencumbered license in another state that is substantially similar to the Florida credential, have no discipline in the prior five years, designate a Florida registered agent, carry the required liability coverage, and may not open a Florida office or see Florida patients in person (Fla. Stat. 456.47(4)). See Florida and behavior analysts without a state license.
What about clients in states with no license?
In the ten states with no behavior analyst license (California, Delaware, Florida, Idaho, Maine, New Hampshire, New Mexico, Pennsylvania, South Carolina and West Virginia), there is no ABA license to hold. That does not mean anything goes. Payers and state programs set their own rules, and many key on BACB certification. California's commercial autism coverage law, for instance, defines who counts as a qualified autism service provider (Cal. Health and Safety Code 1374.73). Pennsylvania has a separate Behavior Specialist license with its own scope. Check the payer contract and any state credential before treating a non-licensing state as open.
Does supervision by video follow the same rule?
Yes, and the BACB says so. "While remote supervision is permissible, it may require that the supervisor be licensed in the state where the trainee or supervisee is providing services, as oversight of client programming by the supervisor may constitute service provision." The RBT Handbook allows supervision observations "via web cameras, video-conferencing, or similar means," but adds, "Internet-based supervision needs to comply with all applicable laws." Our post on remote supervision across state lines goes deeper.
Which checklist keeps a telehealth caseload legal?
- Map client locations. List every state where a client, parent or caregiver actually joins sessions, not just their billing address.
- Map your own location. If you live or work from New York, add New York.
- Map supervisees. Add every state where an RBT, BCaBA or trainee you supervise delivers services.
- Compare against the 40 licensing states and DC on the state license index.
- Check for a temporary window only for genuinely short engagements (temporary practice rules).
- Apply early in the remaining states; reciprocity exists in 27 of the 40 (how it works).
- Keep the state's telehealth duties, such as Texas's consent and identity verification rules, in your intake process.
Payers add their own telehealth rules on top. TDLR tells licensees to "check with your payor before initiating a new type of service or service delivery model, such as telehealth." For payer enrollment in each state, see our sister site's post on telehealth credentialing.
How can we help with a multistate telehealth caseload?
Start with the ABA Licensure Readiness Review, $149, which turns your client and supervisee map into a list of required licenses and an order to get them in. From there, License by Endorsement (BCBA) is $599 per state, or $1,599 per BCBA for an Agency Multi-State Package covering three states. We prepare each application and track it; you review, sign and submit. See pricing and the multistate ABA hub.
Common questions
- Do I need a license where my telehealth client lives?
- If that state licenses behavior analysts, usually yes. The BACB says providing services to someone who resides in another jurisdiction may require a license there, and states like Texas and New York tie telehealth to their own license.
- Can I do parent training by video for a family in another state?
- Parent training is a behavior-analytic service, so the same licensing rules apply. Check whether the family's state licenses behavior analysts and whether it has a short visiting-practice exemption.
- I live in New York but only serve clients in other states. Do I need a New York license?
- Under New York's telepractice guidance, a New York license or other authorization is required when the practitioner is located in New York, as well as when the client is.
- Is there a telehealth registration that replaces an ABA license?
- In a few states. Florida, which has no ABA license, has an out-of-state telehealth registration (s. 456.47) covering behavior analysts certified under s. 393.17. Vermont lists applied behavior analysis for its Interim Telehealth Registration, and Arizona's out-of-state telehealth registration (A.R.S. 36-3606) reaches behavior analysts too.
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