Arizona Behavior Analyst Licensing

Arizona was one of the first states to license behavior analysts; the BACB lists 2010. The Arizona Board of Psychologist Examiners issues the license under Article 4 of Chapter 19.1 of Title 32 (A.R.S. 32-2091 to 32-2091.15), and its rules are in the Arizona Administrative Code at R4-26-401 and following. Under A.R.S. 32-2091.02, "a person who wishes to practice as a behavior analyst must be licensed pursuant to this article." Arizona has no assistant behavior analyst license.

Arizona's file is heavier than most because the board checks the underlying education and experience, not just the BCBA.

What does Arizona require from an applicant?

The statute requires that you be at least 21, pay the fees, be physically and mentally capable of safe practice, have no disqualifying conduct, have no professional license refused, revoked, suspended or restricted elsewhere for unprofessional conduct (unless the board is satisfied it was resolved), have not surrendered a license while under investigation, have no complaint pending elsewhere, and have applied for a fingerprint clearance card (A.R.S. 32-2091.02). A pending complaint in another jurisdiction stops the process: the board "shall suspend the application process" until it is resolved.

Rule R4-26-404 requires passing "the examination administered by the BACB for Board Certified Behavior Analysts." Someone who fails that exam three times, in any jurisdiction, must meet extra board requirements before trying again.

What goes into the Arizona application?

Under rule R4-26-403, every applicant submits the form and:

• An original, unretouched photograph no larger than 1.5 by 2 inches, taken within 60 days.
• The application fee.
• A copy of a valid Department of Public Safety fingerprint clearance card, or evidence that you applied for one.
• A written request that board staff verify with the BACB that you passed the exam.
• Documentation of citizenship or lawful presence under A.R.S. 41-1080.
• The board's Mandatory Confidential Information form.

For an initial license, these must also arrive directly at the board: verification of supervised experience (a copy of the BACB final experience verification form signed by your supervisor, or the board's own form), an official graduate transcript from the school, official proof of the required coursework, and verification of any license, certification or registration held elsewhere. If your supervisor cannot be found, the board may accept your own copies of the BACB experience forms.

That supervised-experience step is the one that stalls. Fieldwork supervisors retire, move and change email addresses. Start that request first.

How much does it cost?

Rule R4-26-402 lists $350 to apply for an active license and $500 to renew an active license, plus a $200 reinstatement fee for an expired license. The DPS fingerprint clearance card has its own fee, paid to DPS. Fees are generally not refundable.

What are the routes for someone licensed in another state?

Arizona has two.

Reciprocity (A.R.S. 32-2091.04). The board "may issue a license" to someone licensed or certified by another state with substantially equivalent requirements, who proves initial licensure and current good standing, and shows no other license has been suspended or revoked. Rule R4-26-403(D) requires these to come directly to the board: supervised-experience verification meeting BACB requirements when you were first certified, an official graduate transcript, official proof of coursework meeting the ABAI Verified Course Sequence requirements in effect when you were first certified, and "official verification of licensure from every jurisdiction that issued a license to the applicant." Reciprocity in Arizona saves little paperwork.

Universal recognition (A.R.S. 32-4302). Arizona's universal licensing law applies to licenses issued under Title 32, which includes behavior analysts. It requires that you establish residence in Arizona (or be a military spouse accompanying a service member on permanent change of station), have held a license in another state for at least one year, be in good standing everywhere you hold a license, have met that state's education and experience requirements, have passed any required exam, and have no disqualifying discipline or criminal history. The fingerprint clearance card is still required. If you are moving to Arizona, this is often the cleaner route. See moving states as a BCBA and licensing for military spouses.

Can you work in Arizona without an Arizona license?

Three ways exist, each narrow.

• Twenty days a year. A.R.S. 32-2091.08(A)(4) exempts someone "who resides outside of this state and who is currently licensed or certified as a behavior analyst in that state" if the work is within their customary practice, does not exceed 20 days per year, and the client is told of "the limited nature of these activities and services and that the behavior analyst is not licensed in this state."
• Out-of-state telehealth registration. Arizona's general interstate telehealth law, A.R.S. 36-3606, lets a health care provider licensed in another state provide telehealth to people in Arizona after registering with the Arizona board that licenses the comparable profession. Behavior analysts fall within that law's definition of health care provider, and the board's fee rule sets a $600 fee "to register as an out-of-state health care provider of telehealth services" (R4-26-402(B)). The registrant needs a current, unrestricted license in another state that is substantially similar to Arizona's, professional liability insurance, an Arizona statutory agent, and an annual update; registrants may not provide in-person services or open an Arizona office. A BCBA who lives in a state with no behavior analyst license has no home license to register. Our sister site covers this law in Arizona's telehealth provider registration.
• Temporary license. A.R.S. 32-2091.06 allows a temporary license only when the board requires an additional exam, lasting until the end of the month in which you receive the results.

Arizona's registration is a feature of Arizona law, not a national shortcut. Do not assume another state offers one; check each state where your clients are. See ABA telehealth across state lines.

Who else is exempt?

A.R.S. 32-2091.08 exempts certified school behavior analysts within school duties, supervised government employees using "assistant" or "associate," students and trainees in a defined program under supervision, university faculty in certain roles, and "a noncredentialed individual who delivers applied behavior analysis services under the extended authority and direction of a licensed behavior analyst," who must use a title such as "ABA technician," "behavior technician" or "tutor." That last exemption covers RBTs and, in Arizona, BCaBAs as well, since there is no assistant license.

How does renewal work in Arizona?

Licenses renew every other year by the last day of your birth month, in odd or even years depending on your license number (A.R.S. 32-2091.07). The first license fee is prorated to that date. Renewal requires a report of any discipline elsewhere, including sanctions by "a state or national behavior analysis ethics committee," and, for the first renewal, a fingerprint clearance card.

Rule R4-26-409 requires 30 hours of CE per license period, at least 4 in ethics, prorated in the first period at 1.25 hours per whole month. BACB-approved providers count, as does attending a board or committee meeting (three hours for a half-day session). An expired license can be reinstated with a fee within two months; after that, for up to a year, you also prove competency. Beyond a year you reapply. See CE requirements across states.

One more point for agencies: A.R.S. 32-2091.14 requires AHCCCS, Arizona's Medicaid program, to recognize licensed behavior analysts as behavioral health professionals eligible for reimbursement. Enrollment is a separate step; see Medicaid and payer enrollment for ABA.

How do we help with an Arizona license?

We prepare, organize and track the many third-party pieces: the supervisor's experience verification, transcripts, coursework proof, license verifications, the DPS clearance card application and the BACB exam verification request. You review, sign and submit everything yourself. The BACB has warned that letting another person or entity complete a licensure application on your behalf "may be a violation of state law," and we never ask for your board login.

Our Full State License Application is $749 and License by Endorsement is $599 per state. Board and DPS fees are separate. See pricing and the Arizona state page.