Most behavior analyst laws exempt licensed psychologists, and often counselors, social workers and other licensed professionals, practicing ABA within their own scope and competence. Texas, Illinois and Louisiana bar them from using behavior analyst titles; Ohio bars calling themselves applied behavior analysts. The exemption applies only in the state where the professional is licensed.
Applied behavior analysis did not start with licensing laws, and many licensed professionals used it before those laws existed. So nearly every behavior analyst licensing act has a clause for other professions. The typical version says the act does not stop a licensed psychologist, or another licensee, from practicing ABA within the scope of their own license, education, training and competence. The details are what matter: which professions are listed, what they may call themselves, and whether people working under them are covered too.
How do the exemptions read, state by state?
Texas
TDLR lists licensed psychologists, "if the applied behavior analysis services provided are within the scope of the licensed psychologist's education, training, and competence," and "other licensed professionals" on the same condition. Only TDLR licensees may use the titles "licensed behavior analyst" or "licensed assistant behavior analyst."
Ohio
Ohio exempts licensed psychologists and licensed counselors, social workers and marriage and family therapists practicing ABA within their education, training and experience, and people acting under their authority and direction if the licensee signs an attestation of responsibility. It also exempts any licensed professional "who, in the offering or rendering of services, does not represent oneself ... by incorporating the term 'applied behavior analyst,'" within their scope (Ohio Rev. Code 4783.02(B) and (C)).
Illinois
The act does not prohibit a clinical psychologist, social worker, psychiatric nurse, speech-language pathologist, audiologist, professional counselor, clinical professional counselor, clinical social worker or marriage and family therapist from performing or advertising ABA activities consistent with Illinois law, their training and their profession's ethics code, "so long as the individual does not use the titles" reserved for licensees (225 ILCS 6/20(c)(3)). In the other direction, behavior analyst licensees may not practice speech-language pathology or audiology without that license (225 ILCS 6/20(e)).
Nevada
Nevada's chapter does not apply to licensed physicians, dentists, psychologists, marriage and family therapists, clinical professional counselors, social workers, occupational therapists and therapy assistants, and certain alcohol, drug and gambling counselors, among others (NRS 641D.110).
Washington
Washington exempts an individual holding another Washington credential practicing within that profession's scope (RCW 18.380.030(1)). The Department of Health's FAQ says ABA is within the scope of counselors, marriage and family therapists, social workers and psychologists, and that each "must determine if they have the training, education, or competency to provide ABA services." A licensed psychologist with an active Washington credential may also supervise LABAs and CBTs, but the department says Washington psychologists are not approved supervisors for training toward state ABA licensure.
Virginia
"The provisions of § 54.1-2957.16 shall not be construed as prohibiting any professional licensed, certified, or registered by a health regulatory board from acting within the scope of his practice" (Va. Code § 54.1-2957.17(A)).
Louisiana
Two exemptions: human service professionals licensed, certified or registered by Louisiana working within their scope and competence, and licensed psychologists practicing ABA within their education, training and expertise, including people under a psychologist's extended authority. Psychologists and those under them may not represent themselves as behavior analysts or licensed or certified assistants without the Louisiana credential (R.S. 37:3715(1) and (9) as enacted; board rules, Chapter 2).
New York
New York's Article 167 says nothing in it limits the scope of any other licensed profession. It also allows a multidisciplinary team to implement an ABA plan if the team includes a licensee under Article 167 or certain other articles. Unauthorized team members may not create, modify or terminate an ABA plan, diagnose, assess or evaluate patients, or develop assessment-based treatment plans (Education Law § 8807).
Oregon
Oregon builds other professions into the technician side: a registered behavior analysis interventionist may be supervised by a "licensed health care professional" whose scope includes ABA and who is licensed by one of eight Oregon boards, including psychology, counseling, social work, occupational therapy and speech-language pathology (ORS 676.802(2) and 676.815).
What do these exemptions not cover?
- Titles. Texas, Illinois, Louisiana and Ohio all keep the behavior analyst titles for their own licensees.
- Practice beyond competence. Every exemption we read is conditioned on the professional's education, training or competence.
- Another state. An exemption follows the professional's license in that state. A psychologist licensed in Ohio has no Texas exemption. PSYPACT is a psychology compact, not an ABA one; see our sister site's note that PSYPACT does not cover master's-level clinicians.
- The BACB's rules. A psychologist can be exempt under state law and still not qualify as a BACB supervisor. The BACB accepts ABPP-certified psychologists as BCaBA supervisors only until December 31, 2026.
- Payers. Exemption from licensing does not decide whether a payer will credential a psychologist or counselor as an ABA provider.
When should a psychologist or counselor get a behavior analyst license anyway?
When you want to use the title, when a payer or employer asks for it, when you supervise BCaBAs or RBTs under BACB rules, or when you practice in a state whose exemption does not clearly cover your profession. Dual-licensed clinicians often hold both because it removes the argument.
Should dual-licensed clinicians get a review first?
A $149 Readiness Review compares your existing licenses with each state's exemption and tells you where a behavior analyst license would add something. If you hold BCBA certification and decide to apply, our Full State License Application ($749 per state) or License by Endorsement ($599 per state) prepares the package for you to review, sign and submit. See the state license index and BACB certification versus a state license.
Common questions
- Do psychologists need a behavior analyst license to provide ABA?
- Usually not, if the work is within their education, training and competence. Texas, Ohio, Illinois, Nevada, Washington, Virginia and Louisiana all exempt licensed psychologists in some form. They generally may not use the behavior analyst titles without the license.
- Can a licensed counselor practice ABA without a behavior analyst license?
- In several states, yes. Illinois lists professional counselors and clinical professional counselors, Ohio lists licensed counselors, and Washington's Department of Health says ABA is within counselors' scope. Each requires the counselor to be competent and to avoid the reserved titles.
- Does a psychologist's exemption work in another state?
- No. The exemption depends on holding that state's psychology license. A psychologist practicing ABA in a second state needs to qualify under that state's own exemption, which generally means holding authority to practice psychology there, or a behavior analyst license there.
- Can a psychologist supervise an RBT or BCaBA?
- Under some state laws, yes, but the BACB has its own rules. The BACB accepts ABPP-certified psychologists as BCaBA supervisors only until December 31, 2026, and RBT supervisors must hold BCaBA or BCBA certification.
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