Florida and Behavior Analysts Without a State License

Florida is one of the ten states without a behavior analyst license. It does not appear on the BACB's list of states with licensure laws, and no Florida board issues a "licensed behavior analyst" credential. For BCBAs in Florida, BACB certification and payer or program enrollment are the gate, not a license.

What does Florida law say about behavior analysts?

The key statute is Florida Statutes 393.17, in the chapter on developmental disabilities. It does two things:

• It lets the Agency for Persons with Disabilities "establish a certification process for behavior analysts in order to ensure that only qualified employees and service providers provide behavioral analysis services to clients," by rule.
• It requires that the agency "shall recognize the certification of behavior analysts awarded by a nonprofit corporation that adheres to the national standards of boards that determine professional credentials" and whose certification undergoes regular psychometric review and validation.

Any certification process the agency adopts by rule must cover scope of practice, qualifications including training and testing, continuing education, standards of performance, and decertification. The second clause describes national certification such as the BACB's. In practice, Florida's disability services system builds on certification rather than a state license.

Who are Florida Certified Behavior Analysts?

A small legacy group. The BACB explains that in October 2003 it "assumed all certifying responsibilities for certificants of the defunct Florida Behavior Analysis Certification Program under the Florida Department of Children and Families." People certified under that program may keep using the Florida Certified Behavior Analyst (FL-CBA) designation. They carry the responsibilities and privileges of BCBA certification, including its ethics and maintenance requirements, but the BACB says "the FL-CBA designation is valid only in Florida." An FL-CBA whose certification expires must reapply under current BCBA requirements.

Does Florida's telehealth law cover behavior analysts?

In part, and this is a detail most guides miss. Florida's telehealth statute defines a "telehealth provider" to include anyone who provides health care services by telehealth and "who is licensed or certified under s. 393.17," along with a long list of licensed professions (Fla. Stat. 456.47(1)(b)). So a behavior analyst certified under the APD provision is a telehealth provider for Florida's practice standards and record rules.

The same statute lets a professional licensed in another state register as an out-of-state telehealth provider, and that registration covers behavior analysts certified under s. 393.17. Conditions include an active, unencumbered out-of-state license "substantially similar to a license issued to a Florida-licensed provider" in that definition, no discipline in the five years before applying, a registered agent in Florida, and liability coverage. A registrant may not open a Florida office or provide in-person care in Florida (Fla. Stat. 456.47(4)). For how the registration works for physicians, see our sister site's post on Florida telehealth registration.

How big is Florida's ABA workforce?

Large enough to matter. When the BACB surveyed people whose RBT certification expired in 2024, Florida residents made up 10% of the 30,018 invited, third behind California (15%) and Texas (12%) (BACB Newsletter, December 2025). Florida BCBAs who supervise that workforce across state lines, or who move north, meet the licensing states quickly.

What should a Florida BCBA watch for?

• Keep BACB certification current. In Florida it carries the weight a license would elsewhere. The BACB gives BCBAs 30 days after the recertification date to reinstate before the certification expires.
• Clients in Georgia or Alabama. Both license behavior analysts. Serving a client there, even by telehealth, likely needs that state's license (telehealth across state lines). Georgia offers a temporary license of up to 30 days a calendar year for short engagements (temporary practice).
• Moving to a licensing state. You will apply on certification, since Florida issues no license to verify. Ohio's statute specifically allows a certificate for someone with a private certification as a behavior analyst from a state that does not license them (moving states).
• Payer rules. Each Florida payer and program sets its own enrollment requirements (after the license).

Can we help with a Florida license?

There is no Florida behavior analyst license to apply for. We help Florida BCBAs with licenses in the states their work reaches: License by Endorsement (BCBA), $599 per state, or a Full State License Application, $749 per state, which you review, sign and submit yourself. An ABA Licensure Readiness Review, $149, maps which states you need. See pricing and the Florida page.