Maryland Behavior Analyst Licensing

Maryland licenses behavior analysts through the State Board of Professional Counselors and Therapists, advised by a Behavior Analyst Advisory Committee. The board's page says legislation passed in 2014 required it to regulate behavior analysis, and "beginning January 2015, individuals practicing behavior analysis must be licensed." The law is Health Occupations Article, Title 17, Subtitle 6A, and the regulations are COMAR 10.58.16. Maryland's rules set out one credential, the licensed behavior analyst; they contain no assistant license.

Who qualifies for a Maryland license?

COMAR 10.58.16.04 requires that you:

1. Be of good moral character.
2. Be at least 18.
3. Hold current BCBA or BCBA-D certification, "verified by the Board with the Behavior Analyst Certification Board."
4. Have a master's degree or higher "from a behavior analysis educational course sequence that is approved by the Behavior Analyst Certification Board."
5. Demonstrate oral and written competency in English as the board requires.

The board waives the degree requirement in item 4 for anyone "certified by the Behavior Analyst Certification Board on or before December 31, 2014" and in good standing.

What do you submit?

COMAR 10.58.16.05 lists the application form, a criminal history records check under Health Occupations Article § 17-501.1, an official transcript showing you met the BACB's minimum degree requirement when you were certified, and a copy of your BACB certificate showing current good standing.

Order matters for the background check. The board's behavior analyst page says, "Applicants must obtain a CHRC before submitting their application," and asks for a copy of the CHRC receipt with the application. The required CHRC form comes with the application packet.

What changed in 2026?

The board moved online. Its page says it "will transition to an online-only application process" beginning June 20, 2026, with the online application system launching July 1, 2026, and it maintains an online portal for the LBA license. The same notice sets expectations:

• "Applicants should allow at least 30 to 45 business days for the processing of a completed initial application."
• If the board asks for more information, the timeline "may restart or be extended," with another 30 to 45 business days from the date the file becomes complete.
• Files flagged for compliance review because of criminal history, prior discipline, adverse licensure history or incomplete disclosure need "a minimum of 90 business days."

The board also lists common reasons for delay, including transcripts not sent directly from the school, missing criminal history results, name mismatches across documents, missing out-of-state license verifications, failure to disclose history and slow responses to staff. Its advice is to "not submit an application until all required documents are ready." See why ABA license applications take as long as they do and application mistakes that cost weeks.

Do you need a Maryland license for telehealth?

Yes. COMAR 10.58.16.13 says "a telehealth practitioner shall be licensed in Maryland when providing telehealth services to a client located in the State." The same rule sets practice standards that matter for multistate telehealth teams:

• Verify the client's identity with government photo ID, an insurance or Medicaid or Medicare card, or documentation of date of birth and home address.
• At the first encounter, disclose your name, Maryland license number and contact information.
• Obtain informed consent, including from a parent or guardian when State law requires it.
• For synchronous sessions, confirm "whether the client is in Maryland" and the client's specific location, identify everyone present, and have a backup contact method.
• Establish emergency protocols with contact information for emergency services at the client's location.
• Never treat "based solely on an online questionnaire."

Confirming the client's location each session is the practical step that protects a multistate practice. See ABA telehealth across state lines.

How does supervision work without an assistant license?

Maryland regulates the supervisor rather than the supervisee. COMAR 10.58.16.12 describes three service models: tiered, direct and consultative. In a tiered model, the licensed behavior analyst may use supervisees "in accordance with this regulation and requirements set by the Behavior Analyst Certification Board," is "responsible for all aspects of clinical direction, supervision, and case management," and may delegate only when the task can be done safely and the delegation follows current BACB supervision requirements. Supervisees deliver protocols "under the close and ongoing supervision of a licensed behavior analyst."

COMAR 10.58.16.14 adds that supervision runs "for the duration of clinical service provision," from assessment through case closure, and that the licensed behavior analyst is "ultimately responsible and accountable" for services and outcomes. A consultative arrangement requires a written contract covering frequency, location and expectations. For BCaBAs and RBTs in Maryland, this means the BCBA's license and BACB supervision standards carry the compliance load. See do RBTs need a state license or registration?

How does renewal work?

Licenses renew every two years on the date the board sets. Under COMAR 10.58.16.06 you submit the renewal form, evidence of current BACB certification (which the board verifies), another criminal history records check, and evidence of any CE the board requires. COMAR 10.58.16.07 ties CE to the BACB: complete "continuing education units in accordance with the requirements of the Behavior Analyst Certification Board" and keep documentation for four years. A behavior analyst who has not renewed and is not on inactive status "may not practice behavior analysis." See BACB recertification and state license renewal.

Where do we fit in a Maryland application?

We prepare, organize and track: the CHRC before you apply, the official transcript sent directly from your school, the BACB certificate, out-of-state verifications and disclosure answers drafted for your review. You review, sign and submit through the board's online portal. 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 portal login.

License by Endorsement is $599 per state and the Full State License Application is $749. Board and background check fees are separate. See pricing and the Maryland state page.