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Behavior Analyst Licensing

Michigan Behavior Analyst Licensing

Michigan licenses behavior analysts and assistant behavior analysts through the Department of Licensing and Regulatory Affairs and its Board of Behavior Analysts. The rules lean on BACB certification at every step: to apply, to apply by endorsement, to renew and throughout the license. Human trafficking training, a sex-offender screen and disclosure of every health license you have held are the Michigan-specific pieces.

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5 min read · by White Glove ABA
A behavior analyst observing a group social skills session in a clinic playroom.

Michigan's Department of Licensing and Regulatory Affairs licenses behavior analysts under rule 338.1823. You need the application and fee, current BACB certification in good standing, no listed sex-offense conviction, human trafficking training and disclosure with verification of every health credential you have held. Endorsement applicants also show a current license elsewhere.

Michigan licenses behavior analysts under the Public Health Code (1978 PA 368). The Board of Behavior Analysts, created under section 18255 of the code (MCL 333.18255), works with the Department of Licensing and Regulatory Affairs (LARA), and the board's rules are Mich. Admin. Code R. 338.1801 to 338.1835. The BACB lists 2016 as Michigan's licensing year. There are two licenses: behavior analyst and assistant behavior analyst.

Michigan's rules are short because almost every requirement runs through the BACB. That makes the file simple, and it makes your BACB status the thing to watch.

What does Michigan require for a first license?

Rule 338.1823 says LARA "shall issue a behavior analyst license" to an applicant who:

  1. Provides a completed application on the department's form.
  2. Pays the required fee.
  3. "Has proof of current certification in good standing with the BACB."
  4. Has not been convicted of a listed offense under the Sex Offenders Registration Act (MCL 28.722). An applicant denied on that ground may request a hearing.

You must also meet the Public Health Code's general requirements. Two are spelled out in the board's rules.

Disclosure of every health credential. Anyone "who is or has been licensed, registered, or certified in a health profession or specialty by any other state, the United States military, the federal government, or another country" must say so on the application and satisfy MCL 333.16174(2), "which includes verification from the issuing entity showing that disciplinary proceedings are not pending against the applicant and sanctions are not in force." That covers any health credential, not only behavior analyst licenses. A former nursing or counseling license counts.

Human trafficking training. Under rule 338.1821 and MCL 333.16148, applicants and licensees must complete training in identifying victims of human trafficking covering the types and venues of trafficking, identifying victims and warning signs in health care settings, and reporting resources. It can come from a recognized health organization, a government agency, an approved educational program, or reading a qualifying journal article. It applies to initial licenses issued from January 7, 2024. LARA may audit, and a provider certificate or a self-certification statement with the required details serves as proof.

How does endorsement work in Michigan?

Rule 338.1824 makes endorsement simple. LARA "shall issue a behavior analyst license" to an applicant who provides the application and fee, "holds a current behavior analyst license in another state or in a province of Canada," has current BACB certification in good standing, and has no listed sex-offense conviction. The same disclosure and verification rule for every health credential applies.

In practice, a BCBA licensed elsewhere and a BCBA with no license file almost the same thing in Michigan. Endorsement matters mainly as the formal route under MCL 333.16186; the core requirement in both is the BACB. See BCBA license by endorsement.

What does the assistant license require?

The assistant license under rules 338.1823(2) and 338.1824(2) adds one item: "proof acceptable to the department that supervision will occur under a Michigan licensed behavior analyst in this state who is currently certified and in good standing with the BACB, and that the supervision satisfies current BACB supervision requirements." The supervisor must hold a Michigan license. The same proof is required at each renewal (rule 338.1827(2)). See supervision rules for licensed assistant behavior analysts.

What happens to your Michigan license if your BACB certification lapses?

Rule 338.1831 is one sentence: "A licensee shall keep active status certification with the BACB throughout the duration of the license cycle." Renewal under rule 338.1827 again requires "proof of current certification in good standing with the BACB." A BACB lapse is a Michigan licensing problem, not just a certification problem. Missing BACB recertification, or moving to voluntary inactive BACB status while still practicing, puts the Michigan license out of compliance.

The same logic applies to new BCBAs who previously held a Michigan assistant license. The BACB ends any other BACB credential 180 days after you pass the BCBA exam, so the assistant license, which depends on BCaBA certification, needs attention. See what happens to your RBT or BCaBA after the BCBA exam and BACB recertification and state license renewal.

Can Michigan behavior analysts practice by telehealth?

Yes, within Michigan's rules for licensees. Rule 338.1832 requires consent for treatment before a telehealth service under MCL 333.16284, proof of that consent kept in the record, practice within the licensee's scope, and "the same standard of care applicable to a traditional, in-person health care service." The rule speaks to Michigan licensees. It does not create a way for an out-of-state behavior analyst to treat Michigan clients without a Michigan license. See ABA telehealth across state lines.

What should you have ready before applying?

  • A BACB certification in good standing, with your recertification date checked against the Michigan license cycle.
  • A list of every health credential you have ever held anywhere, with contact details for each issuing agency so it can send verification.
  • A human trafficking training certificate that meets rule 338.1821.
  • For an assistant, the Michigan-licensed BCBA who will supervise you and your supervision agreement.

LARA's fee schedule, renewal period and any fingerprint step are set outside the board rules quoted here; confirm the current amounts on LARA's application before you pay.

How do we help with a Michigan license?

We prepare, organize and track: the credential history, every verification request, the training documentation, and the BACB status check. You review, sign and submit the application 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 LARA login.

License by Endorsement is $599 per state, the Full State License Application is $749, and the Assistant Behavior Analyst License is $399. State fees are separate. See pricing and the Michigan state page.

Common questions

Does Michigan accept BCBA certification for licensure?
Yes. Michigan's rules require proof of current BACB certification in good standing for the initial license, endorsement and renewal, and licensees must keep active BACB status throughout the license cycle.
What is the Michigan human trafficking training requirement?
Applicants and licensees must complete training on identifying victims of human trafficking that covers set topics, from an approved type of provider or a qualifying journal article (rule 338.1821).
Who can supervise a Michigan licensed assistant behavior analyst?
A Michigan-licensed behavior analyst who is currently BACB-certified and in good standing, with supervision meeting current BACB requirements. Proof is required to apply and to renew.
Do I have to disclose licenses I no longer hold when applying in Michigan?
Yes. Anyone who is or has been licensed, registered or certified in a health profession elsewhere must disclose it and supply verification from the issuing entity.

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