Tennessee Behavior Analyst Licensing

Tennessee licenses two levels of behavior analyst. The Licensed Behavior Analyst and Licensed Assistant Behavior Analyst are issued by the Applied Behavior Analyst Licensing Committee, with approval ratified by the Board of Examiners in Psychology, under T.C.A. § 63-11-301 and following and the committee's rules at Tenn. Comp. R. & Regs. chapter 1180-05. Under rule 1180-05-.03, you must hold a current Tennessee license before practicing as a licensed behavior analyst or assistant in Tennessee, unless an exemption in T.C.A. § 63-11-306 applies.

Tennessee's requirements are simple. Its paperwork is not.

Who qualifies for a Tennessee license?

Rule 1180-05-.04 says the committee and board "shall license no person as a behavior analyst unless at the time of application" the applicant is a BCBA or BCBA-D "credentialed through the nationally accredited behavior analyst certification entity" and "is not the subject of any disciplinary actions by the certifying entity." (A separate path covers people qualified by the Department of Intellectual and Developmental Disabilities before July 12, 2012.)

An assistant must be a BCaBA with no pending certifier discipline and must provide "proof of ongoing supervision by a licensed behavior analyst (LBA) who is certified as a BCBA or BCBA-D." A Tennessee assistant always practices under supervision; see supervision rules for licensed assistant behavior analysts.

Which documents go into the application packet?

Rule 1180-05-.05 lists the pieces. For a behavior analyst:

1. The completed application, answered "truthfully and completely," with all fees. The application must be "sworn to and signed by the applicant and notarized."
2. A passport-style photograph taken within the preceding 12 months.
3. A certified copy of your birth certificate showing you are at least 21.
4. Proof of certification sent "directly from the certifying entity to the Committee's administrative office," confirming good standing.
5. Two recent original letters from ABA professionals or professionals in a related field, on the writer's letterhead and dated within 12 months, attesting to your character and ethics.
6. Disclosure of any criminal conviction other than minor traffic violations, any denial or discipline by another state or certifying entity, any revocation or restriction, and any civil judgment or settlement in which you were a defendant, including malpractice and breach of contract.
7. A criminal background check sent directly from the vendor named in the committee's materials.
8. A license verification from every agency that has ever licensed or certified you to practice ABA, "regardless of the type or level," showing status and good standing.
9. A certification that you have read the statute and the committee's rules.

Two items catch out-of-state applicants. The certified birth certificate is rare among ABA boards. And the civil-suit disclosure covers settlements, not only judgments, so a settled business dispute belongs on the form. See disclosing discipline on an ABA license application.

How much does a Tennessee license cost?

Rule 1180-05-.06 sets the fees:

• Behavior analyst: $50 application, $40 license, $10 state regulatory fee. Biennial renewal is $150 plus the $10 regulatory fee. Late renewal is $100 and reinstatement $100.
• Assistant: $50 application, $15 license, $10 state regulatory fee. Biennial renewal is $100.

Fees are paid by money order or certified, personal or corporate check, payable to the Applied Behavior Analysts Licensing Committee. The application fee is not refundable; the license fee can be refunded if you withdraw.

Is there reciprocity in Tennessee?

Yes, though it saves less than the name suggests. Rule 1180-05-.05(3) says a reciprocity applicant "must comply with the procedures and requirements set forth in rule 1180-05-.05," except the good-moral-character letters. Everything else, including the notarized application, birth certificate, photo, direct certification proof, background check and verifications from every jurisdiction, still applies. In practice a licensed BCBA moving to Tennessee assembles nearly the same packet as a first-time applicant. See BCBA license by endorsement.

Can you start working before the committee meets?

Possibly. Rule 1180-05-.07(3) allows "a temporary authorization to practice," under T.C.A. § 63-1-142, once a committee designee makes an initial determination that "the completed file evidences that the applicant has met all of the requirements for licensure." It lasts until the committee and board make a final decision, for no more than six months. Approvals of all applications are "made and ratified by the Committee and the Board," so the meeting calendar matters.

Why do Tennessee files get closed?

Because the abandonment rule is short. Under rule 1180-05-.07(7), an application "shall be deemed abandoned and closed if it has not been completed by the applicant within sixty (60) days after it was initially submitted and reviewed," or if you do not answer a request for more information within 60 days of receiving it. A closed file needs a new application and fee. Order the verifications, the background check and the BACB proof before you send the packet, not after. See why ABA applications take as long as they do.

How does renewal work?

Renewal is due by the expiration date on your license. Under rule 1180-05-.08 you submit the signed renewal form, the renewal and regulatory fees, "proof of current national certification by B.A.C.B.," and proof of three CE hours on cultural diversity. The committee mails a renewal form, but "failure to receive such notification does not relieve the individual of the responsibility."

Rule 1180-05-.12 makes BACB certification the main CE vehicle: licensees must maintain national certification and its CE. The three cultural diversity hours are the Tennessee-specific item. The course need not be about cultural diversity, but its title, objectives or curriculum must "clearly indicate attention to cultural diversity." BACB ethics or supervision hours do not count unless they say so. See CE requirements across states.

How do we help with a Tennessee license?

Tennessee is a paperwork state, which is the work we do. We prepare the packet, request the BACB proof and every license verification, line up the background check vendor, chase the reference letters, and watch the 60-day clock. You review the application, swear to it before a notary, sign it and submit it. The BACB has warned that letting another person or entity complete a licensure application on your behalf "may be a violation of state law."

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