Virginia Behavior Analyst Licensing

Virginia licenses two levels of behavior analyst through the Board of Medicine, with an Advisory Board on Behavior Analysis that recommends the licensure criteria and standards of conduct. The law is Va. Code § 54.1-2957.16, and the regulations are 18VAC85-150, "Regulations Governing the Practice of Behavior Analysis." It is unlawful in Virginia to practice, or hold yourself out as practicing, as a behavior analyst or assistant behavior analyst, or to use the titles "Licensed Behavior Analyst" or "Licensed Assistant Behavior Analyst," without the board's license.

What does Virginia require for a first license?

The statute ties the license to BACB certification. The board's criteria must include documentation that the applicant "is currently certified as a Board Certified Behavior Analyst," practices under the BACB ethics code, and has not had a license or certification suspended or revoked and is not the subject of disciplinary proceedings by the certifying board or another jurisdiction (§ 54.1-2957.16(B)). The regulation repeats the point: applicants "shall hold current certification as a BCBA or a BCaBA" obtained by meeting the BACB's qualifications and passing its exam (18VAC85-150-60).

For initial licensure, 18VAC85-150-50 asks for:

1. The completed application and fee.
2. Verification of BACB certification.
3. Verification of practice as required on the application form.
4. If you are licensed or certified anywhere else, verification that no discipline has been taken or is pending there.
5. Verification from the BACB on any disciplinary action taken or pending.

Item 4 surprises people who think of Virginia as a "first license" state. If you hold any license elsewhere, even an inactive one, the board wants to hear about it.

How does endorsement work in Virginia?

18VAC85-150-51 sets a short endorsement path for someone already licensed elsewhere. The applicant submits:

• Evidence of a current, active license in good standing in a U.S. jurisdiction or Canada.
• The completed application and fee.
• Verification of BACB certification.
• "A current report from the National Practitioner Data Bank."

The NPDB self-query is the step behavior analysts forget, because few ABA employers ask for one. You order it yourself from the NPDB. Endorsement does not remove the certification requirement: you still need current BCBA or BCaBA status. See BCBA license by endorsement for how Virginia compares with other states.

How much is a Virginia license?

18VAC85-150-40 lists the fees:

• Initial license: $130 for a behavior analyst, $70 for an assistant.
• Active renewal: $135 for a behavior analyst, $70 for an assistant. Inactive renewal is $70 and $35.
• Late renewal within one cycle: an extra $50 or $30.
• Reinstatement after a lapse of two years or more: $180 or $90.
• Letter of good standing or verification to another jurisdiction: $10.

Fees are not refundable.

When do Virginia licenses renew?

Every two years, in your birth month, in odd-numbered years (18VAC85-150-70). A license not renewed by the first day of the month after your renewal month is lapsed, and practicing on a lapsed license may be grounds for discipline. A license lapsed two years or less can be renewed with the renewal fee, the late fee and proof of CE.

Virginia sets its own CE requirement. Under 18VAC85-150-100, a behavior analyst attests to 32 hours and an assistant to 20 hours in the biennium, approved and documented by a BACB-recognized sponsor, with 4 hours related to ethics. Up to two hours can come from unpaid services to low-income clients through a local health department or free clinic, at one CE hour for every three hours of service. You are exempt for your first renewal after initial licensure. Keep the documentation for four years: the board runs random audits and expects records within 30 days. See CE requirements across states.

Are Virginia's supervision rules stricter than most?

Virginia is more specific than most states. Under 18VAC85-150-120:

• A written supervisory agreement between the licensed behavior analyst and the licensed assistant must cover the assistant's domains of competency and the nature and frequency of supervision. Both keep a copy for the board.
• Formal supervision is real-time, meaning "live and person-to-person": direct observation with feedback, one-to-one meetings, or group meetings. Email and phone contact are encouraged but "may not be considered formal supervision."
• Supervision must happen "not less than once every four weeks with each supervision session lasting no less than one hour."

The statute also requires an assistant applicant to document that their work "is supervised by a licensed behavior analyst" (§ 54.1-2957.16(C)(4)). A Virginia assistant license is never a license to practice alone. More in supervision rules for licensed assistant behavior analysts.

Where do RBTs fit in Virginia?

Virginia has no technician credential. 18VAC85-150-130 says unlicensed personnel may be supervised by a licensed behavior analyst or licensed assistant and may perform nonclient tasks and "certain routine client-related tasks that, in the opinion of and under the supervision of" a licensee, "have no potential to adversely impact the client or the client's treatment plan and do not constitute the practice of behavior analysis." That wording is narrower than the paraprofessional exemptions in Texas or Illinois, so agencies should be careful about how they describe technician duties in Virginia. Also exempt under § 54.1-2957.17: other health-regulatory-board licensees within their scope, students in a defined program, people completing BACB supervised experience under a BACB-approved licensed supervisor for up to five years, and school employees within their regular duties. See do RBTs need a state license or registration?

How can we help with a Virginia license?

We prepare, organize and track the file, including the NPDB report, the BACB verification and any out-of-state discipline verifications. You review, sign and submit the application yourself. The BACB has warned that allowing another person or entity to complete a licensure application on your behalf "may be a violation of state law," so we never ask for your board login.

License by Endorsement is $599 per state, a first license under our Full State License Application is $749, and the Assistant Behavior Analyst License is $399. Board and NPDB fees are separate. See our pricing and the Virginia state page.