Behavior Analyst Licensure in Tennessee: BCBA and State License Requirements

The committee issues exactly two licences, and rule 1180-05-.03(3) attaches the right to use the titles Licensed Behavior Analyst and Licensed Assistant Behavior Analyst to holding the matching licence.

Rule 1180-05-.03(2) makes it unlawful for anyone not licensed under T.C.A. §§ 63-11-301 et seq. to represent themselves as licensed, including through titles on signs, stationery, telephone listings and calling cards.

The exemption section adds a title nuance: behavior analysts who practise with nonhumans (§ 63-11-306(4)) and people whose teaching or research of behavior analysis does not involve delivering direct behavior analytic services (§ 63-11-306(7)) may use the plain title behavior analyst without a licence, but may not present themselves as LBAs or LABAs unless the committee issued their credential.

For exempt unlicensed deliverers the bar is lower still: they may not represent themselves as professional behavior analysts at all.

Tennessee writes no degree, coursework or fieldwork rule of its own.

The application must show the applicant is at least twenty-one (21) years of age, of good moral character and working to the certifying entity's ethical standards, holds no refused, revoked, suspended or restricted professional credential and has no pending complaint, allegation or investigation for unprofessional conduct unless the committee finds the conduct corrected or mitigated.

For the licence itself, an LBA applicant shows current BCBA or BCBA-D certification and an LABA applicant current BCaBA certification, each with no certifying-entity disciplinary action.

The rules then fix the documents: a passport-style photograph and certified birth certificate, proof of certification sent directly from the certifying entity, two character letters from professionals dated within the preceding 12 months, and a criminal background check sent directly from the vendor the committee identifies.

A legacy route exists for people qualified by the Department of Intellectual and Developmental Disabilities before July 12, 2012, if the requirements of T.C.A. § 63-11-307(c) are met.

Neither § 63-11-304 nor the saved rules chapter names a Tennessee examination for behavior analysts.

Licensure rides on the certification itself, and BACB certification follows the BCBA or BCaBA examination; the BACB's exam details are covered in the BCBA articles, not here.

The rules mention examinations only generically, in application processing: an application file may be closed if the applicant fails to take or retake required examinations within the specified time frame (1180-05-.07(7)(b)).

Whether the committee requires any additional state-specific exam is not stated in the sources read, so read the current application instructions before filing.

Supervision is load-bearing at both lower levels.

An LABA licence depends on proof of ongoing supervision by an LBA who is currently certified as a BCBA or BCBA-D, in line with the certifying entity's requirements for supervising assistants, so losing a supervisor is a licensing problem, not just an employment one.

Unlicensed deliverers are exempt under § 63-11-306(2) when they work under the extended authority and direction of an LBA, or of an LABA who is supervised by an LBA — a condition the LABA's licence already imposes, since § 63-11-304(a)(5)(C) requires ongoing supervision by an LBA.

Students, interns and postdoctoral fellows in a defined program of study are exempt when directly supervised by an in-state LBA or an instructor in a BACB approved course sequence, and must use trainee titles such as behavior analysis student, intern or trainee.

People pursuing experiential training consistent with the BACB's experience requirements are exempt when an in-state LBA who meets BACB supervisor requirements supervises the experience under BACB standards.

Supervision ratios for exempt unlicensed deliverers are not stated in the sources read.

The rules define applied behavior analysis as the design, implementation and evaluation of environmental modifications by a behavior analyst to produce socially significant improvements in human behavior, including functional assessment and analysis.

The practice expressly excludes psychological testing, neuropsychology, psychotherapy, cognitive therapy, sex therapy, psychoanalysis, hypnotherapy and long-term counseling as treatment modalities, and no licence authorises administering, dispensing or prescribing drugs or practising medicine.

Other human services professionals licensed, registered or certified by the state are exempt when working within the scope of their professions, training and competence, so a licensed psychologist or counselor does not need the LBA for work inside their own scope.

Family members implementing ABA procedures under a licensee's extended authority are exempt but, like unlicensed deliverers, may not represent themselves as professional behavior analysts, and providers of general ABA services to organizations are exempt where the services benefit the organizations and involve no direct services to individuals.

Section 63-11-306 contains no explicit school-employee exemption.

The rules give reciprocity applicants a procedure, not a short-cut: comply with the same licensure-by-criteria steps as everyone else, except the two good-moral-character letters (1180-05-.05(3), waiving the clauses at 1180-05-.05(1)(f) and 1180-05-.05(2)(g)).

An applicant who holds or has ever held a behavior-analysis licence or certificate in another jurisdiction must file a verification from that regulator showing active status and good standing, or standing at the time it lapsed.

The committee's page adds two practice points for movers: a provider must be licensed in Tennessee to treat a client in Tennessee, including by telehealth, unless operating in a free clinic environment, and active-duty servicemembers and military spouses have a portability application route under the Military Families Licensing Recognition Act.

The statute's substantive reciprocity standard, T.C.A. § 63-11-308, is named in the rule's authority line but its text was not saved, so confirm eligibility with the committee.

A licence renews by the expiration date on the initial licence: a signed renewal application, the renewal fee plus the $10 state regulatory fee, proof of current B.A.C.B. certification, and proof of three (3) continuing education hours on cultural diversity.

Fees in effect since May 7, 2025: LBA renewal $150 biennial, LABA $100, application $50, late renewal $100, reinstatement $100.

Licensees must maintain their national certification and meet the certifying entity's continuing education requirements; licensees not certified through the BACB accrue hours under BACB standards.

The committee adopts the BACB's Ethical Code, with state law and committee position statements controlling in a conflict.

Retired licensees re-enter on current B.A.C.B. certification, a reactivation application and fees, with no criminal or practice-act violations that would prohibit initial licensure, if out of clinical practice or an educational setting two (2) years or less or licensed in good standing and in continuous practice in another state when retired.

Out longer than two (2) years adds six (6) months of clinical supervision by a licensed behavior analyst holding BACB or BACB-D certification.

The saved history shows two recent changes.

The 2023 amendment (2023, ch. 426, § 7) added § 63-11-304(b), a decision clock: within sixty (60) days of receiving a completed application for initial licensure, the board must render a decision or inform the applicant of the need to appear, and a completed application is defined as one that satisfies all statutory and board rule requirements.

The fee schedule was then amended effective May 7, 2025, producing the fees on this page.

The cultural-diversity CE requirement and the current renewal provisions date from rule amendments effective August 17, 2021, after a 75-day stay.

Neither change touched the certification route or the exemption list in the saved text.

A completed Tennessee application does not have to sit idle.

After a committee designee's initial determination that the file shows all requirements for licensure, renewal or reinstatement are met, a temporary authorization to practice may issue under T.C.A. § 63-1-142; it lasts until the committee and the Board of Examiners in Psychology make a final decision, for no more than six months.

Two clocks punish drift: an application is deemed abandoned if not completed within 60 days after initial submission and review, or within 60 days of a request for more information, and an abandoned file requires a new application.

For a BCBA relocating for a job, filing a complete file the first time is what unlocks the temporary authorization.