Behavior Analyst Licensure in Washington: BCBA and State License Requirements

Washington regulates at three levels and protects practice and titles separately.

Except as the exemptions in RCW 18.380.030 provide, no one may engage in the practice of applied behavior analysis without a licence or temporary licence, and a person who is not licensed may not represent himself or herself as a licensed behavior analyst or a licensed assistant behavior analyst.

The technician tier gets the same structure: outside those exemptions, a certification issued by the secretary is required to practise as a certified behavior technician, and that title is protected the same way.

For a job seeker this means the credential that matters on a Washington posting is the state one: a national certification is the route in, not the permission itself.

The statute writes a floor for each tier, and the rules fill it in.

An LBA applicant graduates from a recognized master's or doctorate program, completes a minimum of 225 classroom hours at graduate level instruction, and completes a minimum of 1,500 hours of supervised experience or an alternative approved by the secretary by rule.

The LABA needs a bachelor's degree, 135 classroom hours and a minimum of 1,000 hours.

The CBT needs a training program of at least 40 hours approved by the secretary.

Alongside all three sits the alternative: the secretary may accept a national credentialing entity's certification in lieu of the specific requirements, and the department's approval rule requires those certifications to meet or exceed the state's own qualifications plus current ANSI or NCCA accreditation.

Every applicant must also show good moral character and no current discipline.

The licensed behavior analyst licence requires an examination: the statute says successful completion of an examination approved by the secretary, and the application rule fills in what that means on the non-entity route — a national examination for the equivalent of an LBA from a professional credentialing entity.

The assistant licence lists no examination in either the statute or the LABA application rule, which asks for the degree, classroom hours and supervised experience.

A CBT applicant is instead evaluated by the training program supervisor on demonstrated entry level competency.

Neither RCW 18.380 nor chapter 246-805 WAC names a Washington-specific exam on top of the national one.

Trainee hours have their own rulebook.

The LBA trainee completes 1,500 hours within five years of the start date, participates at least 10 and no more than 30 hours per week, gets supervision at least every two weeks, and has at least five percent of each month's hours under the supervision of an LBA with at least one year of full-time equivalency practice (or an equivalent certification) who is not related to, subordinate to, or employed by the trainee.

No more than half the hours may be direct implementation.

The LABA track mirrors this at 1,000 hours.

Supervision does not end at licensure either: a clinical supervisor reviews an LABA's progress at least every six months, holds a face-to-face contact each month and observes a treatment session quarterly, while a CBT needs two face-to-face contacts a month and direct supervision of five percent of monthly hours.

RCW 18.380.050(2) makes proof of ongoing supervision part of the LABA and CBT application itself.

The chapter defines the practice of applied behavior analysis as designing, implementing and evaluating instructional and environmental modifications to produce socially significant improvements in human behavior, functional assessment and analysis, and the systematic use of consequences, motivating operations and antecedents to build behavior.

It draws the outer line against neighboring professions, excluding psychological testing, diagnosis, neuropsychology, psychotherapy, cognitive therapy, sex therapy, psychoanalysis, hypnotherapy and counseling as treatment modalities — and behavioral techniques used alone are not the practice of applied behavior analysis at all.

The eight exemptions name who may work without a state credential: state-credentialed professionals practising within their scope; federal employees under their agency's direction; school employees in their regular duties for their school employer only; matriculated students in a defined course, internship, practicum or program of study, supervised by faculty or an LBA and using a trainee title; people pursuing supervised experiential training under an LBA or a supervisor meeting a national certifying entity's requirements; family members and guardians under supervision; analysts working with nonhumans; and analysts serving organizations rather than individuals.

Two doors exist for credential holders from elsewhere.

Reciprocity under RCW 18.380.090 turns on the secretary determining that the other state's or province's licensing standards are substantially equivalent; the rule adds verification from that state showing an active, unrestricted credential, plus verifications from every other state where the applicant is or was credentialed.

The temporary licence is the faster, harder-capped route, and the WAC names only another state as the qualifying credential: the applicant must hold an active, unrestricted licensed behavior analyst credential from another state, face no pending investigation or conditional or restricted licence, clear the Washington criminal background check and meet all other licensure conditions, including a completed FBI fingerprint card.

It runs 180 days from issuance, carries the full LBA scope, and is never renewed, reissued or extended.

Every credential is valid for two years and renews on the practitioner's birthday; the fee schedule sets the LBA renewal at $350.00, the LABA renewal at $175.00 and the CBT renewal at $150.00.

Continuing education runs every two years, either by maintaining a certification from a professional credentialing entity that requires CE or by completing state hours — a minimum of 32 hours for the LBA (at least four on ethics and boundaries, no more than eight on business practice) and 20 for the LABA.

In addition to either route, an LBA and an LABA each complete two hours of health equity CE every four years (WAC 246-805-401(3); WAC 246-805-402(3)).

A CBT keeps competency by maintaining a credentialing-entity certification or obtaining an assessment within 90 days before renewal.

Let a credential lapse for longer than three years and competence must be demonstrated again to the secretary's satisfaction.

The department rewrote the rules in WSR 24-11-103, filed May 17, 2024 and effective June 17, 2024.

The rewrite added WAC 246-805-025, the approval process behind the national-credential alternative: an entity's certifications must meet or exceed the state's own qualification and CE rules, and the entity must hold current accreditation by the American National Standards Institute or the National Commission for Certifying Agencies.

The same filing repealed the old combined supervision-disclosure section, WAC 246-805-020 (effective since 2017), and split disclosure into separate LABA and CBT sections.

The statute shows no amendment in the saved text: the requirements, the practice ban and the exemptions still read as enacted in 2015 c 118.

There is no separate behavior analyst board.

The chapter vests licensing in the secretary of the Department of Health, advised by the Washington state applied behavior analysis advisory committee: five members — three licensed behavior analysts, one licensed assistant behavior analyst and one public member, who may be the parent or guardian of a recipient of services — appointed by the secretary, meeting at least twice a year.

The secretary shall consult with the committee in determining the qualifications for licensure or certification under RCW 18.380.050.

Applications go to the secretary on department forms, with fees set as provided in RCW 43.70.250.