Supervision Requirements of Board-Certified Behavior Analysts

Clarifies requirements related to Research Based-Behavioral Health Treatment and Specialized Consultative Services and New Taxonomy

This bulletin provides clarification around the supervision requirements of Board-Certified Behavior Analysts (BCBAs) as it relates to Research Based-Behavioral Health Treatment (RB-BHT) and Specialized Consultative Services, and new taxonomy for Behavioral Analyst to be added to NCTracks.

Pursuant to SL 2022-74, House Bill 103, Section 9K.3, Behavior Analysts, or their nationally accredited equivalents may practice without the supervision of a psychologist if they are licensed or certified in another state, or they are board certified by either the BCBA Board or Qualified Applied Behavior Analysis Credentialing Board.  

According to S.L. 2022-74, Section 9K.3, the ability for Behavioral Analysts to practice without the supervision of a psychologist is in effect until 60 days after the North Carolina Behavior Analyst Licensure Board (NBALB) begins to accept licensure applications.  

As a result, BCBAs can act as the Licensed Qualified Autism Service Provider through the RB-BHT State Plan Amendment.  

More information about the RB-BHT Clinical Coverage Policy can be found in Clinical Coverage Policy 8F. In addition, BCBAs can independently provide Specialized Consultative Services through the NC Innovations Waiver.  

The new taxonomy for Behavior Analyst 103K00000X, will not be available for enrollment in NCTracks until the NBALB is authorized to begin accepting applications for licensure. BCBAs should enroll with this new taxonomy only after they are licensed by the Board.  

Behavioral Analysts will use this Level II taxonomy code for enrollment and subsequent billing for care. This new taxonomy will be implemented under the existing group Behavioral Health and Social Service Providers. Submission of an active BCBA board certification and Behavior Analyst license in accordance with N.C.G.S. Chapter 90, Article 43 will be required for enrollment.  

Until this taxonomy code is implemented, analysts should continue to use their current billing process. The new taxonomy code will not preclude continued provision of services and credentialing under the current process. Clinical social workers and licensed counselors can continue to practice and bill within their scope of practice and under their professional taxonomy.  


NCTracks Call Center: 800-688-6696
Medicaid Provider Ombudsman: 866-304-7062 or  

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