Supervision Requirements for Board Certified Behavior Analysts Update

Clarification on the expiration of S.L. 2022-74 Section 9K.3 supervision flexibilities and a new taxonomy for Behavioral Analyst

This bulletin provides clarification around the expiration of S.L. 2022-74 Section 9K.3 supervision flexibilities and a new taxonomy for Behavioral Analyst added to NCTracks.

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

S.L. 2022-74, Section 9K.3 was effective until 60 days after the North Carolina Behavior Analyst Licensure Board (NCBALB) began to accept licensure applications.  In July 2023, the NCBALB began accepting applications for Board Certified Behavior Analyst (BCBA) licensure.  

As a result of these licensure changes, Board Analyst licensed in accordance with NCGS Chapter 90, Article 43 can act as the Licensed Qualified Autism Service Provider through the Research Based Behavioral Health Treatment (RB-BHT) State Plan Amendment.  The taxonomy for Behavior Analyst 103K00000X has been added to NCTracks to allow BCBAs to enroll after they have been licensed by the board.

Behavioral Analysts will use this Level II taxonomy code for enrollment and subsequent billing for care. Local Management Entity/Managed Care Organizations (LME/MCOs) and Prepaid Health Plans (PHPs) will need to accept this new taxonomy. This new taxonomy has been implemented under the existing group Behavioral Health and Social Service Providers. Submission of an active board certification number from a Certifying entity as defined by NCGS 90-732(4) and Behavior Analyst license in accordance with N.C.G.S. Chapter 90, Article 43 is required for enrollment.  

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.  

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


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