Telehealth and telesupervision for ABA in Colorado
Last researched October 21, 2026
Can a BCBA in Colorado deliver or supervise ABA by video, and what licensure applies? Answers below say exactly how sure we are.
BCBA licensure
- State license required for BCBAs
No state license was found.
- License title
Behavior analyst / assistant behavior analyst (licensure under the ABA Practice Act, HB26-1425, deferred until July 1, 2028)
- Board
Colorado Behavior Analyst Licensing Board (Department of Regulatory Agencies), per law-firm summary; no dedicated board URL verified
- Board website
We could not verify this yet - check with Colorado Behavior Analyst Licensing Board (Department of Regulatory Agencies), per law-firm summary; no dedicated board URL verified.
- Statute or rule
HB26-1425 (signed 2026-06-02, Chapter 299); C.R.S. article 12-247, particularly sections 106–109, 112, 118 and 122–123
- Fees and timeline
As of 2026-10-21, the law is enacted but the practitioner licensing requirement is not yet in force; per the bill page, it applies on and after July 1, 2028. Requirements include valid certification and a fingerprint-based criminal history record check. Professional liability insurance is required, with an exception for qualifying public employees covered by governmental immunity. Assistant behavior analysts must work under supervision. Practicing without a license (nonexempt practice) is a class 2 misdemeanor, applicable only after the relevant provision takes effect. The regulation is scheduled for repeal September 1, 2031 under sunset review. No established fee schedule, operational application process or dedicated board URL was verified.
Telehealth and telesupervision
- ABA delivered by telehealth
Yes, per the sources below.
- Detail
HCPF's PBT manual expressly includes pediatric behavioral therapists in its telemedicine policy. The telemedicine manual, accessed through HCPF's state-hosted test mirror with last listed revision 2025-05-09, lists CPT 97151, 97153, 97154, 97155 and 97158 as telemedicine-eligible since 2020-03-20, using POS 02 or 10. It permits PBT through any telemedicine modality when appropriate. Provider eligibility, prior authorization, covered-benefit and standard-of-care requirements remain applicable. Telemedicine does not waive technician qualifications. Production manual URLs returned 403; whether subsequent revisions changed these provisions remains unverified.
- Telehealth parity law
C.R.S. 10-16-123(2): applicable state-regulated plans cannot deny appropriate, otherwise-covered services solely because of telehealth delivery. Participating providers receive reimbursement on the same basis as in person; patient cost sharing cannot be greater. This general protection does not establish a particular plan's ABA authorization.
- In-person requirements
HCPF's retrieved manual does not require initial in-person contact for otherwise reimbursable telemedicine. Signed written disclosures are required before the first visit, except in emergencies; later visits require documented verbal or written consent. C.R.S. 10-16-123(2)(a) similarly bars requiring in-person contact for appropriate covered telehealth, subject to plan terms.
- Supervision by telehealth
BACB's RBT Handbook, updated June 2026, permits required supervision through live videoconferencing. Requirements include supervision for at least 5% of monthly service hours, two real-time face-to-face contacts monthly, at least one individual contact, and observation of service delivery during at least one contact. Telephone/email do not qualify; passive video monitoring without real-time interaction or feedback may not count. These are certification standards, not payer reimbursement authorization. HCPF lists 97155 for telemedicine, but payment for supervision-only encounters and additional Colorado payer restrictions were not established.
Sources (4)
- HCPF - Pediatric Behavioral Therapies Billing Manual, state-hosted test mirror
- HCPF - Telemedicine and eConsult Billing Manual, state-hosted test mirror; last listed revision May 9, 2025
- Colorado General Assembly, Office of Legislative Legal Services - Colorado Revised Statutes 2026, Title 10, section 10-16-123
- BACB - Registered Behavior Technician Handbook, updated June 2026
National baseline: BACB telesupervision
Handbook: in-person on-site observation is preferred, but observation 'may be conducted via web cameras, video-conferencing, or similar means'; internet-based supervision must comply with all applicable laws; video monitoring alone without real-time interaction/feedback may not count. Phone or email contacts do not count as the face-to-face contacts. Payer/state rules can be stricter (CMS toolkit says telehealth should be a limited adjunct and 'generally avoided' for routine technician supervision; that is CMS guidance to states, not a BACB rule).
This is the BACB's certification rule for RBT supervision. State, Medicaid or payer rules can be stricter. High confidence for the BACB text as of 2026-10-21.
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