Telehealth and telesupervision for ABA in District of Columbia

We could not verify this yet - check with Board of Psychology, DC Health.

behavior analyst

Board of Psychology, DC Health

D.C. Law 25-191, Health Occupations Revision General Amendment Act of 2024, effective July 19, 2024; D.C. Code §§ 3-1201.01(7), 3-1201.02(2C-i), 3-1202.11, 3-1205.01, 3-1205.03, 3-1207.71, 3-1210.01, 3-1210.07. No final behavior-analyst chapter of Title 17 DCMR is published.

Law 25-191 (effective July 19, 2024) tells the Board of Psychology to license a person as a behavior analyst who meets subchapter V and (1) a criminal background check, (2) a current Behavior Analyst Certification Board certification, and (3) a master's degree or higher from a BACB-accredited behavior-analysis program. The degree requirement is waived if the person was BACB-certified on or before July 19, 2024. General applicants must be at least 18 (D.C. Code § 3-1205.03(a)(2)). § 3-1205.03(a)(4) also requires an examination; the behavior-analyst exam standard is one of the rules the Mayor has not issued. § 3-1202.11(f) required those rules within one year of July 19, 2024 (by July 19, 2025): an ethics code, education and clinical-training criteria, competency-exam criteria, and continuing education, and at least two public meetings before the rules issue. They are not final. On July 16, 2026 the Board voted to approve draft regulations. On September 25, 2026 Board attorney Scott Sasjack said the psychology-associate and behavior-analyst drafts were still in internal DC Health review, then review by other agencies and the Mayor's Office, then a DC Register public-comment period. That day's licensure census was 1,680 psychologists and 275 psychology associates, with no behavior-analyst count. The Board's licensing and application pages list psychologist and psychology associate checklists only (examination, re-examination, endorsement). No behavior-analyst fee or processing time is published. 'Practice of behavior analysis' is defined in § 3-1201.02(2C-i) and the Board regulates it under § 3-1202.11(b). § 3-1210.01 bars practice of a health occupation licensed or regulated under the chapter without a current license, and § 3-1210.07 sets the general criminal penalty at up to 1 year or a fine up to $10,000, or both, and for a later conviction up to 1 year or up to $25,000, or both. Behavior analysis is not named in the license-required list in § 3-1205.01(a)(1) as rewritten by Law 25-191. The statute creates no BCaBA or RBT license and no behavior-analyst title clause was found.

We could not verify this yet - check with the state Medicaid agency or licensing board.

As of 2026-10-21, D.C. Code 31-3862 (private reimbursement), as summarized, provides that a health insurer may not deny coverage for a healthcare service on the basis that it is provided through telehealth if the same service would be covered when delivered in person. The insurer must reimburse the provider for diagnosis, consultation, or treatment delivered through telehealth, but this does not extend to services not covered under the health benefits plan or to providers who are not covered providers under the plan. The deductible, copayment, or coinsurance for a telehealth service may not exceed the amount applicable to the same service delivered in person. Insurers are not precluded from undertaking utilization review to determine the appropriateness of telehealth as a means of delivering a healthcare service. The section does not set a payment-rate parity requirement. ABA is not mentioned, and the section does not independently authorize ABA practice, technician billing, remote supervision, or particular ABA telehealth procedures. ABA-specific permission, supervision, and in-person requirements were not found and remain unresolved; statutory silence should not be treated as permission.

D.C. Code 31-3862 (as summarized): conditional coverage and reimbursement protections plus cost-sharing parity; no payment-rate parity requirement

We could not verify this yet - check with the state Medicaid agency or licensing board.

We could not verify this yet - check with the state Medicaid agency or licensing board.