Telehealth and telesupervision for ABA in Maryland
Last researched October 21, 2026
Can a BCBA in Maryland 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
Yes.
- License title
Licensed behavior analyst
- Board
Maryland Board of Professional Counselors and Therapists (behavior analyst licensure FAQ hosted on the board's site)
- Board website
- https://health.maryland.gov/bopc/Pages/index.aspx
- Statute or rule
Md. Code Ann., Health Occupations, Title 17, Subtitle 6A (practice of behavior analysis defined at 17-6A-01, as cited in the board FAQ)
- Fees and timeline
The board FAQ (undated; references a Dec 31, 2015 deadline and COVID-19 emergency) says BCBAs practicing behavior analysis in Maryland must hold a license from the board unless exempt; BCaBAs have no license and may practice only under supervision of a licensed behavior analyst or another authorized licensed health care provider. Fees and current application steps were not verified.
Telehealth and telesupervision
- ABA delivered by telehealth
Sometimes. See the detail below.
- Detail
As of 2026-10-21, Maryland Medicaid ABA telehealth is conditional. Per the Feb 2026 Medicaid ABA Provider Manual, the following may be rendered via two-way audio-visual telehealth: direct supervision of a BCaBA, RBT or BT; parent training; and group parent training. In the fee schedule, codes 97155, 97156 and 97157 carry a note that they can be provided via telehealth using the GT modifier. Providers must bill with the GT modifier and place of service 11 for telehealth delivery. Since Oct 16, 2023 a Telehealth Readiness Checklist (in the Treatment Plan Template) is required when requesting telehealth for 97155, 97156 and 97157. Telehealth services not meeting COMAR 10.09.49 are not billable. Remote direction of technicians requires approval from MDH or the BHASO. The February manual is not the current rule on its own: under Maryland Medicaid transmittal PT 60-26, effective April 1, 2026, at least 25% of the service must be rendered in-person and up to 75% may be rendered via telehealth for codes 97155, 97156/97156-U2 and 97157. Per COMAR 10.09.28.04B(6), (7) and (10) and Carelon's May 2026 ABA FAQ, the in-person share is measured monthly (in person at least 25% of the time each month). MDH reviews exceptions on a case-by-case basis. Direct technician treatment (97153, adaptive behavior treatment by protocol) is not marked as telehealth-eligible in the fee schedule and is expressly an in-person service under COMAR 10.09.28.04B(11).
- Telehealth parity law
We could not verify this yet - check with the state Medicaid agency or licensing board.
- In-person requirements
At least 25% of 97155, 97156/97156-U2 and 97157 services must be rendered in-person, measured monthly, effective April 1, 2026 (PT 60-26; Carelon May 2026 ABA FAQ); exceptions are reviewed case by case. Direct technician treatment (97153, adaptive behavior treatment by protocol) is an in-person service under COMAR 10.09.28.04B(11). The Feb 2026 manual says ABA must be delivered in a home or community setting, including a clinic, when medically necessary.
- Supervision by telehealth
Direct supervision of a BCaBA, RBT or BT may be delivered via two-way audio-visual telehealth (Feb 2026 Medicaid manual), subject to the 25% monthly in-person minimum for 97155 effective April 1, 2026 (PT 60-26); remote direction needs MDH/BHASO approval.
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.
Related guides for Maryland
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