Telehealth and telesupervision for ABA in Michigan
Last researched October 21, 2026
Can a BCBA in Michigan 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
Behavior Analyst (licensed behavior analyst, LBA)
- Board
Michigan Board of Behavior Analysts (LARA, Bureau of Professional Licensing)
- Board website
- https://www.michigan.gov/lara/bureau-list/bpl/health/hp-lic-health-prof/behavior-analyst
- Statute or rule
Michigan Public Health Code and the Behavior Analyst General Rules, as identified on the LARA Behavior Analysts page. The LARA Behavior Analyst Licensing Guide (rev. 1/26/2026) references administrative rules R 338.1821 (human trafficking training) and R 338.1823.
- Fees and timeline
As of 2026-10-21, per the LARA Behavior Analyst Licensing Guide (rev. 1/26/2026): application plus initial 4-year license fee $452.40; relicensure $472.40; renewal $374.40; 4-year renewal cycle. Apply via MiPLUS. Requirements per the guide: BACB certification in good standing, verified directly by the BACB (BACB certification is a national credential, not itself a state license); criminal background check (the guide exempts relicensure applicants whose license expired within the preceding three years); good-moral-character and sex-offender questions; one-time human trafficking training; 2 hours of implicit bias training within the preceding 5 years (1 hour per year of the license cycle at renewal); and English proficiency. An SSN is requested; applicants who do not have an SSN, including those legally exempt from obtaining one, upload an affidavit instead. LARA also publishes a separate Assistant Behavior Analyst licensing guide, which the checker opened and found confirms supervision verification; details of assistant licensure were not otherwise verified here. Confirm current fees and requirements with LARA before applying.
Telehealth and telesupervision
- ABA delivered by telehealth
Yes, per the sources below.
- Detail
As of 2026-10-21, permission is payer- and code-specific. Medicaid: the MDHHS specialty behavioral health telemedicine database linked from its current reporting page (page updated 06/30/2026; PDF header effective June 1, 2026) allows simultaneous audio/video for 97155, 97156, 97157 and 97158, with POS 02 or 10 and no telemedicine modifier required. These rows do not authorize audio-only delivery. Its change log explicitly records removal of 0362T, 97151, 97153 and 97154 on 04/28/2023; they remain absent from the allowed-service rows. Thus the current database does not authorize remote technician direct treatment under 97153 or 97154, regardless of RBT status. MMP 23-10 requires beneficiary choice, clinical appropriateness and inclusion in the person-centered service plan. Commercial example: Blue Cross Blue Shield of Michigan and BCN guidance revised February 2026 lists 97151 and 97153–97158 as payable through synchronous telemedicine for commercial members with an autism benefit; technician interventions under 97153/97154 depend on member suitability. These findings do not establish commercial RBT credential requirements or independent technician billing eligibility. R 338.1832, effective December 7, 2021, requires licensed behavior analysts to obtain and retain telehealth consent, remain within their scope and meet the same standard of care as in-person services. Medicaid, board and named-payer findings are supported by primary sources; the section's medium confidence reflects the secondary-source verification of the parity statute.
- Telehealth parity law
MCL 500.3476, as reproduced in Justia's 2025 Michigan Compiled Laws, includes amendments effective April 2, 2025. For policies subject to the section, insurers may not require in-person contact for services they determine can appropriately be provided through telemedicine and must provide at least equivalent coverage to the same service delivered in person. Policy terms, including cost-sharing and approved amounts, still apply; professionals must be licensed, registered or otherwise authorized where the patient is located. This is a general coverage provision, not an ABA-specific authorization of every code or an express equal-payment-rate requirement. Medium confidence: the Legislature's statute viewer and PDF endpoints returned 403, so the statutory text was read through Justia.
- In-person requirements
BHT is designed to be delivered primarily in home and community settings, including centers and clinics. MMP 23-10, issued March 2, 2023 and effective May 12, 2023, requires reasonably frequent periodic in-person evaluations, prioritizes in-person community interactions and does not permit telemedicine to replace separately required in-person visits. It also requires appropriate on-site support when a beneficiary cannot communicate effectively or independently. The reviewed provisions do not specify a fixed ABA in-person visit interval. Blue Cross/BCN's May 2023 technician telemedicine guidance considers member skills, safety, caregiver availability and progress; it describes these suitability factors as guidance rather than formal requirements and directs providers to consider alternative telemedicine services and in-person interventions when progress is insufficient.
- Supervision by telehealth
Medicaid permits 97155 clinical observation and direction with protocol modification by a qualified professional through simultaneous audio/video. MMP 23-10 requires all elements of the billed service to be performed; this code allowance does not by itself establish that every credentialing or employment supervision obligation can be fulfilled remotely. Blue Cross/BCN commercial guidance revised February 2026 permits 97155 protocol modification through telehealth for up to 100% of that service time. It also lists S5108 for LBA supervision of a technician, but only for Michigan providers serving out-of-state members who cannot use the AMA category I codes. Whether all Medicaid-required technician supervision hours may be remote was not explicitly resolved by the reviewed sources.
Sources (8)
- MDHHS Reporting Requirements: current telemedicine database link, updated 06/30/2026
- MDHHS Bureau of Specialty Behavioral Health Services Telemedicine Database, header effective June 1, 2026; ABA rows page 4 and removal history page 9
- MDHHS MMP 23-10: Telemedicine Policy Post-COVID-19 Public Health Emergency, issued March 2, 2023; effective May 12, 2023
- Michigan Medicaid Provider Manual, Telemedicine chapter and Section 18 autism, version Oct 1, 2026
- Michigan Behavior Analysts General Rules, R 338.1832 Telehealth, effective December 7, 2021
- Blue Cross Blue Shield of Michigan / Blue Care Network: Telehealth for behavioral health providers, revised February 2026, autism services pages 5–6
- Blue Cross Blue Shield of Michigan / Blue Care Network: Guidelines for autism interventions delivered via telemedicine, revised May 2023
- Justia: MCL 500.3476, 2025 Michigan Compiled Laws, amendments effective April 2, 2025
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 Michigan
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