BT vs RBT: what a behavior technician needs in Maryland

Only in some situations. See the detail below.

As of 2026-10-21, Maryland Medicaid appears to allow a newly enrolling Behavior Technician (BT) who does not yet hold RBT registration to be enrolled and render ABA to Medicaid participants for a limited time, but the length of that period is in conflict between sources. COMAR 10.09.28.02 still requires the BT to obtain BACB registration within 90 days of enrollment with Maryland Medicaid. Newer agency guidance (PT 39-27, October) describes a 150-day waiver/enrollment period for newly enrolling BTs and says the RBT certificate should be submitted in a new enrollment application, before or after that period expires. That guidance does not authorize continued BT service after the period expires. Because of this conflict, the older '90 days after the ePREP application date' rule should not be treated as reliable current guidance. Enrollment is now handled through MPRIME rather than the legacy ePREP steps; confirm the current portal instructions with the Department before relying on them. For applications submitted by December 31, 2026 and approved, the effective date may be backdated to August 1 or set to a later requested date; later applications use the submission date. A high school diploma (or national equivalent) is still required with the BT application. COMAR .02J also calls for the BT to be age 18 or older, appropriately supervised, and in a written supervisory relationship. BTs/RBTs cannot bill the Program directly; the ABA group or BCBA-level provider bills. Within this Medicaid benefit, an RBT/BT may not serve as a 1:1 educational aide.

• Medicaid provider enrollment is required for BTs and RBTs; current guidance points to MPRIME, and the older ePREP instructions (specialty code 325, 'BT' as license number, application date as issue date, application date plus 90 days as expiration date) are historical and should not be treated as current portal steps
• Obtain BACB registration within 90 days of enrollment per COMAR 10.09.28.02, but PT 39-27 describes a 150-day waiver/enrollment period for newly enrolling BTs with the RBT certificate submitted in a new enrollment application; the two sources conflict and neither authorizes continued BT service after the applicable period expires
• Be at least 18 years old, be appropriately supervised, and have a written supervisory relationship (COMAR .02J)
• High school diploma or national equivalent uploaded with the BT application
• Per the 2026 manual, a completed Criminal Justice Information System (CJIS) criminal background check and the CJIS Private Party Petition form from the DPSCS website (the manual itself spells this 'Parity'); not independently re-verified by the fact-checker
• Per the 2026 manual, agencies check the HHS-OIG exclusion list for all employees, with a recommended frequency of every 30 days; not independently re-verified by the fact-checker

As of 2026-10-21, per the ABA Provider Manual effective Feb 1, 2026: ABA services must be administered by a licensed psychologist, BCBA-D, BCBA, BCaBA, RBT and/or a BT working within scope. BCBA and BCBA-D providers must also hold the required Maryland license. The current regulation (COMAR 10.09.28.04) lists the rendering credentials as licensed psychologist, LBA, BCaBA, RBT, or BT. BCaBAs, RBTs and BTs work under the direction of a psychologist, BCBA-D or BCBA. They cannot bill the Program directly; fee-for-service payment goes to an ABA group or an individual provider (psychologist, BCBA-D or BCBA), with claims submitted to the BHASO. Maryland Medicaid covers medically necessary ABA for members under age 21 under the EPSDT program (COMAR 10.09.28.05), and the ASD diagnosis must come from a qualified health care professional. Being under 21 and having an ASD diagnosis are necessary but not the only eligibility conditions under COMAR 10.09.28.03.

It depends. See the condition below.

Conditional, and the enrollment instructions are in conflict as of 2026-10-21. The Feb 1, 2026 manual says a Behavior Technician (BT) may enroll with Maryland Medicaid before obtaining RBT certification, but must submit proof of RBT certification via an ePREP supplemental application within a 90-day grace period (application date plus 90 days). The manual says the 90-day period is specific to the individual, not the employer, and does not restart if the BT changes companies. Those manual instructions appear outdated: enrollment now goes through MPRIME rather than ePREP. Provider Transmittal PT 39-27 (dated October 6) describes a 150-day waiver/enrollment period and a new RBT enrollment application, which conflicts with the manual's 90-day supplemental-application process. COMAR 10.09.28.02J(2) still specifies registration within 90 days of enrollment, while the manual counts from the application date. BT requirements are in COMAR 10.09.28.02J; .02I addresses RBTs. The grace period does not waive other enrollment requirements in COMAR 10.09.28.02. Confirm the current period and process with MDH before relying on either figure.