Practice requirements for ABA providers in New York
Last researched October 21, 2026
The internal processes a practice in New York has to run before and after a technician starts. A practice, not MeetAllo, remains responsible for compliance.
Requirements for practices
- Facility or agency license
As of 2026-10-21, LBAs/CBAAs may work in any legally authorized setting (private practice, clinics, hospitals, residences, community). Article 28 facilities can also bill for ABA services; LBAs/CBAAs providing ABA in an Article 28 facility must be enrolled in NYS Medicaid FFS as OPRA providers and affiliated with the facility for the facility to be reimbursed. Whether a separate NY agency license is required for stand-alone ABA practices was not verified; this field should not be read as meaning none is required.
- Background checks
We could not verify this yet - check with the state health or licensing department.
- Staff training
LBA applicants must complete state-approved child abuse identification and reporting training. The Medicaid manual does not specify a technician training credential, but this does not remove the LBA's responsibility to train and supervise staff. General technician background-check rules were not verified.
- Other requirements
Medicaid revalidation: the older ABA manual states five years, but current DOH guidance uses three-, four-, or five-year cycles by provider risk tier (e.g., high-risk providers every 3 years), requires revalidation when requested, and uses the Provider Services Portal. An ABA provider's risk tier should not be assumed without its notice. For this Medicaid benefit, the manual excludes reimbursement of ABA in school settings and requires a referral from an enrolled physician, psychologist, psychiatric NP, pediatric NP or PA; these describe the Medicaid benefit, not every lawful ABA setting or prescription. Clinical records should be retained for at least six years and, for minors, until one year after the patient reaches age 21 (through age 22); retain for the longer of the two periods to satisfy both.
Sources (5)
- eMedNY Applied Behavior Analysis Policy Manual (updated October 1, 2025)
- NYSED OP - Licensed Behavior Analysts: License/Certification Requirements
- NYS DOH Medicaid Update 2021 No. 9 (ABA: any legally authorized setting; Article 28 facilities)
- NYS DOH Medicaid Provider Revalidation
- NYSED Rules of the Board of Regents, Part 29 (record retention)
Medicaid supervision and enrollment
- Provider enrollment
- https://www.emedny.org/info/ProviderEnrollment/
- Supervision requirements
Per the manual, the supervising LBA must supervise unlicensed technicians for at least 5% of the ABA-service hours they work each calendar month. This includes at least two face-to-face, real-time contacts per month (not by phone, email or text), and the LBA must observe the technician during at least one of them. One of the two contacts may be a small-group meeting. CPT 97155 may count toward the 5% only when the LBA joins the patient and technician to direct implementation of a new or modified protocol. Progress is reviewed at least every 6 months.
Sources (5)
- eMedNY Applied Behavior Analysis Policy Manual (updated October 1, 2025)
- eMedNY ABA Provider Manual page
- eMedNY Provider Enrollment
- NYS Medicaid Update 2022 No. 12 (Medicaid Managed Care ABA coverage effective Jan 1, 2023)
- NYS Medicaid Update 2021 No. 9 (ABA eligibility: under 21, ASD and/or Rett Syndrome)
National baseline for onboarding a technician
Items below are supported by BACB or regulator sources. Your state may add more.
- Verify RBT status on the BACB Certificant Registry (status, expiration, listed supervisor; red text means may not practice) or via portal verification report / $25 written verification.
- Ensure a qualified BCBA/BCaBA supervisor (with completed supervisor training 2.0) or RBT Requirements Coordinator lists the RBT as supervisee in their BACB portal before the RBT provides services as an RBT.
- Assign a supervisor/Coordinator for every client the RBT serves; no relation, employer-superior or multiple relationship with the RBT.
- Plan supervision: 5% of monthly service hours, at least two real-time contacts per month, one individual, one observation of services; document dates, durations, format, observations; retain 7 years.
- Criminal background check and abuse registry check comparable to those for home health aides/child care/teachers, within 180 days before the application is paid; fingerprinting may be required by state or organization.
- For applicants: have a BCBA/BCaBA Responsible Assessor (with 8-hour supervision training, same organization as applicant and clients, not related/subordinate/employed by the applicant at the time of assessment) complete the ICA after the 40-hour training; keep assessment records 7 years.
- Attesting Certificant for the application attestation must not be related to, subordinate to, or employed by the applicant.
- Correct worker classification (employee vs contractor) for RBTs; BACB may ask for a tax professional's written opinion in an ethics matter.
- For TRICARE ACD enrollment: RBT/ABAT/BCAT or state certification, current BLS/CPR, authorized ABA supervisor named, 10-year federal/state/county criminal and sex-offender history check.
- For Medicaid/commercial payers: confirm state Medicaid or payer definition of technician qualifications, enrollment and credentialing before billing (state-specific).
Verify any certified technician on the BACB certificant registry.
Related guides for New York
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