Practice requirements for ABA providers in Rhode Island

As of 2026-10-21, under the 2016 EOHHS standards, HBTS provider agencies must be certified by EOHHS. ABA agencies may serve as Direct Service Providers subject to EOHHS approval, and center-based ABA requires EOHHS approval and meeting the standards' Appendix 7 requirements. Provider agencies must demonstrate an evidence-based clinical model. They may list accreditation such as COA, CARF or Joint Commission, but these are examples and not a mandatory accreditation requirement. Certification eligibility does not establish that a new practice can currently enroll and bill Medicaid: EOHHS posts a 6-month temporary moratorium on newly enrolling HBTS/ABA providers starting June 16, 2026. EOHHS limits the notice's impact to newly enrolling providers.

BCI and CANTs screenings are required for HBTS workers and clinical staff under the 2016 EOHHS standards.

Agency-specific skills validation or formal training for HBTS workers. Under the 2016 standards, clinical supervisors and treatment consultants must show competency with the target population. The standards' transitional BCBA-certification language should not be read as overriding current licensure requirements, so verify current licensure rules before relying on BCBA certification alone.

The 2016 standards limit clinical supervision or treatment consultation for HBTS to qualified clinicians. Their transitional BCBA-certification language must not override current licensure requirements. For individuals with dual coverage (commercial plus Medicaid), Medicaid assumes responsibility for ABA payment once commercial benefits are exhausted, and payment reverts to commercial each benefit year (2016 standards). This does not apply to everyone. A June 2021 EOHHS addendum states that members receiving HBTS/ABA services can utilize more than one provider agency. It requires secondary-agency billing to add an XP modifier, and agencies should follow its multi-agency coordination and billing rules. As of 2026-10-21, a 6-month temporary moratorium on newly enrolling HBTS/ABA providers (from June 16, 2026) is posted on the EOHHS provider enrollment page.

Clinical supervision is required for both Specialized Treatment and Treatment Support throughout the authorization (July 1, 2016 HBTS Certification Standards). The supervisor is responsible for the direct-service staff and must observe the home-based worker treating the child at least monthly. Each supervision contact must be child-specific and longer than 15 minutes, and must be documented with the child's name, who was supervised, date, place, duration, purpose and content, recommendations, and the supervisor's signature. Authorized clinical supervision is 8 to 16 units per month, which is 4 to 8 hours (1 unit = 30 minutes). A 2016 change reset the allowance from 2 hours per week to 8 hours total per month; the phase table lists a maximum of 8 hours of supervision per month in Phases 1 and 2. Group supervision is required when more than two home-based workers serve the same child. EOHHS does not set a caseload ratio; a clinical supervisor or treatment consultant who provides more than 30 hours of service per week is subject to EOHHS review unless EOHHS has approved it. ABA-recognized providers may be authorized for additional clinical supervision and lead therapy. Lead therapy is administrative support; units are set case by case, and the lead therapist may observe the assigned child and treatment worker once per month when the agency finds it clinically necessary. For licensed assistant applied behavior analysts, R.I. Gen. Laws § 5-86-26(b) requires in-person initial direction and periodic on-site supervision by a licensed applied behavior analyst, in an amount the supervisor sets from the assistant's experience, competence, and the program's complexity; the statute states no hour percentage. Aides require close supervision under § 5-86-26(d). The Medicaid standards do not adopt the BACB 5 percent RBT supervision rule. Billing codes in Appendix 13 of the standards are H0046 HO (master's-level clinical supervision), H0046 HP (doctoral-level clinical supervision), and H0046 (lead therapy).