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Telehealth and telesupervision for ABA in Tennessee

Last researched October 21, 2026

Can a BCBA in Tennessee deliver or supervise ABA by video, and what licensure applies? Answers below say exactly how sure we are.

BCBA licensure

Medium confidence: reputable secondary source
State license required for BCBAs

Yes.

License title

Licensed Behavior Analyst (LBA); Licensed Assistant Behavior Analyst (LABA)

Board

Applied Behavior Analyst Licensing Committee, Division of Health Related Boards, Tennessee Department of Health

Statute or rule

Tenn. Code Ann. §§ 63-11-301 through 63-11-311 (including the licensure exemptions in § 63-11-306); Rules of the Applied Behavior Analyst Licensing Committee, Tenn. Comp. R. & Regs. ch. 1180-05 (revised May 2025)

Fees and timeline

As of 2026-10-21, Tennessee requires a current license to practice as an LBA or LABA unless the person is exempted under T.C.A. § 63-11-306 (rule 1180-05-.03). Rule 1180-05-.04: the ordinary LBA pathway requires certification as a BCBA or BCBA-D in good standing, and the assistant pathway requires a BCaBA with proof of ongoing LBA supervision. The rule also contains a legacy DIDD pathway for persons qualified before July 12, 2012 who meet § 63-11-307(c), so the BCBA/BCaBA requirement is not universal. Rule 1180-05-.05: the application includes a passport-style photograph taken within the preceding 12 months; proof the applicant is at least 21, documented by a certified birth certificate; BACB certification verification, which administrative staff request directly from the BACB according to the application packet; two character letters from the preceding 12 months addressing character and professional ethics (waived for reciprocity applicants); a criminal background check; and verification of every license or certificate ever held in other states, including inactive ones. Fees (rule 1180-05-.06): LBA application $50, license $40, biennial renewal $150; assistant application $50, license $15, biennial renewal $100. The State regulatory fee is $10 for each license type and is paid with both initial and renewal applications. The Committee was created in 2014. Rule-specific text was confirmed through Cornell LII reproductions of the rules, corroborated where possible by the official application packet. The cited rules PDF and the claimed April 2026 Internet Archive capture could not be directly verified, so confirm current fees and requirements with the Committee.

Sources (6)

Telehealth and telesupervision

Medium confidence: reputable secondary source
ABA delivered by telehealth

Yes, per the sources below.

Detail

The posted 2024 shared TennCare program discusses clinically appropriate ABA telehealth. BlueCare's Telehealth Approved Code List, updated March 10, 2026, includes 97151-97158 for POS 02 and POS 10. Its January 2025 telehealth guide requires covered, medically appropriate services meeting the requirements applicable in person. The licensing committee's page, last updated September 23, 2026, states that an out-of-state provider treating a Tennessee client through telehealth must hold Tennessee licensure, except in its stated free-clinic circumstance. These sources supersede reliance on the record's 2019 blanket prohibition.

Telehealth parity law

Tenn. Code Ann. § 56-7-1012 requires reimbursement consistent with the policy's in-person coverage for the same service, without geographic distinctions, subject to utilization review and medical necessity. Its definition includes TennCare MCOs. This statutory text was verified through Justia's 2025 compilation. BCBST's October 2026 commercial manual also recognizes telehealth reimbursement under § 56-7-1003, while noting possible exclusions in certain self-funded contracts.

In-person requirements

The shared TennCare program recommends at least one in-person assessment contact using the word 'ideally'; that passage does not impose an absolute prerequisite. It identifies clinical and safety circumstances where in-person care is more appropriate. No universal ABA-specific initial or recurring in-person visit requirement was verified across all plans.

Supervision by telehealth

The June 2026 BACB handbook permits supervision contacts and service observations by live videoconferencing, subject to applicable law. Telephone or email alone does not satisfy its real-time face-to-face requirement. This credentialing permission does not itself authorize payer reimbursement. The shared TennCare program excludes non-client-specific administrative supervision or technician training from coverage.

Sources (7)

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 Tennessee

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