Practice requirements for ABA providers in Virginia
Last researched October 21, 2026
The internal processes a practice in Virginia has to run before and after a technician starts. A practice, not MeetAllo, remains responsible for compliance.
Requirements for practices
- Facility or agency license
We could not verify this yet - check with the state health or licensing department.
- Background checks
We could not verify this yet - check with the state health or licensing department.
- Staff training
We could not verify this yet - check with the state health or licensing department.
- Other requirements
Providers must keep enrollment and license information current in the DMAS provider portal (PRSS); MCOs may not pay non-enrolled network providers. Budget act item 291.WW.2 requires a 20 hours/week limit (exceedable via EPSDT medical necessity) and an ASD diagnosis (provisional allowed for age 5 and under) pending CMS approval; effective date to be announced.
Medicaid supervision and enrollment
- Provider enrollment
- https://vamedicaid.dmas.virginia.gov/
- Supervision requirements
Delegation only by LBA/LABA/Licensed Clinical Psychologist. Unlicensed personnel may be supervised by an LBA or LABA (18VAC85-150-130). Medicaid requirements: unlicensed staff receive supervision at least twice monthly, and an LBA/LABA/LMHP observes the youth and supervises services at least monthly. The Board of Medicine rule 18VAC85-150-120 requirement of supervision not less than once every four weeks for at least one hour per session concerns supervision of LABAs, not unlicensed technicians. Initial ABA assessments must be conducted in person with the youth and family/caregivers by an LBA, LABA or LMHP, and the assessment must be reviewed at least annually.
Sources (7)
- DMAS ABA Policy and Regulatory Clarifications bulletin (last updated 12/16/2025)
- DMAS ABA Policy Changes bulletin (last updated 07/31/2026): 20 hours/week limit and ASD diagnosis requirement pending CMS approval
- 18VAC85-150-120 Supervisory responsibilities
- 18VAC85-150-130 (unlicensed personnel may be supervised by an LBA or LABA)
- Va. Code 54.1-3614 (psychologist delegation to unlicensed personnel)
- Mental Health Services Manual, Appendix D (updated 7.17.25)
- Mental Health Services Manual, Chapter 4 (updated 10.2.26)
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 Virginia
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