Telehealth and telesupervision for ABA in Vermont

Last researched October 21, 2026

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

BCBA licensure

High confidence: read from an official primary source

State license required for BCBAs: Yes.
License title: Applied Behavior Analyst; Assistant Behavior Analyst
Board: Vermont Office of Professional Regulation (OPR), Secretary of State
Board website: https://sos.vermont.gov/applied-behavior-analysis/
Statute or rule: 26 V.S.A. Chapter 95 (Applied Behavior Analysis)
Fees and timeline: Applications are submitted through OPR's Online Services System; OPR refers to a 90 Day Initial Licensing Policy and a fee document (amounts not read; fees set per 3 V.S.A. 125(b)). OPR notes a Fast Track Endorsement for people licensed elsewhere for three consecutive years. Assistant behavior analysts need a minimum of five hours per month of off-site case supervision by a licensed applied behavior analyst (26 V.S.A. 4929).

Sources (3)

Telehealth and telesupervision

Medium confidence: reputable secondary source

ABA delivered by telehealth: Sometimes. See the detail below.
Detail: As of 2026-10-21, Vermont Medicaid permits ABA telehealth for CPT 97155, 97156 and 97157. DVHA's February 5, 2026 legislative presentation identifies January 1, 2026 as the effective date of these restrictions; the August 4, 2026 ABA Supplement confirms the eligible codes. This Medicaid policy does not establish commercial-plan code eligibility or audio-only ABA coverage.
Telehealth parity law: 8 V.S.A. 4098a, recodified and amended effective September 1, 2025, requires comparable coverage for telemedicine and in-person services and equal reimbursement for equivalent procedure codes and modifiers, subject to plan and provider-contract terms. Reimbursement exceptions include third-party telemedicine-vendor arrangements and value-based contracts. Medical necessity, clinical appropriateness and network requirements remain applicable. Subsection (j) extends the section to Medicaid and other state public health programs. Telemedicine is defined as live interactive audio/video over a HIPAA-compliant secure connection.
In-person requirements: The August 2026 supplement marks 97151, 97152, 97153, 97154, 97158, 0362T and 0373T ineligible for telehealth; 0362T/0373T require an onsite BCBA for 2:1 care.
Supervision by telehealth: Conditional for 97155: a BCBA may participate remotely when working with an onsite BT. A BCBA delivering direct treatment or personally modifying protocol must be onsite. This service-specific permission does not establish blanket approval of remote supervision.

Sources (3)

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.

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