Colorado Licensed Behavior Analysts — and Made RBT Hours Reimbursable

Governor Polis signed HB26-1425, Applied Behavior Analysis Services, on June 2, 2026. It creates the Colorado behavior analyst licensing board under the Division of Professions and Occupations at the Department of Regulatory Agencies, with two credentials: Behavior Analyst and Assistant Behavior Analyst.

The operative sentence is dated well ahead: "On and after July 1, 2028, an individual is prohibited from engaging in or offering the practice of applied behavior analysis unless the individual is licensed by the board."

Two years is the story

Licensure laws usually arrive with a compliance date close enough to cause a scramble. This one gives just over two years between signature and prohibition — time for the board to be constituted, rules to be written, and an application system to exist before anyone has to use it. Colorado is the most recent addition to the BACB's list of licensing jurisdictions, which now covers 41 of the 51 US jurisdictions — the 50 states and the District of Columbia.

What the license will require

• An application to the new board.
• Valid certification maintained with a certifying entity.
• A fingerprint-based criminal history check.
• Professional liability insurance, unless practicing as a public employee.
• Assistant behavior analysts practice under the supervision of a licensed behavior analyst.

The part that is revenue, not compliance

The bill also requires Medicaid reimbursement for applied behavior analysis provided by certified behavior technicians to members with autism spectrum disorder, and directs the Department of Human Services to establish licensing standards for ABA clinics.

That is worth separating from the licensure headline. Most regulatory news this year has narrowed what can be billed and by whom — North Carolina removed telehealth for paraprofessional codes, and federal guidance is pushing states toward tighter credentialing. A state mandating reimbursement for technician-delivered services is moving the other way on the same question.

What you must know or do

If you practice in Colorado, the date to put in the calendar is not July 2028. It is whenever the board opens applications, which will be sooner and is not yet set. The BACB notes that states with newly enacted laws may not have an application system in place yet. Watch the Division of Professions and Occupations rather than the statute.

Check your professional liability coverage now, not at renewal. It becomes a licensure condition rather than a commercial choice, and the one time you do not want to discover a gap is while an application is open.

If you operate across state lines, add Colorado to the matrix. Forty-one jurisdictions now license behavior analysts and the requirements are not uniform. A supervisor covering multiple states is the person most likely to be caught by a rule written for a state they visit rather than the one they live in.

If you serve Colorado Medicaid, read the technician-reimbursement provision against your staffing model. A mandate to reimburse technician-delivered services changes what a caseload can look like — and it arrives while the same question is being tightened elsewhere.