Louisiana Registers Your Line Technicians Itself. A BACB Credential Isn't Enough.

Most states decide who may deliver ABA by pointing at a national credential. Louisiana keeps its own list.

Chapter 4 of the Louisiana Medicaid Services Manual, reissued August 22, 2025, names three tiers, and two of them are state registrations rather than BACB certifications:

• LBA — the licensed behavior analyst, or a licensed psychologist or licensed medical psychologist. No sanctions or disciplinary actions, “state-certified or board-certified by the BACB,” and a criminal background check.
• CaBA — the state-certified assistant behavior analyst, working under an LBA with “the supervisory relationship documented in writing.”
• RLT — the registered line technician, who must be “registered by the Louisiana Behavior Analyst Board,” work under an LBA with the relationship documented in writing, and complete a criminal background check.

The turn: the credential you hold is not the one that pays

An RBT credential is a national certification held by the individual. Louisiana's requirement is a state registration held with the board and tied to a named supervisor in writing. A technician who is certified, competent, trained and working under a properly licensed analyst is still not billable in Louisiana until the board has them on its register.

That is a different failure mode from a lapsed certification. Nothing expires and no alert fires. The person simply was never on the list, and the claims went out anyway.

Supervision has to be someone else's session

Three constraints sit in one paragraph of Section 4.1, and the second is the one that costs money:

• The ratio is 2:10 — “two hours of supervision for every ten hours of therapy.”
• Supervision is not approved if the licensed supervising professional is delivering the direct therapy. It “can only occur when a non-licensed professional is providing the therapeutic behavioral services.”
• Part of it must be face-to-face with both — “in the presence of the beneficiary receiving treatment and state-certified assistant behavior analyst (CaBA) or the registered line technician (RLT).”

The ratio lands on the same number Nevada uses as a ceiling, from the other direction: Nevada caps supervision at 20% of hours, Louisiana approves it at 20%. The clause worth your attention is the second. An LBA who covers a session personally cannot bill supervision for that time — the code exists only for oversight of somebody else's delivery. One-on-one supervision may be billed simultaneously and concurrently with the one-on-one therapeutic service, so the two can share a clock, but not a person.

Two caps, both on the person, one of them on the clock

The manual sets two caseload limits, and both attach to the individual supervisor rather than the clinic. The licensed professional is the subject of each sentence:

“The licensed supervising professional shall supervise no more than 24 technicians a day.”

“The licensed professional can supervise no more than 10 CaBAs.”

Read those honestly. Twenty-four technicians in a day is a ceiling almost nobody reaches — at half an hour each it is a twelve-hour day — and the sentence sitting between the two softens it further: more technicians may be supervised “if a CaBA is part of the professional support team or depending on the mix of needs in the supervisor's caseload.”

That middle sentence is what explains the structure. CaBAs raise the technician ceiling because they are absorbing supervision themselves, which makes this a span of control rather than two unrelated numbers: one LBA over as many as ten assistant analysts, and those assistants over line technicians. The ten-CaBA limit is the one likely to bind, and it is the only one of the two with no period attached — no “a day,” no month. On its face it caps the roster, not the calendar.

The manual never says so outright, and the sentence sits directly after one that does carry a period, so a reviewer could argue the daily frame carries over. The roster reading is the more sensible of the two — you would rarely touch ten assistant analysts in a single day regardless — and it is also the stricter one.

Keep the ratio separate from both. The 2:10 basis is 20% of hours, not a headcount: two hours of supervision for every ten hours of therapy.

Background checks reach the parish, and they recur

The manual specifies federal, state, parish criminal and sex offender reports, “for the state and parish of employment and residence.” The schedule:

• LBA — at the enrollment application, current within a year prior to the initial Medicaid application, or at time of hire. Updated at least every five years thereafter.
• CaBA — at time of hire.
• RLT — at time of hire.

Evidence of the checks must be produced by the contracted provider, not the individual. Everyone in all three tiers must also be clear of Medicare and Medicaid sanctions and absent from the OIG list of excluded individuals and entities, the System for Award Management listing, and the state Medicaid sanctions lists.

The five-year refresh is the quiet one. Hire-date checks get done because somebody is being onboarded. A recurring obligation with a five-year period has no such trigger.

The plan of care has writing rules

Appendix D is specific about language, and it is worth reading even outside the state. Baselines must be written as observed performance:

“Sharlee could tact ten animals and four colors during assessment.”

And then the prohibition:

“Do not refer to idiosyncratic, proprietary assessment instrument results to describe baseline performance.”

The manual's own rejected example is “Harry could perform skills 4L to 5G on ABEL4 assessment.” The same bar applies to goals: a provider “may NOT use idiosyncratic, proprietary nomenclature to specify treatment goals.” Every goal needs a performance standard and a mastery criterion, and a renewal must list the present level of performance for each skill under treatment plus any goals mastered in the previous authorization period.

This is a reviewer telling you in advance that a plan written in the shorthand of a commercial assessment protocol will not be read as documentation.

The limits

The August 22, 2025 reissue changed the whole chapter, and the revision log gives one reason for every section: “Revisions made to incorporate technical edits throughout section.” So this is the standing requirement rather than a change arriving, and the log identifies no substantive amendment.

Two other numbers to carry: authorizations for ABA-derived therapy services shall not exceed 180 days, and beneficiaries have the right to change providers every 180 days unless the change is for good cause. Exclusions include services that are primarily educational, services delivered outside the school setting that duplicate an IFSP or IEP, treatment that is vocationally or recreationally based, and custodial care.

What you must know or do

• Check every line technician against the Louisiana Behavior Analyst Board register, not your BACB roster. These are separate lists and only one of them makes the claim payable. Anyone missing from the state register has been unbillable for as long as they have been working.
• Confirm each RLT and CaBA has a written supervisory relationship on file naming their LBA. The manual requires it documented in writing. It is the kind of record that exists in practice and not in the file.
• Stop billing supervision on sessions your LBA delivered. Supervision is payable only when a non-licensed person provided the service. If an analyst covered a technician's absence and the supervision unit went out anyway, that is a clean reversal to find yourself before someone else does.
• Owners: put the five-year LBA background-check refresh on a calendar today. Nothing in a hiring workflow will raise it, the evidence is the provider's to produce, and the first one comes due five years after an enrollment date nobody is watching.
• Count CaBAs against ten per individual supervisor, not per clinic. Both caps attach to the licensed professional, and this is the one likely to bind — the 24-technicians-a-day ceiling is softened in the same paragraph and rarely reached. If one analyst carries eleven assistant analysts, that is the number to look at first.
• Read one Louisiana treatment plan for assessment shorthand. If baselines or goals are stated as protocol levels or program codes from a commercial assessment rather than as observed behavior with a mastery criterion, Appendix D says a reviewer will not accept them.