Missouri Added a Law Exam August 30. Its Next Rule Bans Group Supervision.

Two amended Missouri licensing rules took effect on August 30, 2026. Applicants for a behavior analyst license now have to pass a state jurisprudence exam. Applicants for a provisional license now have to prove they've finished a graduate degree in behavior analysis. A third rule, still pending, would change how every assistant and provisional licensee in the state is supervised.

The turn: billing closed the gap first, licensing is closing it now

We reported on September 27 that MO HealthNet limits provisional analysts without a finished degree to three codes, and recoups the rest back to February 1. The licensing board is now keeping degree-less applicants out of provisional licensure altogether. For clinics that hire provisionals, the pending supervision rule matters more than either.

In effect since August 30 (20 CSR 2063-2.005 and 1.015)

• Jurisprudence exam for LBA applicants. The exam covers Missouri law, rules and ethics. An applicant passes with "at least seventy percent (70%) of the total items correct." The fee is $75. The requirement sits in the behavior analyst section only, not the assistant section.
• Provisional applicants (analyst and assistant) must submit "a completed transcript from an accredited educational institution of all coursework with evidence of completion of a graduate degree in behavior analysis." They must also document BACB eligibility "if requested."
• Notarization is gone from applications.

Pending: the supervision rule (20 CSR 2063-5.005)

The rule was proposed in the July 1 Missouri Register and its comment window closed about July 31. It would apply to supervisors of licensed assistant analysts, provisional analysts and provisional assistant analysts. Supervisors would have to:

• "Be affiliated with the same company, corporation, or organization, and be located and licensed in the same state as the supervisee."
• Provide "at least two (2) hours of in-person, face-to-face direct supervision on a monthly basis (four (4) hours per month) for every eighty (80) hours worked." As published, that sentence gives two figures. It doesn't say which one governs.
• Meet the ban: "Supervision in a group setting is not permitted." The current rule allows one group hour per 160 hours worked. The proposal deletes it.
• Be licensed "in the state of Missouri." Certification by the certifying entity is no longer the test.

Missouri's rulemaking statute gives an agency 90 days after comments close to file a final order, or the proposal lapses. By our count that's around October 29. No final order appears in the Register indexes through October 1. A separate proposal on provisional education requirements (20 CSR 2063-4.005) closed for comment around September 16.

The limits

The supervision rule isn't in force and could change or lapse. Its cost statements disagree: the Register version says it won't cost private entities more than $500, while the board's own copy says it will. The adopted degree rule says "graduate degree in behavior analysis," but the pending education rule uses BACB exam-eligibility language. Watch which wording prevails.

What you must know or do

• Owners hiring provisionals: ask for a final transcript showing a conferred graduate degree before you make an offer. Since August 30, the license application needs it.
• New LBA hires: build the jurisprudence exam and its $75 fee into onboarding timelines.
• Clinical directors: list every supervision pairing for LaBAs and provisionals. Flag any supervisor employed by another company, based outside Missouri, supervising by video, or counting group hours. Those are the pairings the proposal would end.
• Check the Missouri Register in late October for a final order on 5.005. It decides whether that list becomes a staffing change.