Pennsylvania's IBHS Rules Cite a Task List the BACB Has Retired

Pennsylvania's IBHS regulations require a behavioral health technician to have completed a 40-hour training covering the RBT Task List. That document no longer exists. OMHSAS said so itself, in a letter to every IBHS provider:

“Training content is now referred to as the RBT Test Content Outline (3rd ed.), replacing the previous RBT Task List (2nd ed.). The regulations now have outdated language by referring to the RBT task List.”

The regulations are 55 Pa. Code § 5240.71 and § 5240.81. They still cite the retired document. Rather than wait for a rulemaking to catch up, OMHSAS has told providers which standard it will actually enforce.

What OMHSAS says it will look for

“OMHSAS is taking this time to affirm that meeting the BACB standards … is the standard OMHSAS is looking for. In order to avoid confusion between name changes now and in the future OMHSAS will utilize the terminology the BACB is currently using where possible, and in all other places default to BACB certification as referenced in the regulations.”

In plain terms: follow the BACB's current requirements, not the words printed in the regulation.

Certificates dated before January 1 are outdated

The BACB's changes took effect January 1, 2026. The letter is blunt about what that does to paperwork already in your files: “Training materials referencing the 2nd edition Task List or certificates dated before January 1, 2026, are now considered outdated.”

And new certificates must carry exact wording. The BACB has issued required language for 3rd edition certificates:

“This training program is designed to meet the 2026 training eligibility requirement for RBT certification. The training is offered independent of the BACB.”

The letter adds the part that makes this operational: “Licensing staff will review these new RBT certificates for compliance.” A certificate without that sentence is a finding waiting to be written up.

The one-year phase-in, by staff type

OMHSAS set out four cases, and they are not the same:

• Staff switching agencies who trained under the 2nd edition elsewhere: being out of date “does not preclude them from being hired in 2026,” but the new provider “should have a plan in place” for them to get 3rd edition training within the year.
• Existing staff holding a 2nd edition certificate: update “within one year of holding a 2nd edition training certificate.” The clock runs from their certificate date, not from a single agency-wide deadline.
• New hires with no prior BHT experience: train on the 3rd edition curriculum from the start.
• After 2026: all BHT/BHT-ABA staff under those regulatory requirements should be trained in the 3rd edition.

Staff who hold active RBT certification must separately follow current BACB requirements for ongoing certification — the training rule and the certification rule are different obligations.

OMHSAS also set the precedent forward: “Any future editions can follow the one year phase in time frame we've outlined here unless there is some reason not to.”

The limits

This is guidance in a letter, not a regulation, and it does not amend § 5240.71 or § 5240.81 — the outdated text stays until it is changed through rulemaking. The language throughout is “should,” not “shall,” which matters if you are reading it as a compliance floor rather than a plan. The one-year phase-in runs per staff member from their own certificate date, so there is no single date to diary. The BACB announced these changes in 2023, and OMHSAS notes the field had “plenty of lead time,” which is a fair signal about how sympathetically a licensing reviewer will treat an agency that has not started. Questions go to ra-pwibhs@pa.gov.

What you must know or do

• Pull every BHT and BHT-ABA training certificate and check the date. Anything dated before January 1, 2026 is outdated on OMHSAS's own account. That is a file review you can do this week, before a licensing visit does it for you.
• Check the new certificates for the exact BACB sentence. Licensing staff will be reading for it. If your training vendor's certificate omits “The training is offered independent of the BACB,” go back to the vendor now.
• Build the per-person clock, not an agency deadline. Each person's year runs from their own 2nd edition certificate date. A single spreadsheet column with that date and a due date is the whole compliance system.
• If you hire from another IBHS agency, the plan is your obligation, not theirs. You can hire someone trained on the 2nd edition, but you need a documented plan to get them current within the year — and the letter puts that on the new provider.
• Do not rely on the regulation's wording in a dispute. The regulation says RBT Task List; OMHSAS says it will enforce the BACB's current standard. Where those diverge, the letter tells you which one a licensing reviewer is holding.