Purpose

ABAS delivers Applied Behavior Analysis services that Massachusetts law and MassHealth allow only properly licensed and certified individuals to provide. This policy establishes the credentials required for each clinical role, the organizational licenses and enrollments ABAS must maintain, and the process for verifying credentials at hire and keeping them current. It exists so that no service is delivered, supervised, or billed by a person who lacks the required license or certification.

Scope

This policy applies to all ABAS employees who hold or are required to hold a professional license or certification, specifically the BCBA Team (LABA licensure and BCBA certification, or Assistant LABA licensure and BCaBA certification for any employees practicing in an assistant applied behavior analyst capacity) and the Behavior Technician Team (behavior technicians who meet MassHealth's qualification requirements, of which RBT certification is one pathway). It also applies to the employees responsible for credential verification, tracking, and provider enrollment: the Employee Relations Specialist, the Billing & Recovery Specialist, the Director of Operations, the Compliance Officer, and the Executive Director. The policy covers ABAS's organizational obligations as well, including MassHealth provider enrollment.

Definitions

Policy Statement

5.1 Credential Requirements by Role

Every member of the BCBA Team who practices applied behavior analysis independently must hold a current LABA license from the Massachusetts Board of Registration of Allied Mental Health and Human Services Professions and current BCBA certification from the BACB. Any employee practicing in an assistant applied behavior analyst capacity must hold a current Licensed Assistant Applied Behavior Analyst (Assistant LABA) license from the Massachusetts Board of Registration of Allied Mental Health and Human Services Professions and current BCaBA certification, and work under BCBA supervision. In Massachusetts, the credential that authorizes practice is the state license: the LABA license for independent practice and the Assistant LABA license for assistant-capacity practice (262 CMR 10.00), each based on a qualifying degree, supervised experience, and the Board-approved BACB examination. BACB certification (BCBA or BCaBA) is the certification behind that licensing examination and is required by ABAS and by most commercial payers, but it is not by itself a Massachusetts practice credential. Every member of the Behavior Technician Team must meet MassHealth's qualification requirements for behavior technicians and work under the supervision of a qualified behavior analyst. RBT certification is one qualifying pathway; a behavior technician who is not RBT-certified qualifies through the education and experience standards MassHealth recognizes. ABAS's standard is for behavior technicians to obtain and maintain RBT certification, and ABAS expects RBT certification to become required; this policy will be updated to require it when that takes effect. No one may deliver, supervise, or bill a service that requires a credential they do not hold in active status. An employee advancing from one credential to another, such as an Assistant LABA working toward LABA licensure and BCBA certification, practices only within the scope of the credential they hold in active status until the higher credential is issued.

5.2 Organizational Licenses and Enrollment

ABAS must maintain active MassHealth provider enrollment and meet MassHealth credentialing, screening, and revalidation requirements for the organization and its rendering providers. The Executive Director is accountable for organizational licenses and enrollments, and the Director of Operations maintains them, including renewals, revalidations, and required notices to MassHealth of changes in ownership, location, or key personnel.

5.3 Verification at Hire

Before a new hire delivers or supervises any service, ABAS must verify each required credential by primary source: the Board's license lookup for LABA and Assistant LABA licensure and the BACB certificant registry for BCBA, BCaBA, and RBT certification. For a behavior technician who is not RBT-certified, ABAS verifies and documents the education and experience that qualify the person under MassHealth's standards in place of a board registry check. The verification record (source, date, result, and the person who performed it) is kept in the personnel file. An offer may be made contingent on credentials, but no clinical work may begin, and no claim may be submitted, until verification is complete.

5.4 Renewal and Maintenance

Each credentialed employee is personally responsible for renewing their license and certification before expiration and for completing the continuing education, supervision, and ethics requirements their credential carries. Employees must provide evidence of each renewal to the Employee Relations Specialist, who re-verifies it by primary source. ABAS tracks all credential expiration dates centrally and issues reminders in advance of each deadline, but a reminder failure does not excuse an individual lapse.

5.5 Practice Within Scope

Employees must deliver only the services their credential and role permit. Behavior technicians work under the supervision of a qualified behavior analyst and must not design or modify treatment plans, conduct assessments reserved to behavior analysts, or practice unsupervised. Employees must not misrepresent their credentials to clients, payers, or colleagues, and ABAS must not represent an employee as holding a credential they do not hold. Rendering provider information on claims must match the person who actually delivered the service and that person's actual credential.

5.6 Lapse, Suspension, and Disciplinary Action

An employee whose required credential lapses, or who becomes the subject of suspension, revocation, surrender, denial, or disciplinary action by the Board or the BACB, must report it to the Compliance Officer within one business day of learning of it. ABAS immediately removes the employee from credentialed duties until the credential is restored to active status and re-verified by primary source. Services delivered during a lapse may not be billed; any claims already submitted for such services are handled as potential overpayments under POL-004. A lapse caused by the employee's failure to renew, or failure to report a lapse, may result in disciplinary action up to and including termination.

Procedures

Responsibilities

Steps

1. Before a new hire's first day of clinical work, the Employee Relations Specialist verifies each required credential by primary source and files the verification record in the personnel file.
2. The Employee Relations Specialist enters each credential, its identifier, and its expiration date in ABAS's practice management system, which serves as the credential tracking system of record.
3. The Employee Relations Specialist issues renewal reminders to the employee and their supervisor 90 days and 30 days before each expiration date.
4. The employee submits evidence of renewal before the expiration date; the Employee Relations Specialist re-verifies by primary source and updates the record in the practice management system.
5. If a credential reaches its expiration date without verified renewal, the Director of Operations removes the employee from the clinical schedule and the Billing & Recovery Specialist holds any unsubmitted claims for that provider.
6. Reported lapses, board actions, and scope-of-practice concerns are logged and investigated under POL-003 and its Compliance Ticket Management SOP; the employee returns to credentialed duties only after re-verification.
7. The Compliance Officer audits the credential records in the practice management system and a sample of personnel files at least annually and reports results to the Compliance Committee.

Training Requirements

All ABAS employees must complete training on this policy during onboarding and as part of annual compliance refresher training. Credentialed employees receive role-specific orientation at hire covering their renewal cycle, continuing education and supervision obligations, the scope of practice their credential allows, and the duty to report a lapse or board action within one business day. Behavior Technician Team members also acknowledge the RBT Ethics Code section of the Employee Handbook (Section 18) as part of onboarding. The Compliance Officer tracks completion and reports it to the Compliance Committee as part of regular compliance reporting.

Reporting and Enforcement

Employees who become aware of a lapsed or misrepresented credential, unsupervised practice, or any other potential violation of this policy must report it through the channels described in POL-003 (Compliance Reporting, Investigation, and Resolution), including the anonymous web form and the compliance ticketing system. Reports are investigated under POL-003 and its Compliance Ticket Management SOP. A confirmed violation may result in disciplinary action up to and including termination, repayment of amounts billed for services delivered without a valid credential, and notification to MassHealth, the Board, or the BACB where required. ABAS will not retaliate against any person who reports a concern in good faith.

Forms Reference

The register supporting this policy is maintained by the Employee Relations Specialist:

The Employee Relations Specialist records each employee credential, its identifier, expiration, and primary-source verification in the credential tracking log (REG-001), and issues the 90-day and 30-day renewal reminders from it. ABAS's practice management system is the electronic realization of REG-001 and serves as the credential tracking system of record. Organization-level enrollments, principally MassHealth provider enrollment, are tracked in the same log by the Director of Operations.