Across Mount Ord
Arizona Behavior Analyst Licensure Basics

This information is presented as a courtesy to prospective applicants for behavior analyst licensure. Board staff cannot provide advice or guidance relative to an individual's choice of education and training, or whether these qualify the individual for licensure. Please consult an attorney for interpretation of Arizona law and consider seeking application mentoring from an Arizona licensed behavior analyst, or a behavior analyst membership association.
 

  1. All requirements for Arizona licensure are provided in Arizona Revised Statutes (A.R.S.) and the Arizona Administrative Code (A.A.C. or Rules). Both the rules and statutes have the force of law.  It is the responsibility of the applicant to compare their education and training to the Board's statutes and rules before applying for licensure.   
     
  2. The statutes regulating the licensure and practice of Behavior Analysis in Arizona are encompassed in Article 4: Licensure starting with A.R.S. § 32-2091
     
  3. Sections 32-2091.02 & 2901.03 list the basic qualifications, education and training requirements for licensure as a behavior analyst. 
     
  4. Rules further define the statutes, providing more details. Article 4 in the Arizona Administrative Code (A.A.C. or Rules) lists the coursework required for licensure under A.A.C. R4-26-405.  Other education requirements are listed in A.A.C. R4-26-404.1.  Applicants are responsible for ensuring their education meets these requirements.
     
  5. Please note, the only national certification board recognized by the Arizona Board of Psychologist Examiners is the Behavior Analyst Certification Board (BACB).  An applicant must pass the BACB's exam for BCBA certification to be considered for licensure as a behavior analyst in Arizona (see #10, below). When applying for BCBA certification with the BACB, the BACB's 2022 Eligibility Requirements handbook is an important resource. The Arizona Board does not have involvement in this process. 
     
  6. In Arizona's rules, R4-26-404.2 provides detailed requirements for the minimum 1,500 hours of supervised experience/fieldwork required to qualify for licensure per A.R.S. § 32-2091.03.  If you have not completed 1,500 hours of supervised fieldwork that meets all the requirements in this Rule, you may not qualify for licensure in Arizona. This includes the requirement that if your supervised experience (fieldwork per BACB's 2022 changes) is taking place in a state that requires licensure for behavior analysts, YOUR SUPERVISOR MUST BE LICENSED IN THE SAME STATE to provide supervision to you, even remotely, even if your supervisor resides in another state.  Per A.R.S. § 32-2091.03(A)(2), supervision takes place where the trainee is providing behavior analytic services to a client, regardless of the supervisor's location.  As part of the application process, AZ Board staff verifies each and every supervisor's license status in the state where you provided behavior analytic services.  Historically, the Committee on Behavior Analysts and the Board have not accepted supervised experience/fieldwork hours for which the supervisor was not licensed in the state where the behavior analytic services were provided by the trainee, if that state requires licensure for behavior analysts. This is true even if the BACB accepted the hours for your BCBA certification. Please see the BACB's website for an up-to-date list of states that offer licensure for behavior analysts. 
     
  7. Remote Supervision:  Yes, remote supervision is acceptable, as long as the supervisor meets the requirements for supervisors in Arizona's statutes and rules (see above for links). This includes meeting the BACB's requirements for supervisors such as completing the BACB's 8-hour supervision training and executing a written contract signed by each and every supervisor before the start of the supervision.  If the trainee IS NOT providing behavior analytic services in Arizona, the supervisor doesn't  have to be licensed in Arizona. If the trainee IS providing behavior analytic services to clients in Arizona, the supervisor MUST BE LICENSED in Arizona, regardless of where the supervisor is located or any other licenses the supervisor might hold. The experience/fieldwork must meet Arizona's requirements in statute and rule in order for those hours to qualify to be applied towards licensure, regardless of where the experience/fieldwork took place. 
     
  8. Supervisors:  It has been noted that the BACB allows qualifying psychologists to be supervisors for a BCBA-candidate's supervised fieldwork.  For Arizona licensure, supervisor qualifications are detailed in R4-26-404.2.  All supervisors of a behavior analyst trainee's supervised fieldwork must meet these qualifications in order for an applicant to apply the hours towards Arizona licensure. If that qualifying supervisor is also a psychologist is not a factor one way or the other. 
     
  9. A word about intensive practicums & concentrated fieldwork:  Per R4-26-404.2(A), the Arizona Board does NOT recognize intensive practicum hours or concentrated fieldwork hours on any other ratio than one hour equals one hour, regardless of the number of supervision hours accrued.  The BACB's rule about more supervision equaling concentrated hours DOES NOT apply to Arizona licensure requirements. To qualify for licensure, applicants must have verification of literally 1,500 hours of supervised experience or fieldwork submitted to the Board, regardless of the BACB's fieldwork type. If an applicant does not have 1,500 hours, Per R4-26-404(A)(2), "To be licensed in Arizona, the individual shall complete additional hours of supervised experience [or fieldwork] to meet the 1500-hour requirement under A.R.S. § 32-2091.03...." 
     
  10. Again, in the Rules, R4-26-404 states, " To be licensed as a behavior analyst in Arizona, an individual shall take and pass the examination administered by the BACB for Board Certified Behavior Analysts as part of its certification process."  If you have not taken and passed the exam for BCBA certification, you may not qualify for licensure as a Behavior Analyst in Arizona. 
     
  11. Only the Committee on Behavior Analysts and the Board can make the determination whether or not an applicant meets requirements and is qualified for licensure in Arizona.