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Mandatory Registered Behavior Technician Credential, 90-Day Grace Period, and Billing Compliance for Applied Behavior Analysis

Per the MO HealthNet Behavioral Health Services Provider Manual, registered behavior technicians (RBTs) are paraprofessionals who must practice under the close, ongoing supervision of a licensed Applied Behavior Analysis (ABA) practitioner.

To help providers recruit staff while maintaining clinical quality, the MO HealthNet Division (MHD) allows a strict 90-day grace period for new technicians to complete their certification:

  • A behavior technician (BT) may render services for up to 90 calendar days from the date they pass their RBT™ initial competency assessment.
  • The technician must successfully pass the national RBT™ examination and be fully credentialed by the Behavior Analyst Certification Board (BACB) by the end of this 90-day grace period.
  • If the technician does not secure the RBT™ credential by day 90, they must immediately stop providing ABA services to MO HealthNet participants.


In the event of an audit, Missouri Medicaid Audit and Compliance (MMAC) monitors these timelines closely. Any claims submitted for services rendered by an uncredentialed RBT beyond the 90th calendar day from their initial competency assessment date are considered non-compliant. All paid claims for these unauthorized services are subject to immediate, full recoupment.

To prevent disruption and financial penalties, MHD recommends that all ABA providers implement the following protocols:

  • Immediately review the onboarding and assessment dates for all un-credentialed BTs currently on staff.
  • Establish an internal tracking mechanism to flag when a BT reaches day 30, 45, and 60 of their grace period, ensuring ample time to schedule and pass the national RBT™ exam.
  • If a BT reaches day 91 without an active BACB credential, do not submit claims for their services. They may not resume billing until their active RBT status may be verified on the BACB registry.
     

Refer to MO HealthNet Provider Bulletin 47-19 for additional information. For questions, email MHD.Education@dss.mo.gov or call 573-751-6683.