Behavior Analysts as LMHPs

In 2018, Sen. Barker initiated a bill to change the regulations to classify Licensed Behavior Analysts as Licensed Mental Health Practitioners (LMHP).

The bill passed into law and the Commonwealth took the necessary steps to make the change.  As of 11/29/18, the changes have been made: and are the applicable Web sites.

“Licensed mental health professional (LMHP) means a physician, licensed clinical psychologist, licensed professional counselor, licensed clinical social worker, licensed substance abuse treatment practitioner, licensed marriage and family therapist, or certified psychiatric clinical nurse specialist, or licensed behavior analyst.” (emphasis added)

LABAs were not included in the regulations due to push back from the state.

So what does this mean?

Technically, LBAs are authorized to provide the same services as other LMHPs (that include Licensed Professional Counselors, Licensed Clinical Social Workers, among others).

In reality, it will probably be necessary to adjust the manuals that apply to those services to accommodate LBAs.

DMAS is reluctant to do this right now as Virginia is in the midst of a behavioral health redesign.

The timing of the LMHP bill was excellent as LBAs now have a seat the table for these discussions and are better poised to increase the number of services that will be covered by Medicaid, and hopefully eventually private insurance.

For more information, see the Community Mental Health Rehabilitation Services (CMHRS) Manual:

For LBAs who don’t want to wait for the redesign, you may try to work with DBHDS to get licensed to deliver CMHRS services.  The licensing process is arduous and is not suited for LBAs, but it is the only pathway at this time to deliver the broader array of services.

It is very important to note that the designation of LBAs as LMHPs in no way changes our scope of practice.  For instance, diagnosis is NOT generally in an LBA’s scope of practice unless s/he has another license.  Being designated as an LMHP does not allow LBAs to diagnose, even though it is within the purview of other LMHPs.

For information on scope of practice for LBAs see Regulations Governing the Practice of Behavior Analysis Part IV, Page 7.

For information on scope of practice for BCBAs, see the Professional and Ethical Compliance Code at  Specifically, 1.02 Boundaries of Competence. (a) All behavior analysts provide services, teach, and conduct research only within the boundaries of their competence, defined as being commensurate with their education, training, and supervised experience. (b) Behavior analysts provide services, teach, or conduct research in new areas (e.g., populations, techniques, behaviors) only after first undertaking appropriate study, training, supervision, and/or consultation from persons who are competent in those areas. But there are other codes that apply.

A note regarding QMHPs:

QMHPs or Qualified Mental Health Professionals are another level of service providers.  There is no need for LBAs to register as a QMHP due to our status as LMHP.

Board of Counseling registration and information: 

Note that it may or may not be necessary for LABAs and RBTs to register as QMHPs – it would depend on how the organization for which you work is licensed.  Ask your supervisor or contact to figure it out.

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