Regulation of Behavioral Analysts

Behavioral Analysis Overview

Ancillary Services Rules

NC Psychology Board Position Statement on HB 103

Behavior analysis is included in the definition of the practice of psychology, pursuant to NC Gen. Stat. Sec. 90-270.2(8).  In order to practice psychology in North Carolina, including behavior analysis, one must be licensed by the NC Psychology Board, unless one is exempt from licensure pursuant to NC Gen. Stat. Sec. 90-270.4.


NC Psychology Board rules allow a licensee of the Board to employ or supervise anunlicensed individual to provide ancillary services to assist the licensee in the provision of psychological services to clientsThese rules are found under Section .2800 of the Board rules, Ancillary Services.   The Board’s Ancillary Services rules address such areas as scope, titles, employment and supervision, services appropriate and not appropriate for unlicensed individuals.


An individualwho is a behavioral analyst, but not licensed to practice psychology in North Carolina, may provide ancillary services under the supervision and/or employment of a licensed psychologist or psychological associate, but shallnot otherwise practice behavior analysis.  Board Rule 21 NCAC 54 .2806(b) allows for unlicensed persons to “implement specific behavioral interventions that are part of a detailed treatment plan.”  Therefore, an unlicensed behavioral analyst may implement a detailed treatment plan under the supervision of a licensed psychologist or psychological associate.  However, the unlicensed behavioral analyst shallnot conduct assessments and/or develop the treatment plans for individuals, which would be the unlicensed practice of psychology.  It is also important to point out that under Board Rule 21 NCAC 54 .2001(a) the licensed psychologist or psychological associate supervising or employing the unlicensed behavioral analyst is required to “have had face-to-face contact during the course of services with all patients, clients, or other recipients of services who are provided ancillary services by unlicensed persons as part of the psychologist’s services.”