ACT 62 Behavior Specialist FAQ 5/23/2014
This document has been developed by the Department of Public Welfare (DPW), with input
from the Board of Medicine. It contains information specific to the implementation of ACT 62,
the Behavior Specialist regulations, and BSC-ASD services, as it pertains to DPW’s behavioral
health rehabilitation (BHRS) services. This document replaces the FAQs issued on 11/27/2012.
The Behavior Specialist regulations can be downloaded from the following link:
http://www.pacode.com/secure/data/049/chapter18/subchapItoc.html
QUESTIONS ABOUT ACT 62
1. Does Act 62 apply to the Medical Assistance (MA) program as well as private
insurance?
Act 62 states that it applies to both health insurance policies and government programs
and defines government programs as including the MA program.
2. What are BSC-ASD services?
BSC-ASD services are Behavioral Specialist Consultant (BSC) services delivered to youth
with an autism spectrum disorder (ASD) diagnosis. BSC services are described in Medical
Assistance Bulletin 01-94-01, Outpatient Psychiatric Services for Children Under 21 Years
of Age (January 11, 1994):
http://www.dpw.state.pa.us/publications/bulletinsearch/bulletinselected/index.htm?b
n=01-94-01&o=N&po=OMAP&id=01/11/1994
BSC services have not changed, only the qualifications one must have to serve children
with ASD have changed.
3. When will DPW start requiring that in order to receive payment for providing BSC-ASD
services, the individual who provides BSC-ASD services must have either a Behavior
Specialist license or a professional license whose scope of practice includes the
diagnostic assessment or treatment of ASD?
May 26, 2014
4. After May 26, 2014, who can be paid for providing BSC-ASD services?
Staff providing BSC-ASD services must have a Behavior Specialist license or a license
whose scope of practice includes the diagnostic assessment or treatment of ASD. The
preamble to the behavior specialist licensure regulations identifies licensed
psychologists, licensed social workers, licensed clinical social workers, and licensed
professional counselors as professionals who are currently providing treatment of ASD
pursuant to treatment plans and provides that to the extent that their scope of practice
under such a license includes the diagnostic assessment or treatment of ASD these
professionals will not need to obtain a behavior specialist license. In addition, the
licensing board for licensed marriage and family therapists has confirmed that the scope
of practice for licensed marriage and family therapists includes the treatment of ASD.
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Other licensed professionals who believe that their scope of practice includes the
diagnostic assessment or treatment of ASD should contact their respective licensing
board for verification.
5. Can DPW or the Board of Medicine tell me if I have the qualifications to be a licensed
Behavior Specialist before I submit my licensure application?
No. An individual's qualifications for licensure cannot be evaluated until all application
materials have been received by the Board of Medicine.
6. Once I have obtained my Behavior Specialist license, will I be able to be paid for
providing BSC-ASD services?
In order to receive payment for BSC-ASD services through the MA program as a licensed
Behavior Specialist you must either work for a provider that can bill the MA program for
BSC-ASD services or enroll in the MA program as an individual.
7. Can an experienced BSC be “grandfathered”?
No. ACT 62 establishes the minimum standards necessary to obtain l a Behavior
Specialist license. ACT 62 does not allow “grandfathering” of experienced individuals or
of provider types.
8. Must a master’s level clinician who has a Board Certified Behavior Analyst (BCBA)
certification obtain a license to receive payment through the MA program for BSC-ASD
services after May 26, 2014?
A BCBA needs to obtain either a Behavior Specialist license or a license whose scope of
practice includes the diagnostic assessment or treatment of ASD in order to receive
payment through the MA program for BSC-ASDs service after May 26, 2014.
9. Can individuals with licenses or certifications from other states receive payment for
BSC-ASD services through the MA program?
No, individuals with licenses or certifications from other states will not receive payment
for BSC-ASD services through the MA program.
10. I am a licensed psychologist who provides BHRS. I currently have BSCs working for me
who are unlicensed. After May 26, 2014, will they need to obtain a license to provide
BSC-ASD services or will their qualifications be covered under my psychologist license?
MA will not pay for BSC services provided by unlicensed individuals to children with ASD
after May 26, 2014 even if the individuals are working under the direction or supervision
of an appropriately licensed individual. In other words, the individual providing BSC-ASD
services will need to be licensed in order to receive MA reimbursement.
11. Do individuals have to be licensed to work with youth on the spectrum if the ASD
diagnosis is not primary?
Yes. If an individual is providing BSC-ASD services to a youth with an ASD diagnosis the
staff person must be licensed after May 26, 2014 even if the ASD diagnosis is not the
primary diagnosis.
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12. Do unlicensed mental health professionals who work within a program that provides a
BHR service other than BSC-ASD services, such as a Summer Therapeutic Activities
Program (STAP) or a site based autism program, also need to obtain a license?
Unlicensed mental health professionals who work within a program that provides a BHR
service other than BSC-ASD services are not required by DPW to obtain a license to
receive payment through the MA program. However, managed care organizations may
require that mental health professionals who work within a program that provides a
BHR service other than BSC-ASD services must obtain a license.
QUESTIONS ABOUT EDUCATION, TRAINING AND EXPERIENCE REQUIREMENTS
13. What are the educational requirements for the Behavior Specialist license?
You must have a Master’s Degree or higher or a Post-Master’s Certificate in Behavioral
Analysis; Special Education; Speech Therapy; Psychology (School, Clinical, Counseling or
Developmental); Professional Counseling; Social Work; Occupational Therapy; or Nursing
(the "named fields”) or in a field related to a “named field.”
14. What if my Master’s Degree or Post-Master’s Certificate is NOT in a “named field,” but
is in a related field?
The university/college must verify that the Major/Degree is in a related field. The Board
of Medicine may request additional information from the university/college and will
make the final determination about whether or not the degree is in a field related to a
“named field.”
15. Can I submit an application if my Master’s Degree or Post-Master’s Certificate is not in
either a “named field” or a field related to a “named field”?
If a university/college is not able to verify that you have a Master’s Degree or PostMaster’s Certificate in a “named field” or a field related to a “named field,” you must
obtain a Master’s degree or Post-Master’s Certificate in a named field or a field related
to a “named field” to be eligible for a Behavior Specialist license. An application SHOULD
NOT be submitted until you have confirmed that your university can provide this
documentation or you have obtained a Master’s Degree or Post-Master’s Certificate in
either a named field or a field related to a “named field.”
16. How do I fulfill the required 90 hours of Evidence-Based coursework/trainings?
Every application must include verification that ALL 90 hours of evidence-based
coursework have been completed. These hours can be completed through:
▪ Accredited college/university coursework (undergraduate or graduate)
▪ Bureau of Autism Services (BAS)-approved supplemental trainings
▪ Behavioral Analyst Certification Board (BACB) Continuing Education
▪ OR a combination of these options.
If your College/University determines that you fulfilled all 90 hours of coursework
through your major course of study, no additional coursework or trainings are required.
If your College/University determines that your degree/post-graduate certificate is in a
“named field” or field related to a “named field,” but none or only some of the 90 hours
of Evidence-Based coursework /training were fulfilled through your major course of
study, then you can fulfill the remaining content hours through additional coursework
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from an accredited college/university (undergraduate work acceptable), through BASapproved trainings or BACB continuing education, OR any combination of these options.
17. Where can I find trainings that have been approved by BAS as counting towards the
requirements for a Behavior Specialist license?
All 90 hours of required training in the 8 content areas are available through BASapproved virtual trainings. They can be accessed on the BAS Virtual Training Center
(VTC), http://bastraining.tiu11.org. There is no cost for BAS Virtual Trainings. When
applicants complete these virtual trainings, they will obtain a certificate of completion
listing the Course Name, Course Number, and the number of hours awarded for each
content area. To submit documentation of completed trainings, complete Section 1 and
Section 2B of Form 5 (Verification of Evidence-Based Coursework form). The verification
form and the certificates verifying completion of approved trainings can be returned
directly to the Board of Medicine by the applicant.
18. Can I submit documentation for trainings provided by other organizations?
The Behavior Specialist regulations require that all supplemental trainings be provided
by an accredited college/university, by the BACB, or approved by BAS. Any training that
is not provided by an accredited college/university, by the BACB, or directly by BAS must
therefore go through the BAS approval process before it can be counted towards the
requirements for a Behavior Specialist license. BAS’s procedure for approving trainings
can be found at http://bastraining.tiu11.org.
To submit documentation of completed trainings to the Board, complete Section 1 and
Section 2B of Form 5 (Verification of Evidence-Based Coursework form). The verification
form and the certificates verifying completion of approved trainings can be returned
directly to the Board of Medicine by the applicant.
Please Note: The Board of Medicine does not evaluate coursework or trainings. Only
submit documentation that complies with the application directions.
19. BACB continuing education is awarded as CEU credits, rather than indicating specific
clock hours. How will this translate into the required 90 hours of coursework?
BACB awards CEU credits based on a minimum of 50 minutes of instruction, such that
one CEU credit is given for each minimum 50-minute period. Therefore, for purposes of
the 90 hours of coursework requirement, 90 CEU credits are required to meet the
requirement. For each BACB continuing education credit earned, an individual can
submit for the equivalent number of hours towards the 90 hours of coursework. For
example, if an individual has documentation reflecting 1.5 BCBA CEUs, the credits can be
applied towards 1.5 hours of the required coursework.
20. What is considered acceptable experience with functional behavior assessments
(FBAs)?
The Behavior Specialist regulations require an applicant for a Behavior Specialist license
to have at least 1 year of experience involving functional behavior assessments of
individuals under 21 years of age. This includes the development and implementation of
behavioral supports or treatment plans. For example, experience implementing an FBA
by a Therapeutic Staff Support worker can be used to satisfy the requirement. Experience
can also be obtained providing services outside of BHRS.
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The experience needs to be face-to-face. Verification of experience does not need to be
documented by the applicant’s direct supervisor but must be verified by the agency
where the applicant worked.
21. What is considered acceptable clinical experience?
The Behavior Specialist regulations require an applicant for a Behavior Specialist license
to have completed 1,000 hours of direct clinical experience with individuals with
behavioral challenges OR 1,000 hours of experience in a related field with individuals
with autism spectrum disorders.
Experience gained subsequent to obtaining a bachelor’s degree can be counted towards
meeting this requirement. Examples of experiences that meet the clinical experience
requirement include employment or verified volunteer work as a teacher in an autistic
support class, job coach, residential program manager or work experience provided in a
summer therapeutic activities program. The clinical experience can be working with
either children OR adults. Verification of experience does not need to be documented by
the applicant’s direct supervisor but must be verified by the agency where the applicant
worked.
QUESTIONS ABOUT THE APPLICATION PROCESS
22. Where can I obtain a copy of the most recent Behavior Specialist license application?
The most current version of the application for a Behavior Specialist license is available
on the Board of Medicine website: www.dos.state.pa.us. Select "Licensing"; "HealthRelated Boards;" then "State Board of Medicine."
23. Can the application items be submitted separately, or must they all be submitted
together?
▪ Application Items 1-8 should be submitted together, at the same time, with the
$75 fee, which can be paid via check or money order.
▪ Application Items 9-14 can be submitted separately as they become available.
However, they must be submitted within 90 days of the submission of the first 8
items.
24. How will I know if the Board of Medicine received my application?
You will receive a letter of receipt from the Board of Medicine, which will include an
individual identifier that you can use to track the status of your application online.
25. What does it mean if I receive a discrepancy letter?
It means that you did not provide the Board of Medicine with a complete application, or
that there is a question about the information you submitted. After the Board of
Medicine evaluates your application, the Board of Medicine will notify you through a
discrepancy letter what is needed to complete your application.
26. How long will it take before I receive my license?
The Board of Medicine typically processes applications for a Behavior Specialist license
within a 30-60 day timeframe. However, the amount of time it takes for an individual
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applicant to receive a license is dependent upon many factors (e.g., number and type of
discrepancies).
QUESTIONS ABOUT LICENSURE RENEWAL
27. When does the Behavior Specialist license have to be renewed?
Regardless of when a license is issued, the Behavior Specialist license expires on
December 31 of the even-numbered year unless renewed for the next biennium. Renewal
notices will be mailed to the address on file for each active licensee approximately 120
days prior to the December 31 (2014, 2016, 2018…) expiration date.
28. What do I need to do to renew my license?
Instructions regarding the renewal process will be provided in the renewal notice you will
receive prior the expiration of your Behavior Specialist license. To renew your Behavior
Specialist license, you will need to follow the instructions provided by the Board of
Medicine and pay the required biennial renewal fee prior to the expiration of the current
biennium. The current fee is $75.
29. What additional trainings or forms are required for renewal?
No additional training hours or forms are needed for renewal. It is a simple online
process.
ADDITIONAL AREAS OF CLARIFICATION:
30. When billing for BSC-ASD services, who can conduct an FBA for a child with ASD?
Any person who is conducting an FBA for a child with ASD as part of providing BSC-ASD
services must be licensed as a Behavior Specialist or have a license whose scope of
practice includes the diagnostic assessment or treatment of ASD and have either
A) completed the BAS-approved FBA training, including passing the required post-test;
OR
B) be a BCBA.
31. When must I obtain out-of-state child abuse clearances?
You are required to obtain a clearance from any state where you resided or worked
within the last 10 years. If you have problems getting original documentation from
another state, you should provide the Board of Medicine with an official letter or other
communication from that state explaining why the documentation is not able to be
provided in an original format.
32. What degrees must I have to receive payment for BSC-ASD services?
Individuals providing BSC-ASD services must hold a license in order to receive payment
through the MA program. OMHSAS relies on the license to confirm that the individual
providing BSC-ASD services has the graduate degree required by the Behavior Specialist
regulations. OMHSAS does not review degrees separately from the license for individuals
providing BSC-ASD services.
33. Should I use “LBS” to designate that I am a licensed Behavior Specialist?
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Many individuals have begun to use “LBS” to designate that they have a Behavior
Specialist license. Information regarding expected terminology associated with the
licensure of this profession was not specified in the Behavior Specialist law/regulations.
Therefore, neither DPW nor the Board of Medicine is able to provide advice on how a
licensed Behavior Specialist should identify him or herself.
ADDITIONAL INFORMATION:
Additional information on the issues addressed in this FAQ can be found by viewing a Power
Point of a Web-Ex Training conducted by DPW. The Power Point can be found at
http://www.parecovery.org/services_bhrs.shtml
Questions related to the application process for a Behavior Specialist license can be
emailed to [email protected].
 Questions related to training requirements for a Behavior Specialist license can be
emailed to [email protected].
 Additional questions can be emailed to DPW at [email protected].

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