How to start an ABA practice in Michigan

Michigan requires a Licensed Behavior Analyst; Licensed Assistant Behavior Analyst from Michigan Department of Licensing and Regulatory Affairs (LARA), Bureau of Professional Licensing — Michigan Board of Behavior Analysts to operate an ABA practice. Fee: $452.40.

License required

Yes

License

Licensed Behavior Analyst; Licensed Assistant Behavior Analyst

Issuing agency

Michigan Department of Licensing and Regulatory Affairs (LARA), Bureau of Professional Licensing — Michigan Board of Behavior Analysts

Fee

$452.40

Fee details

Application fee plus 4-year license fee: $452.40 for behavior analysts and assistant behavior analysts (card payment through MiPLUS). Relicensure: $472.40.

Renewal

Every 4 years · Renewal every 4 years: $374.40 (behavior analyst and assistant).

Professional license

board: Michigan Board of Behavior Analysts (LARA); statute: Public Health Code, MCL 333.18201 et seq. (Part 182A, Applied Behavior Analysis); Michigan Admin. Code behavior analyst rules; behavior analyst: License required; BACB-based qualifications, background check and good moral character, plus state-mandated trainings.; assistant behavior analyst: Separate license; practices ABA under supervision of a Michigan licensed behavior analyst, documented on the supervision verification form.; technician: No state technician license. Under Michigan Medicaid's autism benefit, behavior technicians must be 18 or older, trained, and supervised by the overseeing professional with at least one hour of clinical observation and direction per 10 hours of direct treatment.; medicaid enrollment: Michigan Medicaid covers Behavioral Health Treatment including ABA through the Prepaid Inpatient Health Plans (PIHPs), which contract ABA providers. Qualified providers have included BCBAs, BCaBAs, licensed and limited-licensed psychologists, and Qualified Behavioral Health Professionals. A 2026 MDHHS proposed policy would require BHT to be directed by a licensed behavior analyst.

Regulation

MCL 333.18201–333.18237 (Part 182A); Michigan Medicaid Provider Manual, Behavioral Health and IDD Supports — Behavioral Health Treatment/ABA

1. Apply online through MiPLUS and pay $452.40
2. Complete the criminal background check (fingerprints) using the instructions emailed after you apply
3. Complete one-time human trafficking training and 2 hours of implicit bias training (within the prior 5 years)
4. Assistants: the supervising Michigan LBA submits a Verification of Supervision form confirming supervision meets BACB requirements
5. Renew every 4 years

Training

• Human trafficking identification training (Admin. Rule 338.1821)
• Implicit bias training: 2 hours within 5 years before licensure, and annually per renewal cycle requirements

Program

Michigan Medicaid (Michigan Department of Health and Human Services)

Enrollment portal

Community Health Automated Medicaid Processing System (CHAMPS) — Provider Enrollment

Fiscal agent

None named — MDHHS runs CHAMPS provider enrollment itself

Application fee

Michigan's 2012 bulletin MSA 12-55 charges the fee to every provider type except individual physicians and non-physician practitioners, for each enrolled provider type at initial enrollment and re-enrollment but not at revalidation or for updates. Medicare- or other-state-enrolled providers are exempt, and hardship exceptions can be requested in writing. Federal rule (42 CFR 455.460): the state must collect the CMS application fee from institutional providers that are newly enrolling or re-enrolling; individual physicians and non-physician practitioners are exempt, as are providers already enrolled in (or that already paid the fee to) Medicare or another state's Medicaid/CHIP. CMS set the fee at $750 for calendar year 2026.

Fingerprinting

MSA 12-55 classes newly enrolling home health agencies and DMEPOS suppliers as high risk, subject to fingerprint-based checks; every enrolled provider and 5%+ owner must consent to background checks including fingerprints. Federal rule (42 CFR 455.434, 455.450(c)): providers the state places in the 'high' categorical risk level, and anyone owning 5% or more of such a provider, must submit fingerprints for a criminal background check.

Site visit

MSA 12-55 puts ambulance services, community mental health centers, CORFs, hospices, independent labs, physical therapists, and revalidating home health agencies and DMEPOS suppliers in the moderate tier, subject to unannounced pre- and post-enrollment site visits. Federal rule (42 CFR 455.432, 455.450(b)-(c)): the state must do site visits before and after enrollment for providers in the 'moderate' or 'high' risk levels, and any enrolled provider must allow unannounced on-site inspections.

Revalidation

MDHHS revalidates at least every five years (or sooner on request), with a 90-day window to finish in CHAMPS. Federal rule (42 CFR 455.414): every enrolled provider must be revalidated at least once every 5 years.

Full Michigan Medicaid enrollment guide →

CON program

Yes

Program

Certificate of Need

Agency

Michigan Department of Health and Human Services, Certificate of Need Program; review standards set by the CON Commission

Services covered

• new health facilities and changes in bed capacity
• covered capital expenditures of $2,500,000+ (indexed annually)
• neonatal intensive care / special newborn nursing
• open heart surgery
• extrarenal organ transplantation
• lithotripsy
• megavoltage radiation therapy
• PET
• surgical services (freestanding outpatient surgery, ASCs, hospital surgical departments)
• cardiac catheterization
• fixed and mobile MRI
• fixed and mobile CT
• air ambulance
• child/adolescent specialized psychiatric programs

Michigan certificate of need details →

State minimum wage

$13.73 an hour

Effective

2026-01-01

Scheduled increases

Rises to $15.00 on 2027-01-01 under PA 337 of 2018 as amended in 2025.

Rate pass-through

Medicaid pays a direct care worker wage add-on of $3.40/hour (funded for 2024-10-01 to 2026-09-30); MDHHS and the MI Choice, MI Health Link and PIHP plans must pass it through. The FY2026-27 conference budget keeps the $3.40 increase, requires the uplift to go directly to workers with documented proof, and directs recoupment from employers that do not pass it through.

HCBS 80/20 rule

Federal baseline: 42 CFR 441.302(k) requires the state to show that each provider spends at least 80% of Medicaid payments for homemaker, home health aide and personal care services under 1915(c) waivers on direct care worker pay and benefits. Compliance starts 2030-07-09 (for managed care, the first rating period starting on or after that date); annual payment-adequacy reporting under 441.311(e) starts 2028-07-09. A state may set a lower share for state-defined small providers and exempt providers facing hardship, each only through a public notice-and-comment process. The eCFR text has not changed since 2024-07-09. No state-published 80/20 implementation step (small-provider criteria, hardship exemption or reporting guidance) was found for this state in the official sources reviewed.

Applied behavior analysis organizations — active organization NPIs (NPPES)

449 (as of Sep 13, 2026)

Total Medicaid and CHIP enrollment (latest reported month)

2,130,181 (as of Jun 1, 2026)

• Behavioral Health 1915(i) State Plan Amendment (1915(i))
• Coordinated Health HCBS Waiver (1915(c))
• Children's Waiver Program (1915(c))
• Habilitation Supports Waiver (1915(c))
• Choice Waiver (1915(c))
• Waiver for Children with Serious Emotional Disturbances (1915(c))

Michigan waivers and waiting lists →