How to start an ABA practice in Vermont

Vermont requires a Applied Behavior Analyst; Assistant Behavior Analyst from Vermont Secretary of State, Office of Professional Regulation (Director, with advisor appointees) to operate an ABA practice. Fee: Set in 3 V.S.A. § 125(b) (26 V.S.A. § 4926); amount not captured.

License required

Yes

License

Applied Behavior Analyst; Assistant Behavior Analyst

Issuing agency

Vermont Secretary of State, Office of Professional Regulation (Director, with advisor appointees)

Fee

Set in 3 V.S.A. § 125(b) (26 V.S.A. § 4926); amount not captured.

Renewal

Every 2 years · Licenses renew every two years on a schedule set by the Director (26 V.S.A. § 4925); fee per 3 V.S.A. § 125(b).

Professional license

board: Office of Professional Regulation (Director) with advisor appointees; statute: 26 V.S.A. §§ 4901–4932 (chapter 95); fees 3 V.S.A. § 125(b); behavior analyst: License required to practice ABA. Employing unlicensed people to practice as analysts is prohibited (26 V.S.A. § 4903).; assistant behavior analyst: Separate license; practices under an applied behavior analyst's supervision.; technician: No state technician license. 26 V.S.A. § 4904(3) exempts school-employed behavior interventionists or paraprofessionals working under close direction of a licensed supervisor. § 4904(1)(C) exempts employees or contractors of the Agency of Human Services who do not use the 'behavior analysis' title. Other private-practice technicians are not expressly addressed.

Regulation

26 V.S.A. ch. 95; 3 V.S.A. § 125(b)

1. Analyst: earn a doctoral or master's degree from an ABAI-accredited or Director-approved program that includes a BACB-approved course sequence
2. Complete at least 1,500 hours of approved practicum or supervised experience over at least one year (assistant: bachelor's degree, 1,000 hours, at least 50 hours one-to-one with a supervisor)
3. Pass a nationally recognized exam as defined by the Director
4. Apply to OPR under oath with the fee
5. Renew every two years (CE may be required by rule)

Program

Vermont Medicaid / Green Mountain Care (Department of Vermont Health Access, DVHA)

Enrollment portal

Provider Management Module (PMM)

Fiscal agent

Gainwell Technologies (enrollment department and revalidation notices)

Application fee

Under 42 CFR 455.460, institutional and certain other providers pay the application fee on initial enrollment, new practice locations and revalidation. Proof of payment goes to DVHA with the application. The fee is waived if already paid to Medicare, another state's Medicaid program or another Vermont state agency. CMS decides hardship waivers, and DVHA passes on the result. Under the federal rule (42 CFR 455.460), institutional providers pay the CMS application fee when they first enroll, re-enroll or revalidate. The fee is $750 for calendar year 2026. Individual physicians and non-physician practitioners do not pay it. A fee already paid to Medicare or to another state's Medicaid program counts.

Fingerprinting

High-risk providers get a fingerprint-based criminal background check. DVHA follows the CMS risk categories, under which newly enrolling DMEPOS suppliers and newly enrolling home health agencies are high risk. DVHA may raise a provider's risk level at any time, for example after a payment suspension, exclusion or Medicare revocation.

Site visit

Moderate-risk providers get on-site visits, for example ambulance suppliers, community mental health centers, CORFs, hospices, independent clinical labs, IDTFs and physical therapists. High-risk providers get them too.

Revalidation

Providers get system notices 90 and 45 days before their contract end date, and screening is repeated at revalidation. Missing the deadline ends enrollment, and coming back requires a new application. Under its 2026 strategy, Vermont is revalidating high-risk providers off-cycle starting July 1, 2026 and selected moderate-risk providers starting January 1, 2027 (about 300 providers); Gainwell contacts those affected. Federal rule (42 CFR 455.414) requires the state to revalidate every enrolled provider at least once every 5 years.

Full Vermont Medicaid enrollment guide →

CON program

Yes

Program

Certificate of Need

Agency

Green Mountain Care Board (GMCB)

Services covered

• construction, purchase, renovation or capital expenditure by a health care facility above $10,000,000
• changes in licensed bed counts (addition, conversion or relocation)
• offering any home health service
• transfer of more than 50% ownership of a health care facility other than a hospital or nursing home
• single diagnostic or therapeutic equipment items above $5,000,000
• new services or technology with annual operating expense above $3,000,000
• conceptual development phase CON for projects above $50,000,000

Vermont certificate of need details →

State minimum wage

$14.42 an hour

Effective

2026-01-01

Scheduled increases

Adjusted each January 1 by CPI; the 2027 rate was not found in the sources reviewed.

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)

33 (as of Sep 13, 2026)

Total Medicaid and CHIP enrollment (latest reported month)

145,492 (as of Jun 1, 2026)

All Vermont ABA Medicaid rates, ranked →

• Vermont Global Commitment to Health (1115)

Vermont waivers and waiting lists →