How to start an ABA practice in Illinois

Illinois requires a Licensed Behavior Analyst (LBA); Licensed Assistant Behavior Analyst (LABA) from Illinois Department of Financial and Professional Regulation (IDFPR) to operate an ABA practice. Fee: $400. Processing time: Licensing began January 15, 2025 in the CORE online system. IDFPR delayed enforcement against unlicensed practice until April 21, 2025 to clear the application backlog.

License required

Yes

License

Licensed Behavior Analyst (LBA); Licensed Assistant Behavior Analyst (LABA)

Issuing agency

Illinois Department of Financial and Professional Regulation (IDFPR)

Fee

$400

Fee details

Application: LBA $400, LABA $100 (68 Ill. Adm. Code 1376).

Renewal

Renewal: LBA $300, LABA $75. Restoration: $50 plus lapsed renewal fees, capped at $600 for an LBA and $150 for a LABA.

Processing time

Licensing began January 15, 2025 in the CORE online system. IDFPR delayed enforcement against unlicensed practice until April 21, 2025 to clear the application backlog.

Professional license

board: IDFPR (with a Behavior Analyst Licensing Board); statute: Behavior Analyst Licensing Act, 225 ILCS 6; 68 Ill. Adm. Code 1376; behavior analyst: LBA license requires BCBA certification, BACB-approved education, the BCBA exam and a fingerprint check.; assistant behavior analyst: LABA license is separate and requires BCaBA-level credentials, at lower fees.; technician: No Illinois technician license. Medicaid 'ABS Technicians' must be enrolled in IMPACT and work under an ABS Clinician; the 2020 notice required RBT credentials. Technician credential rules after the 2023 notice were not re-verified.; agency or clinic license: No facility license, but 225 ILCS 6/150 limits who may own or operate an ABA business: everyone in the business who renders ABA must be licensed starting January 15, 2027.; medicaid enrollment: HFS covers ABA, called Adaptive Behavior Support (ABS), for ages 0–20 with autism under fee-for-service and managed care with prior authorization (since November 1, 2020). The August 2023 notice (effective for dates of service from February 1, 2022) supersedes earlier rules. ABS is reimbursable to enrolled Behavioral Health Clinics and to independently enrolled ABS Clinicians (BCBAs in good standing, or licensed 'ABS Developmental Clinicians'). It removed the LPHA supervision and written collaborative agreement requirements. Every rendering individual, including ABS Technicians employed by a clinic, must be enrolled in IMPACT.

Regulation

225 ILCS 6; 68 Ill. Adm. Code 1376; HFS Provider Notices of Oct. 30, 2020 and Aug. 24, 2023

1. Hold current BCBA certification and a BACB-approved education (transcripts or certification of education)
2. Show proof of passing the BCBA exam
3. Complete a fingerprint background check through an approved Illinois vendor (prints no more than 60 days old)
4. Apply online in IDFPR's CORE system and pay the fee
5. ABA business owners: by January 15, 2027, every owner, officer, agent and employee who renders ABA in a business must be licensed; unlicensed owners must divest

Staffing

• 225 ILCS 6/150: starting 24 months after licensing began (by January 15, 2027), a business may provide ABA only if every member, partner, shareholder, director, officer, owner, agent and employee who renders ABA holds a valid license
• Medicaid: independently enrolled ABS Clinicians may bill only for their own services or those of ABS Technicians they employ or contract with and supervise

Program

Illinois Medical Assistance Program (Department of Healthcare and Family Services)

Enrollment portal

IMPACT (Illinois Medicaid Program Advanced Cloud Technology) provider enrollment system

Fiscal agent

None named — HFS runs provider enrollment itself through IMPACT Provider Enrollment Services

Application fee

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

IMPACT uses CMS's risk levels and sets its own for provider types CMS does not classify; high-risk providers must submit fingerprints and pass criminal background checks before enrollment. DMEPOS suppliers are high risk and must be licensed (or exempt) and accredited by a recognized body. 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

IMPACT does onsite visits before and after enrollment for moderate- and high-risk providers, including at revalidation. 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

HFS restarted revalidation in IMPACT in rolling stages from September 3, 2024; providers revalidate through the 'Provider Revalidation List' in IMPACT and may be asked for more documents. Federal rule (42 CFR 455.414): every enrolled provider must be revalidated at least once every 5 years.

Full Illinois Medicaid enrollment guide →

CON program

Yes

Program

Certificate of Need permit (Illinois Health Facilities Planning Act)

Agency

Illinois Health Facilities and Services Review Board (HFSRB), staffed by the Illinois Department of Public Health

Services covered

• hospitals
• ambulatory surgical treatment centers
• skilled and intermediate long-term care facilities (nursing homes)
• ID/DD and MC/DD skilled and intermediate care facilities
• Specialized Mental Health Rehabilitation Act facilities
• kidney disease treatment centers / freestanding hemodialysis
• state-operated hospitals, nursing homes, surgery and dialysis centers

Illinois certificate of need details →

State minimum wage

$15.00 an hour

Effective

2025-01-01

Scheduled increases

No scheduled change found in the official sources reviewed.

Direct-care wage floor

Department on Aging homemaker rates were raised to $30.80/hour from 2026-01-01 to sustain a minimum wage of $18.75/hour for direct service workers (after $17 in 2024 and $18 in 2025).

Rate pass-through

In-home service providers must certify they pay the mandated wage increase, and may not cut fringe benefits (paid time off, training pay, health insurance, travel) in response to the rate increases.

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)

512 (as of Sep 13, 2026)

Total Medicaid and CHIP enrollment (latest reported month)

2,932,625 (as of Jun 1, 2026)

All Illinois ABA Medicaid rates, ranked →

• Adults with Developmental Disabilities Waiver (1915(c))
• Persons with Brain Injury Waiver (1915(c))
• Residential Waiver for Children and Young Adults with Developmental Disabilities (1915(c))
• Support Waiver for Children and Young Adults with Developmental Disabilities (1915(c))
• Persons who are Elderly Waiver (1915(c))
• Persons with HIV or AIDS (1915(c))
• Medically Fragile, Technology Dependent Waiver (1915(c))
• Persons with Disabilities Waiver (1915(c))
• Supportive Living Program Waiver (1915(c))

Illinois waivers and waiting lists →