The five rows below carry the operative statutory language verbatim, each quote pulled from the official code. This page is one state from the full state-by-state reference. Nothing here is legal, tax, or financial advice.
The five-part test in brief
Whether an ABA practice needs a professional entity is a stack of five questions. The licensing act is the gateway, because an unlicensed profession is generally not a professional service and an ordinary entity governs. The professional-entity statute supplies the form and the ownership rule that applies if that form is used. The scope definition decides whether ABA is actually inside that statute. The corporate-practice doctrine, a separate body of law that often lives in the medical practice act or case law rather than the entity statute, is usually what forces licensed ownership and pushes outside capital into a management company. And the fee-splitting and anti-remuneration rules constrain management-fee economics even where ownership is open. The rows below run those five against this state's actual code, quoting the operative language so the position rests on the statute.
Arizona, provision by provision
Arizona
Ownership open; any business entity permittedHolding: a non-licensee may wholly own a standard Arizona LLC that delivers ABA. ABA is licensed, but a 2022 statute lets any health professional practice through or be employed by any form of business entity, the professional forms are optional, and even a professional corporation may sell up to forty-nine percent of its voting shares to non-licensees.
Yes. Arizona licenses behavior analysts under Title 32, Chapter 19.1, Article 4, with the license issued and regulated by the Board of Psychologist Examiners, and applied behavior analysis has been a licensed profession in the state since 2011. Practicing or supervising behavior analysis without a license is a class 2 misdemeanor under the article's violations section.
Conclusion. ABA is a licensed profession in Arizona, the gateway for the entity questions below, but the gateway carries no ownership rule with it.
A professional entity is not required; Arizona permits ABA through an ordinary business entity, and the professional forms are optional. If the professional corporation or professional LLC is chosen, Arizona is unusually open about ownership: it permits non-licensees to hold up to forty-nine percent of the voting shares, far more room for outside equity than the licensee-only rule in strict states.
Conclusion. No professional entity is required, and even the optional professional form leaves room for non-licensees to hold up to forty-nine percent of the voting shares.
The professional forms reach ABA because Arizona defines a professional service by general category, a service that only a licensed person may lawfully render, so applied behavior analysis qualifies and a professional corporation or PLLC is available to a behavior analyst. But availability is the operative word, and the next axis makes the professional form optional rather than required.
Conclusion. ABA qualifies for the professional form, so the form is available; availability is not a requirement, as the next axis shows.
Ownership. No ownership-by-law rule restricts who may hold equity in an ABA practice. A 2022 statute lets a health professional practice through, or be employed by, any form of business entity, with optometry the only carve-out, and the companion definition makes a Chapter 19.1 behavior analyst a health professional, so the rule reaches ABA directly. The professional-corporation statutes themselves also preserve a licensed professional's right to render services in any other business form, including an ordinary corporation, unless the licensing law forbids it, and the behavior analyst article does not.
Clinical control. The Arizona corporate-practice doctrine is only a narrow common-law rule drawn from two old optometry cases; it has never been extended by statute to force licensed ownership or to require that clinical judgment be held by the owner rather than by the licensed staff who render the service. Ownership is open because neither equity nor clinical control is restricted for ABA.
Conclusion. A non-licensee may wholly own a standard LLC that employs licensed behavior analysts.
Open ownership does not mean open money. A behavior analyst remains subject to the article's grounds for discipline, which reach unprofessional conduct and improper financial arrangements, and any ABA practice that bills Medicaid through AHCCCS or commercial insurers is bound by the federal anti-kickback statute and the Stark self-referral rules. Arizona does not layer on a broad professional fee-splitting statute, so the binding limits on a management fee come mainly from the federal and payor side.
Conclusion. A management agreement should be priced at fair market value to the federal and payor rules; Arizona adds no broad state fee-splitting bar.
ABA is a licensed profession in Arizona (axis one), but no professional entity is required: the professional forms are optional, and even a professional corporation may sell up to forty-nine percent of its voting shares to non-licensees (axes two and three). A 2022 statute lets any health professional, including a behavior analyst, practice through or be employed by any form of business entity, and the only corporate-practice rule is a narrow optometry-based common-law doctrine never extended to ABA (axis four). The money rules come from the federal and payor side rather than a state fee-splitting statute (axis five). Therefore a non-licensee may wholly own a standard Arizona LLC that delivers ABA.
Outlook: how this verdict could change
Likelihood of change: Low. Arizona has trended toward openness and is not among the states that tightened ownership in 2025, and no ABA-specific bill has been identified. The verdict would change only if the 2022 statute that lets any business entity employ a licensee were repealed or narrowed, or a new corporate-practice or ownership-restriction law were enacted.
What to watch. Arizona legislative activity touching the professional-entity statutes or a new corporate-practice rule; none is currently pending for ABA.
Disruption if it changes: Low. Any realistic change would add reporting or clinical-control terms rather than a new entity form, so existing entities and credentials would carry over.
Where professional advice is essential, not optional
Verbatim statutory text is a starting point, not a conclusion. Statutes are amended, agencies issue rules that fill them in, and courts interpret them. Arizona is also in the middle of moving the behavior analyst statutes into a new chapter and weighing a separate behavior analyst board, so section numbers may shift even where the substance holds. Use this page to locate the operative provisions and to speak from the source, then confirm the current text and citations against the official code and engage qualified Arizona counsel before acting. The entity verdict is also only one layer of an Arizona practice's obligations, alongside the facility and records rules and the Arizona Medicaid enrollment that discloses the entity and its owners. Nothing here is legal, tax, or financial advice.
The provisions quoted here change and are interpreted by agencies and courts, and the behavior analyst statutes are being renumbered. The official Arizona code and qualified Arizona counsel are the authoritative sources. Neither this page nor any secondary source should be relied on in place of direct verification and professional advice.