Statutory Source Reference · Michigan · 2026

The professional-entity decision for ABA in Michigan

Michigan licenses behavior analysts under the Public Health Code and offers a professional entity that, if used, must be owned by licensed analysts. But the statute forces that form only on a closed list of learned professions, and behavior analysts are not on it, so the form is available and not required. Below are the provisions, verbatim.

Important · Not legal advice; do not rely on this without a lawyer

This page is general educational information, not legal, tax, or financial advice, and it is not produced by an attorney. Reading it creates no attorney-client relationship. The verdict is an interpretation of statutes that are amended, repealed, and reinterpreted by courts and agencies, and that apply differently to the specific facts of any practice, so it may be incomplete, outdated, or wrong. Verbatim text should be confirmed against the current official code. Do not form an entity, raise capital, buy or sell a practice, or make any other decision in reliance on this page. Engage a licensed attorney in Michigan before acting.

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Michigan · summary and verdict
Michigan licenses behavior analysts under Article 15 of the Public Health Code, regulated by LARA. A professional limited liability company or professional corporation is available, and if one is used, every member, manager, or shareholder must be a licensed behavior analyst. But Michigan forces the professional-entity form only on a closed list of learned professions, namely dentist, osteopathic physician, physician, surgeon, clergy, and attorney, and behavior analysts are not on it. By statute a corporation rendering professional services other than a learned profession may instead incorporate as an ordinary corporation, so a non-licensee may own a standard LLC that employs licensed behavior analysts. The professional form is optional for ABA, not mandatory. The live constraints are the Public Health Code fee-splitting ground and the criminal health-care kickback statute, plus Medicaid and payor rules, not an entity-law ownership bar.

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.

Michigan, provision by provision

Michigan

Ownership open; professional entity optional

Holding: a non-licensee may own a standard Michigan LLC that delivers ABA. ABA is licensed, but Michigan compels the professional form only for a closed list of learned professions that omits behavior analysts, and the statute lets a non-learned profession incorporate as an ordinary corporation; the real constraint is on the money side, not on ownership.

1Licensed Profession2Prof Entity State3ABA Prof Entity4Non Professional Ownership5Fee splitting
1Is ABA a licensed profession?

Yes. Michigan licenses behavior analysts and assistant behavior analysts under Part 182A of Article 15 of the Public Health Code, added by 2016 PA 403, with the license issued by the Department of Licensing and Regulatory Affairs through the Board of Behavior Analysts. Because the license sits inside Article 15, the Occupations article of the Public Health Code, behavior analysts are health professionals for the entity and fee questions below, but they are licensed on their own track, not under the medical practice parts that drive Michigan's strongest ownership rules.

Verbatim, MCL § 333.18253(2)Beginning 1 year after the effective date of the rules promulgated under sections 18257 and 18259 for licensure under this part, an individual shall not engage in the practice of applied behavior analysis or practice as an assistant behavior analyst unless licensed or otherwise authorized under this article.

Conclusion. ABA is a licensed health profession in Michigan, but licensed on its own track rather than under the medical practice parts that drive the strongest ownership rules.

2The professional-entity rule: is one required, and who may own it

A professional entity is not required. Michigan compels the professional form only for a narrow, historically rooted set of professions, dentists, osteopathic physicians, physicians, surgeons, clergy, and attorneys, which its regulator treats as the only fields that may operate solely as a professional corporation or professional limited liability company. Behavior analysts are not in that set; they sit with counselors, social workers, and therapists, who use a standard LLC that a non-licensee may own. If a behavior analyst does elect a professional limited liability company, its members and managers must all be licensed, and the professional-corporation chapter of the Business Corporation Act imposes the parallel restriction on shareholders.

Verbatim, MCL § 450.4904(1)Except as provided in this section or otherwise prohibited, a professional limited liability company may render 1 or more professional services, and each member and manager must be a licensed person in 1 or more of the professional services rendered by the company.

Conclusion. The professional form is optional for ABA; a standard LLC that a non-licensee may own governs, with the all-licensed-members rule applying only if a professional LLC is elected.

3Does the rule reach ABA? The scope link

Michigan defines a professional service by general category, any personal service that requires a license, so applied behavior analysis qualifies even though behavior analysts are not named in the illustrative list. And because ABA is a service included within the Public Health Code, a professional LLC rendering it must have all licensed members and managers. This rule binds the professional form if you adopt it; it does not by itself force you into that form.

Verbatim, MCL § 450.4904(2)Except as provided in subsection (3) or (4), if a professional limited liability company renders a professional service that is included within the public health code, 1978 PA 368, MCL 333.1101 to 333.25211, then all members and managers of the company must be licensed or legally authorized in this state to render the same professional service.

Conclusion. The all-licensed-members rule binds the professional form if adopted, but it does not force a behavior analyst into that form.

4Learned-profession doctrine and ownership by law

Michigan's corporate-practice rule runs through a statutory learned-profession doctrine: a corporation rendering services in a learned profession must use a professional corporation, but the term learned profession is a closed list, and behavior analysts are not on it. For professional services other than a learned profession, the statute expressly lets the practice incorporate as an ordinary corporation. So a non-licensee may own a standard LLC or corporation that employs licensed behavior analysts, and the medical learned-profession doctrine does not reach ABA. One caveat: a Michigan court left open, for physical therapists, whether a non-learned health profession might still be pushed toward the professional form, so the statute's text settles the question but it has not been tested for ABA.

Verbatim, MCL § 450.1201(3)A corporation incorporated to provide professional services other than services in a learned profession may comply with chapter 2A and incorporate as a professional corporation, or may incorporate as a corporation under chapter 2 without complying with chapter 2A.
Verbatim, MCL § 450.1109(1) (the closed list)Services in a learned profession means services provided to the public by a dentist, an osteopathic physician, a physician, a surgeon, a doctor of divinity or other clergy, or an attorney-at-law.

Conclusion. The learned-profession doctrine reaches only its closed list and does not include behavior analysts, so nothing forces licensed ownership of an ABA practice.

5Fee-splitting and illegal remuneration

Even though ownership is open, the money rules still bite. The Public Health Code makes dividing fees for referrals and accepting kickbacks an unethical business practice and a disciplinary ground, and that ground applies to every Article 15 health professional, behavior analysts included. Layered on top is Michigan's criminal health-care kickback statute, which makes soliciting, paying, or receiving a kickback in connection with services paid by a health care insurer a felony, and that statute reaches anyone, entity or individual. For Medicaid-funded ABA the federal anti-kickback statute and Stark rules apply as well.

Verbatim, MCL § 333.16221(d)(ii)Dividing fees for referral of patients or accepting kickbacks on medical or surgical services, appliances, or medications purchased by or in behalf of patients.

Conclusion. The binding constraint in Michigan is on referral and kickback economics, including the criminal kickback statute, not on who may own the entity; management-fee structures must be built to those rules.

Holding and chain of reasoning

ABA is a licensed health profession in Michigan, licensed on its own track within Article 15 (axis one). Michigan compels the professional form only for a closed list of learned professions, dentists, osteopathic physicians, physicians, surgeons, clergy, and attorneys, and behavior analysts are not on it, so the professional form is optional and a standard LLC that a non-licensee may own governs (axes two, three, and four). The all-licensed-members rule binds only an elected professional LLC, and the statute lets a non-learned profession incorporate ordinarily. The real constraint sits on the money side, the Public Health Code referral-fee ground and the criminal kickback statute, rather than on ownership (axis five). Therefore a non-licensee may own a standard Michigan LLC that delivers ABA through licensed behavior analysts.


Outlook: how this verdict could change

Likelihood of change: Low. Michigan is not among the 2025 wave states and no ABA-specific proposal has been identified. The verdict would change only if behavior analysts were added to Michigan's enumerated learned-profession list (MCL 450.1109), or a new corporate-practice or ownership bill were enacted.

What to watch. any bill amending the learned-profession list, which currently omits behavior analysts.

Disruption if it changes: Moderate. Adding behavior analysts to the learned-profession list would make the professional form licensee-only, but an ordinary LLC would likely still serve; a full mandate to use the professional form would force re-formation and recredentialing.


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, so the learned-profession and fee-splitting questions in particular often turn on interpretation rather than the words on the page. The open question of whether a non-learned health profession could still be steered toward the professional form, and the practical pull of Medicaid rendering-provider and payor credentialing rules, both mean the entity decision should be confirmed for the specific practice. Use this page to locate the operative provisions and to speak from the source, then confirm the current text against the official code and engage qualified Michigan counsel before acting. The entity verdict is also only one layer of a Michigan practice's obligations, alongside the facility and records rules and the Michigan Medicaid enrollment that discloses the entity and its owners. Nothing here is legal, tax, or financial advice.

Confirm current requirements directly

The provisions quoted here change and are interpreted by agencies and courts. The official Michigan code and qualified Michigan counsel are the authoritative sources. Neither this page nor any secondary source should be relied on in place of direct verification and professional advice.

Last updated June 2026. A statute-level reference for the Michigan ABA professional-entity and ownership question, with operative language quoted verbatim from public statutory sources. Statutes change and are interpreted by agencies and courts. Nothing here is legal, tax, or financial advice. Confirm against the official code and consult qualified counsel before relying on this information.