Who must be licensed to practice ABA in Hawaii, and how do you get credentialed?

Is ABA licensed in Hawaii, and under which agency

Yes. Hawaii licenses behavior analysts under HRS chapter 465D, enacted as Act 199, Session Laws of Hawaii 2015, with licensure beginning January 1, 2016, as confirmed by the state auditor's own account of the program's history (Hawaii State Auditor, Report No. 20-20, Dec. 2020). The chapter is administered by the Department of Commerce and Consumer Affairs, through its Professional and Vocational Licensing Division. The licensing requirement was originally scheduled to sunset on June 30, 2021, and the December 2020 auditor evaluation recommended continued regulation; the legislature then removed the sunset date and made the licensing requirement permanent. Secondary accounts cite the repealing measure as Act 80, Session Laws of Hawaii 2021, but this guide could not independently fetch that act's text, so confirm the exact citation with the department. The department's program remains active today, which independently confirms the chapter was not allowed to lapse.

Credential tiers: one licensed tier, confirmed

Hawaii licenses one tier: licensed behavior analyst. The department's own program page lists exactly one entry under "Behavior Analyst License Types": "Behavior Analyst" (cca.hawaii.gov, Behavior Analyst Program page). There is no separate licensed "assistant behavior analyst" credential. An individual who holds BACB's assistant-level certification, a Board Certified Assistant Behavior Analyst, is instead addressed through the exemptions in HRS section 465D-7(a): the state auditor's December 2020 sunset evaluation reproduces that exemption as covering "an individual who implements or designs applied behavior analysis services and possesses board certification as an assistant behavior analyst by the Behavior Analyst Certification Board and who practices in accordance with the most recent supervisory and ethical requirements adopted by the Behavior Analyst Certification Board under the direction of a licensed behavior analyst" (Hawaii State Auditor, Report No. 20-20, Dec. 2020, quoting HRS § 465D-7(a)(3)). A BCaBA practices under a licensed behavior analyst's direction as an exempt category, not as a second Hawaii license. Confirm with the department if this exemption has since changed.

The BACB foundation

Hawaii's license rests on the national credential. A license may be issued to an applicant who has passed the BACB examination and maintains active BACB certification as a board certified behavior analyst or board certified behavior analyst-doctoral. This guide found no reference to an alternate certifying entity such as QABA in Hawaii's statute or program materials. Hawaii does not restate the BACB's own degree, coursework, or fieldwork requirements; it requires current BACB certification, which is where those requirements live.

What it takes to get licensed

An applicant qualifies through one of two routes. The primary route is passage of the BACB examination and active BACB certification. The second route, licensure by endorsement, is available to an applicant who holds a current and unencumbered license in another state, provided the requirements in that state at the time the applicant was licensed were equivalent to or higher than Hawaii's. Processing an application takes approximately fifteen to twenty business days once it is complete, and an application is considered abandoned and destroyed if the process is not completed within one year of filing. A temporary license for military spouses during a period of active-duty service is also available, through its own application form.

Title protection, scope, and exemptions

Hawaii's exemptions provision, HRS section 465D-7(a), states that the chapter is not intended to restrict licensed or credentialed practitioners practicing within their own recognized scopes of practice, and lists categories exempt from the licensing requirement. This guide could not independently fetch the complete current exemptions list, but one part of it has changed recently and materially: Act 167, Session Laws of Hawaii 2023, effective July 3, 2023, amended section 465D-7(a) to remove the exemption for Medicaid home and community-based services waiver providers who design applied behavior analysis services, such as functional behavior assessments and positive behavior support plans, without meeting licensed behavior analyst or supervised-assistant requirements; to make permanent the exemption for those who only implement such services to waiver participants, including direct support workers, caregivers, and family members; and to expand the exemption for Registered Behavior Technicians to cover supervision by a licensed psychologist who meets the chapter's exemption, in addition to supervision by a licensed behavior analyst.

Supervision rules

This guide's sources did not describe a separate Hawaii-specific supervision framework beyond the exemption provisions discussed above, which condition several exempt categories on acting under the direction of a licensed behavior analyst or, after Act 167, in some cases a licensed psychologist. Registered Behavior Technicians remain responsible for ensuring their supervision also meets the BACB's own requirements, which Hawaii's 2023 amendment does not alter or replace.

Renewal, fees, and continuing education

A license is subject to renewal by December 31 of every odd-numbered year, regardless of issuance date. For the licensing period beginning January 1, 2026, renewal applications were accepted from November 3, 2025 through December 31, 2025, with renewal notices mailed roughly two months in advance. The current on-time renewal cost is $220 for active status and $12 for inactive status; a license placed on inactive status remains an option for a licensee who is not practicing. There is no continuing-education requirement for renewal. A license not renewed by December 31 becomes forfeited; a forfeited license may be restored within one year, at a restoration cost of $320 for active status and $112 for inactive status. This guide also found an older figure, from a 2015 department FAQ, describing initial licensing-period fees of $310 or $200 depending on where in the two-year cycle the license is issued; that figure predates the current renewal fee and may not reflect the present initial fee, so confirm the current initial application fee directly with the department.

Getting credentialed with payors

Licensure lets you practice; credentialing lets you bill, and they are separate. After licensure, a provider enrolls with Hawaii Medicaid and credentials with commercial plans, most of which draw provider data from CAQH. Credentialing verifies the license and history and is followed by periodic revalidation. The billing entity and its ownership are disclosed during enrollment, which is where licensing meets the entity and ownership questions covered elsewhere in this guide. What each payor covers and pays for ABA is a separate topic on the Medicaid and insurance page. A sale or expansion in Hawaii turns on more than licensing: the Hawaii sale and expansion guide covers the records and the covenant.

Hawaii-specific wrinkles

Three Hawaii features stand out. First, the chapter almost disappeared: it carried a June 30, 2021 sunset date from the start, and only a subsequent legislative act, following a supportive December 2020 state auditor evaluation, made the licensing requirement permanent; this guide could not independently fetch that 2021 act's text, so confirm its exact citation with the department. Second, the 2023 Medicaid-waiver exemption amendment is recent enough that anyone relying on an older description of HRS 465D-7 should confirm the current exemption text, particularly if the practice designs behavior plans for waiver participants rather than only implementing them. Third, Hawaii licenses one tier, not two: the department's program page names only "Behavior Analyst," and BACB's assistant-level certification is addressed as an exemption under HRS 465D-7(a)(3), not as a second state license.

How licensing connects to the rest of your compliance stack

Licensing is the credential the rest of the structure is built around:

• Entity and ownership. Hawaii's professional-corporation statute omits chapter 465D from its enumerated list, so the PLLC form is unavailable and an ordinary LLC governs. See the Hawaii entity page and the Hawaii ownership page.
• Medicaid and insurance. Licensure and credentialing are prerequisites to coverage; what is covered and paid is separate, and the 2023 waiver-exemption amendment is directly relevant to Medicaid I/DD Waiver providers. See Medicaid and insurance mandates.
• Facility and records. Supervision documentation carries into facility and HIPAA compliance. See facility licensure and HIPAA.

Becoming licensed and credentialed in Hawaii: the sequence

1. Obtain BACB certification. Pass the BACB examination and hold active certification as a BCBA or BCBA-D.
2. Apply to the Department of Commerce and Consumer Affairs. Submit the application, fee, and certification proof, or apply by endorsement with an unencumbered out-of-state license.
3. Track the one-year filing window. Complete the application within one year of filing or it is treated as abandoned.
4. Credential with payors. Enroll with Hawaii Medicaid and credential with commercial plans, typically via CAQH, then plan for revalidation.
5. Renew by December 31 of each odd-numbered year. No continuing education is required; pay the renewal fee before the deadline to avoid forfeiture.

Hawaii licensing variables at a glance

Frequently asked questions