Dossier · Licensing & Credentialing · South Carolina
South Carolina still has no enacted behavior analyst license, as of October 2026
Latest development · Verified Oct 23, 2026
South Carolina Act 186 sets school-day rules for private ABA providers; it does not create a license
What changed
Nothing has changed in the law itself; this item exists because older descriptions of South Carolina ABA regulation, including an earlier version of this site's own South Carolina licensing guide, stated that the state actively licenses behavior analysts under Title 40, Chapter 75, with a December 31, 2026 grandfathering deadline for existing practitioners. That description is inaccurate. We fetched the current, official text of S.C. Code Title 40, Chapter 75 directly from the General Assembly's own code site. Chapter 75 licenses professional counselors, marriage and family therapists, addiction counselors, and psycho-educational specialists under a combined board; its text never uses the term behavior analyst, and the board named in the chapter has no behavior-analyst seat. A full-text search of the chapter for the root word behavior returns only generic uses already built into the existing counseling professions, naming addictive behavior inside the addiction-counselor definition and behavioral telehealth as an article heading, neither of which names or licenses a behavior analyst.
Two companion bills in the 2021-2022 General Assembly session, Senate Bill 630 and House Bill 3731, would have changed that by adding licensed behavior analysts and licensed assistant behavior analysts to Chapter 75's jurisdiction and renaming the board to include them. Neither passed. According to the General Assembly's own official bill-history pages, S. 630 was introduced and referred to the Senate Committee on Labor, Commerce and Industry on March 2, 2021, and the official history shows no recorded action after that referral. H. 3731 was introduced and referred to the House Committee on Medical, Military, Public and Municipal Affairs on January 27, 2021, picked up additional sponsors through May 4, 2021, and likewise shows no recorded action after that point. Neither bill was reported out of its committee, neither received a floor vote in either chamber, and neither was signed into law. Both died with the end of the 2021-2022 session. We found no other South Carolina statute that fills the gap: Title 40's general professions framework has no occurrences of the root word behavior in its text, and the only credential requirement we located anywhere touching ABA was inside a Department of Disabilities and Special Needs provider-enrollment form, an agency document rather than a Code of Laws statute.
Who this affects
Anyone practicing applied behavior analysis in South Carolina today, since the credential that actually governs practice is BACB certification, not a state license, and treating Chapter 75 or the never-enacted bills as current law would be a mistake with real consequences for how a practice documents its own compliance posture. Anyone relying on an older description of South Carolina law, whether from this site's own prior content, another secondary source, or general industry commentary repeating the 2021-2022 bills' provisions as if they were enacted, should treat those descriptions as describing proposals that did not become law, not the current Code. A multistate practice comparing South Carolina to licensed-state requirements should not budget time or cost for a South Carolina license application process, grandfathering window, or transition deadline, because none of those exist in the Code of Laws as of this writing.
What to do now
This is practical guidance, not legal advice. Treat BACB certification, SCDHHS Medicaid enrollment, and each commercial payor's own credentialing process as the operative requirements for practicing and billing in South Carolina, since no state license sits above them. If an internal compliance checklist, a credentialing vendor's state-requirement matrix, or any other secondary source lists a South Carolina behavior-analyst license, registration, or a December 31, 2026 deadline, correct that record against the current Code of Laws rather than assuming the secondary source is current. We found none in the Code of Laws as of October 2026; confirm directly with the South Carolina Department of Labor, Licensing and Regulation and with SCDHHS before relying on this as exhaustive, since a future General Assembly session could reintroduce similar legislation at any time. For the fuller South Carolina picture, including how BACB certification, Medicaid enrollment, and payor credentialing function together as the operative framework, see the South Carolina licensing guide, the South Carolina entity decision page, and the South Carolina PLLC and professional-entity page.
Key dates
- March 2, 2021S. 630 referred to the Senate Committee on Labor, Commerce and Industry. No further recorded action followed.
- January 27, 2021 to May 4, 2021H. 3731 introduced, referred to committee, and gained sponsors. No further recorded action followed after May 4, 2021.
- End of the 2021-2022 sessionboth bills died with the session's close, having never been reported out of committee, passed by either chamber, or signed into law.
- October 2026the date of this site's direct fetch and confirmation that S.C. Code Title 40, Chapter 75 still does not mention behavior analysts.
This item exists to correct a specific, recurring inaccuracy; it is not tracking an active legislative matter, since none currently exists. If a new bill is introduced in a future session, this item will be updated.
Last updated October 2026.
Timeline, newest first
2026-10-23Live
South Carolina Act 186 sets school-day rules for private ABA providers; it does not create a license
House Bill 3974 (Act No. 186 of 2026), signed May 18, 2026, governs private providers of applied behavior analysis therapy in public schools. As read in the April 20, 2026 text of the bill, a private provider must be licensed by South Carolina and in good standing or, where state licensure is unavailable, certified by a national organization, and may not be an employee of a school district or the State Department of Education.
Districts must consider a parent's request for school-day services case by case, and a request does not entitle a student to services in the school. The State Board of Education must finalize a model policy by January 6, 2027, and districts must adopt it, or their own policy meeting its minimums, by July 1, 2027. The act does not license behavior analysts.
Source: South Carolina General Assembly, H. 3974 (Act No. 186), Private Providers
If these licensing rules touch who can deliver, supervise, and bill in South Carolina, the payer and Medicaid rules advisory maps them to your operation.
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ABAWiser provides research, analysis, and compliance advisory services. We are not a law firm, we do not provide legal advice, and no engagement creates an attorney client relationship. Dossiers track developments as they occur and may be incomplete or updated as a story evolves. Confirm any statutory or regulatory point against the primary source before acting on it.