Until 2026, Colorado did not license ABA providers. Behavior analysts could hold a national certification, but the state itself had no license for them or for the clinics where they work. That changed on June 3, 2026, when Governor Jared Polis signed HB26-1425.
Here is what the law does, why it passed when it did and what families can ask providers now.
What HB26-1425 requires
According to the Governor’s joint release on the bill:
- ABA providers must apply for professional licensure.
- Providers and staff need fingerprint-based background checks for both professional and facility licenses.
- The law sets up licensing for ABA facilities, the clinics and centers where therapy happens.
- Clinics facing a negative licensing action must notify the families they serve and give the state a list of those families.
The release did not give an implementation timeline or name the agency that will run licensing. Those details usually arrive through rulemaking after a bill is signed, so expect more information from the state over the coming months.
Why it passed now
The law followed a hard year for Medicaid ABA in Colorado.
In February 2026, the U.S. Department of Health and Human Services Inspector General released an audit of Colorado’s Medicaid ABA payments (report A-09-24-02004). It found that Colorado made at least $77.8 million in improper fee-for-service payments for children’s ABA in 2022 and 2023. Every one of the 100 sampled cases had at least one improper or potentially improper claim. The problems centered on session documentation, what counted as billable time, provider credentialing and checks on diagnostic evaluations and referrals.
The audit recommended that the federal Centers for Medicare & Medicaid Services recover $42.6 million in federal funds, issue more guidance to ABA facilities and review ABA payments regularly. Colorado agreed with three recommendations, partly agreed with one and disagreed with one.
At the same time, the state was trying to control Medicaid spending. The Governor’s 2026–27 budget proposal included cuts to Medicaid reimbursement for pediatric behavioral therapy, and in September 2025 a group of ABA providers and the Colorado Association for Behavior Analysis sued the state over those cuts.
A license gives the state a way to set standards for ABA providers and to act when a clinic falls short.
What it means for families
The law doesn’t change how therapy itself works. As it takes effect, you should see:
- Clinics that have applied for, or hold, a Colorado ABA license
- Background checks on the staff who work with your child
- A notice from your clinic if it faces a negative licensing action
If a clinic loses its license or has one restricted, the law requires it to tell enrolled families, which gives you time to arrange another provider instead of learning about a closure at the door.
Credentials you can check today
Licensing is new, but national certification has existed for years. The Behavior Analyst Certification Board certifies Board Certified Behavior Analysts (BCBAs), who design and supervise ABA programs, and Registered Behavior Technicians (RBTs), who deliver most one-on-one sessions. The BACB website has a public registry where you can look up a certificant by name.
Ask for the name of the BCBA who will supervise your child, then look them up.
Questions to ask any Colorado ABA provider
- Have you applied for your Colorado ABA license under HB26-1425?
- Who is the BCBA on my child’s case, and are they BACB-certified?
- Are your technicians RBTs, and who supervises them?
- How do you document sessions and supervision?
- How will you tell us about changes to your license or services?
Our guide to choosing between in-home and center-based ABA has more questions by setting. If your child is on Medicaid, see how Health First Colorado covers ABA.
When you’re ready to compare providers, start with your city: Denver, Colorado Springs, Aurora, Arvada, Fort Collins or Grand Junction. You can also browse providers accepting Medicaid, in-home ABA or the full Colorado directory.