Pennsylvania IBHS · Reference Portal
Two rulebooks — the state's and the BACB's — land on the same staff roster and confuse everyone. Here is who needs what, by role, with the regulation cited on every line.
Who needs what, in three steps
The state’s clock and the BACB’s clock land on the same roster. Start here, then open the door that matches the person in front of you.
Every person on the roster is a BHT, BHT-ABA, behavior consultant, mobile therapist, or clinical director. The hours follow the role, not the job title on the offer letter.
New BHT staff: 30 hours before independent work, 24 more in the first six months, then 20 hours every year. The 40-hour RBT training is taken once. But OMHSAS treats certificates dated before 2026 as outdated, and staff should update to 3rd edition training within a year.
“Department-approved” is the regulation’s phrase, not a description of our catalog. Your agency decides what goes on its own plan under § 5240.13. We are a BACB ACE provider (#OP-14-2437).
The rules
Where a row below says “Department-approved”: those are § 5240.73’s words, not a description of our courses. Special Learning does not hold a Pennsylvania Department of Human Services approval. We are a BACB Authorized Continuing Education provider (ACE #OP-14-2437), which § 5240.83 accepts for ABA-services staff; your agency decides what counts against its own training plan under § 5240.13.
30 hours before working independently (8 required topics) + 24 hours within the first 6 months (11 topics). Then 20 hours annually.
§ 5240.73(c), (d), (e)
PA IBHS Initial 30-Hour Training for BHTs — $99 · Within-6-Months 24-Hour Training — $129
20 Department-approved hours annually, tied to the individual training plan your agency keeps under § 5240.13.
§ 5240.73(e)
Annual BHT 20-Hour Training — $99 · BHT 20-Hour for Mental Health Professionals — $99 · Interpersonal, Safety & Systems for BHTs — $129
Qualification route: one-time 40-hour training covering the RBT Task List (certificate names the responsible BCBA/BCaBA trainer): a certificate dated before 2026 should be updated to 3rd edition within a year (OMHSAS, April 2, 2026). Then 20 ABA-related hours annually; BACB-authorized (ACE) CE provider training accepted.
§ 5240.81(g)(5) · § 5240.83(d)
On top of state hours: 12 PDUs per 2-year cycle, in effect since January 1, 2026; the first deadline is two years after each RBT's own 2026 certification or recertification date, so in 2028. PDU content must be behavior-analytic.
BACB RBT Handbook, 06/2026
16 Department-approved hours annually, related to job functions.
§ 5240.73(b)
PA IBHS BC/MT Training — $99 · Yearly Training for Clinical Directors & Consultants — $129
16 hours annually — training from a BACB-authorized (ACE) CE provider accepted. BCBAs: note PA wants 16 each year, not 32 anywhere in the 2-year BACB window.
§ 5240.83(b)
Initial Training for Clinical Directors & Consultants — $99 · CE catalog (ACE OP-14-2437)
20 hours up front, then 20 hours annually.
§ 5240.83(c)
Agency assessment
Ten questions about your roster. One output: every role's initial and annual requirements, the BACB overlays, and your agency's total annual training load.
| Behavioral Health Technicians (BHT) | |
| …of whom are NEW (not yet practicing independently) | |
| BHT-ABA technicians | |
| …of whom are BACB-certified RBTs | |
| Behavior Consultants / Mobile Therapists | |
| Behavior analytic staff / BC-ABA (incl. BCBA/BCaBA) | |
| …of whom hold BCBA/BCaBA certification | |
| Assistant BC-ABA (not yet certified) |
Common questions
Not every year, but an older certificate should be updated. The regulation (55 Pa. Code § 5240.71(d)(5) and § 5240.81(g)(5)) asks for one 40-hour training covering the RBT Task List, with a certificate naming the BCBA or BCaBA trainer. OMHSAS's letter of April 2, 2026 treats certificates dated before January 1, 2026 as outdated, and says staff should update to 3rd edition training within one year. What recurs every year is the annual requirement — 20 Department-approved hours per year for BHT staff (§ 5240.73(e)).
Sometimes, and the answer differs by table. For ABA-services staff, the regulation itself accepts training from a BACB-authorized continuing education (ACE) provider toward the annual hours (§ 5240.83). For BHT staff on individual services, § 5240.73 requires Department-approved hours and states no ACE alternative in any subsection. PA DHS process guidance does list trainings offered by a BACB ACE provider among those requiring no Department review — but that guidance is not the regulation, Special Learning does not hold a Pennsylvania Department of Human Services approval, and your agency makes the call against its own training plan under § 5240.13.
Not in Pennsylvania. The BACB allows 32 CEUs anywhere in the 2-year cycle, but PA requires 16 hours each year (§ 5240.73(b), § 5240.83(b)). Front-loading or back-loading leaves one year short of the state requirement.
Since January 1, 2026, every RBT certified or recertified in 2026 or later must earn 12 hours of professional development units (PDUs) per 2-year recertification cycle — the first recurring education requirement RBTs have ever had. The first deadline is two years after each RBT's own 2026 (re)certification date, so in 2028. PDU content must be behavior-analytic, so most state-required topical hours do not count toward it.
No. An IBHS agency may accept documentation of completed initial or annual training from a previous agency (§ 5240.13(d)). Keep certificates on file and stop paying to retrain people.
Only from organizations Pennsylvania specifically names — for Child Protective Services Law training, providers such as the University of Pittsburgh's Child Welfare Resource program; for first aid, organizations such as the American Red Cross and American Heart Association. No other provider's version counts, including ours.
A short plain-English video walkthrough of these requirements, and an ask-anything assistant grounded in the regulation text — both in production. Questions now? Contact us and a human answers.
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