Bill Text: IL SB0712 | 2025-2026 | 104th General Assembly | Enrolled

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Bill Title: Amends the Behavior Analyst Licensing Act. Adds an occupational therapist to the individuals that the Act does not prohibit from performing or advertising activities that are considered to be the practice of applied behavior analysis under the Act. Provides that any member, partner, shareholder, director, officer, holder of any other ownership interest, or agent of a business organization that provides behavior analysis services who makes clinical decisions regarding patient care without being licensed or exempt under the Act shall be deemed to have violated the provisions concerning unlicensed practice, violation, and civil penalty. Provides that, notwithstanding any other provision of the Act and any rules adopted under the Act, a public school, school district, charter school, or nonprofit organization that is exempt or qualified for exemption from federal income taxes under Section 501(c)(3) of the Internal Revenue Code may employ or contract with a licensed behavioral analyst regardless of whether each individual who owns, operates, or manages the public school, school district, charter school, or nonprofit organization holds a currently valid license issued under the Act. Provides that a public school, school district, charter school, or nonprofit organization that is exempt or qualified for exemption from federal income taxes under Section 501(c)(3) of the Internal Revenue Code may employ, contract with, or otherwise engage a licensed behavioral analyst to perform services within his or her scope of practice if the licensed behavioral analyst holds a currently valid license under the Act. Amends the Professional Service Corporation Act. Adds the practice of applied behavior analysis by persons licensed under the Behavior Analyst Licensing Act to the list of personal services that, when combined, constitute "related professions" and "related professional services". Amends the Professional Limited Liability Company Act. Adds the practice of applied behavior analysis by persons licensed under the Behavior Analyst Licensing Act to the list of professional services that may be combined under a single professional limited liability company. Effective immediately.

Sponsorship: Partisan Bill (Democrat 9)

Status: (Passed) 2026-07-24 - Public Act . . . . . . . . . 104-0618 [SB0712 Detail]

Download: Illinois-2025-SB0712-Enrolled.html

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AN ACT concerning regulation.
Be it enacted by the People of the State of Illinois,
represented in the General Assembly:
Section 5. The Behavior Analyst Licensing Act is amended
by changing Sections 20 and 70 and by adding Section 150.1 as
follows:
(225 ILCS 6/20)
(Section scheduled to be repealed on January 1, 2028)
Sec. 20. License required; exemptions.
(a) Beginning 10 months after the adoption of the rules
required under subsection (b) of Section 80, an individual
shall not engage in the practice of applied behavior analysis
unless licensed under this Act or covered by an exemption
under subsection (c).
(a-5) An individual licensed under this Act as an
assistant behavior analyst shall not engage in the practice of
applied behavior analysis unless supervised by a licensed
clinical psychologist or licensed behavior analyst.
(b) Beginning 10 months after the adoption of the rules
required under subsection (b) of Section 80, an individual
shall not use the title "licensed behavior analyst", "L.B.A.",
"licensed assistant behavior analyst", "L.A.B.A.", or similar
words or letters indicating the individual is licensed as a

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behavior analyst or assistant behavior analyst unless the
individual is actually licensed under this Act.
(c) This Act does not prohibit any of the following:
(1) Self-care by a patient or uncompensated care by a
friend or family member who does not represent or hold
oneself out to be a behavior analyst or assistant behavior
analyst.
(2) An individual from implementing a behavior
analytic treatment plan under the extended authority,
direction, and supervision of a licensed behavior analyst
or licensed assistant behavior analyst.
(3) A clinical psychologist, social worker,
psychiatric nurse, speech-language pathologist,
audiologist, professional counselor, clinical
professional counselor, clinical social worker,
occupational therapist, or marriage and family therapist
from performing or advertising activities that are
considered to be the practice of applied behavior analysis
under this Act if the activities are consistent with the
laws of this State, the individual's training, and any
code of ethics of the individual's respective professions,
so long as the individual does not use the titles provided
in subsection (b).
(4) An individual from performing activities that are
considered to be the practice of applied behavior analysis
under this Act if the activities are with nonhumans,

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including applied animal behaviorists and animal trainers.
The individual may use the title "behavior analyst" but
shall not represent oneself as a licensed behavior analyst
or licensed assistant behavior analyst unless the
individual holds a license issued by the State.
(5) An individual who provides general applied
behavior analysis services to organizations, so long as
the services are for the benefit of the organizations and
do not involve direct services to individuals. The
individual may use the title "behavior analyst" but may
not represent oneself as a licensed behavior analyst or
licensed assistant behavior analyst unless the individual
holds a license issued by the State.
(6) An individual who is a matriculated student at a
nationally accredited university approved in rules or a
postdoctoral fellow from performing activities that are
considered to be the practice of applied behavior analysis
under this Act if the activities are part of a defined
program of study, course, practicum, internship, or
postdoctoral fellowship, provided that the applied
behavior analysis activities are directly supervised by a
licensed behavior analyst under this Act or a licensed
clinical psychologist.
(7) An individual who is not licensed under this Act
from pursuing field experience in the practice of behavior
analysis if the experience is supervised by a licensed

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behavior analyst or a licensed psychologist.
(8) An individual with a learning behavior specialist
or school support personnel endorsement from the State
Board of Education, the school district in which the
school is located, or a special education joint agreement
serving the school district in which the school is located
from delivering behavior analytic services in a school
setting when employed by that school as long as those
services are defined in the scope of practice for that
endorsement and that person is not in any manner held out
to the public as a licensed behavior analyst or licensed
assistant behavior analyst.
(9) A qualified intellectual disabilities
professional, meeting the minimum federal education
requirements outlined in 42 CFR 483.430, who is performing
the duties required for individuals with intellectual or
developmental disabilities in programs and facilities
regulated by the federal Centers for Medicare and Medicaid
Services, the Department of Human Services, or the
Department of Public Health, so long as the individual
does not use the titles provided in subsection (b).
(10) A service provider, designated by the Department
of Human Services, from providing behavior intervention
and treatment, so long as the individual does not use the
titles provided in subsection (b).
(d) This Act does not apply to an individual who, on the

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effective date of this Act, is engaging in the practice of
applied behavior analysis under the medical assistance program
under the Illinois Public Aid Code while that individual is
seeking the education, training, and experience necessary to
obtain a license under this Act.
(e) No licensed behavior analyst or licensed assistant
behavior analyst shall engage in the practice of
speech-language pathology or the practice of audiology, as
defined in the Illinois Speech-Language Pathology and
Audiology Practice Act, unless licensed to do so under that
Act.
(Source: P.A. 102-953, eff. 5-27-22; 103-857, eff. 8-9-24.)
(225 ILCS 6/70)
(Section scheduled to be repealed on January 1, 2028)
Sec. 70. Unlicensed practice; violation; civil penalty.
(a) Any person who practices, offers to practice, attempts
to practice, or holds oneself out to practice as a licensed
behavior analyst or licensed assistant behavior analyst
without being licensed or exempt under this Act shall, in
addition to any other penalty provided by law, pay a civil
penalty to the Department in an amount not to exceed $10,000
for each offense, as determined by the Department. The civil
penalty shall be assessed by the Department after a hearing is
held in accordance with the provisions set forth in this Act
regarding the provision of a hearing for the discipline of a

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licensee.
(a-5) Any member, partner, shareholder, director, officer,
holder of any other ownership interest, or agent of a business
organization that provides behavior analysis services who
makes clinical decisions regarding patient care without being
licensed or exempt under this Act shall be deemed to have
violated this Section.
(b) The Department may investigate any actual, alleged, or
suspected unlicensed activity.
(c) The civil penalty shall be paid within 60 days after
the effective date of the order imposing the civil penalty.
The order shall constitute a final judgment and may be filed
and execution had thereon in the same manner as any judgment
from any court of record.
(Source: P.A. 102-953, eff. 5-27-22.)
(225 ILCS 6/150.1 new)
Sec. 150.1. Ownership exemption for certain schools and
nonprofit organizations. Notwithstanding any provision of this
Act and any rules adopted under this Act, a public school,
school district, charter school, or nonprofit organization
that is exempt or qualified for exemption from federal income
taxes under Section 501(c)(3) of the Internal Revenue Code may
employ or contract with a licensed behavioral analyst
regardless of whether each individual who owns, operates, or
manages the public school, school district, charter school, or

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nonprofit organization holds a currently valid license issued
under this Act. A public school, school district, charter
school, or nonprofit organization that is exempt or qualified
for exemption from federal income taxes under Section
501(c)(3) of the Internal Revenue Code may employ, contract
with, or otherwise engage a licensed behavioral analyst to
perform services within his or her scope of practice if the
licensed behavioral analyst holds a currently valid license
issued under this Act.
Section 10. The Professional Service Corporation Act is
amended by changing Section 3.6 as follows:
(805 ILCS 10/3.6) (from Ch. 32, par. 415-3.6)
Sec. 3.6. "Related professions" and "related professional
services" mean more than one personal service which requires
as a condition precedent to the rendering thereof the
obtaining of a license and which prior to October 1, 1973 could
not be performed by a corporation by reason of law; provided,
however, that these terms shall be restricted to:
(1) a combination of 2 or more of the following
personal services: (a) "architecture" as defined in
Section 5 of the Illinois Architecture Practice Act of
1989, (b) "professional engineering" as defined in Section
4 of the Professional Engineering Practice Act of 1989,
(c) "structural engineering" as defined in Section 5 of

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the Structural Engineering Practice Act of 1989, (d) "land
surveying" as defined in Section 2 of the Illinois
Professional Land Surveyor Act of 1989;
(2) a combination of the following personal services:
(a) the practice of medicine by persons licensed under the
Medical Practice Act of 1987, (b) the practice of podiatry
as defined in the Podiatric Medical Practice Act of 1987,
(c) the practice of dentistry as defined in the Illinois
Dental Practice Act, (d) the practice of optometry as
defined in the Illinois Optometric Practice Act of 1987;
(3) a combination of 2 or more of the following
personal services: (a) the practice of clinical psychology
by persons licensed under the Clinical Psychologist
Licensing Act, (b) the practice of social work or clinical
social work by persons licensed under the Clinical Social
Work and Social Work Practice Act, (c) the practice of
marriage and family therapy by persons licensed under the
Marriage and Family Therapy Licensing Act, (d) the
practice of professional counseling or clinical
professional counseling by persons licensed under the
Professional Counselor and Clinical Professional Counselor
Licensing and Practice Act, or (e) the practice of sex
offender evaluations by persons licensed under the Sex
Offender Evaluation and Treatment Provider Act; or
(4) a combination of 2 or more of the following
personal services: (a) the practice of acupuncture by

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persons licensed under the Acupuncture Practice Act, (b)
the practice of massage by persons licensed under the
Massage Therapy Practice Act, (c) the practice of
naprapathy by persons licensed under the Naprapathic
Practice Act, (d) the practice of occupational therapy by
persons licensed under the Illinois Occupational Therapy
Practice Act, (e) the practice of physical therapy by
persons licensed under the Illinois Physical Therapy Act,
or (f) the practice of speech-language therapy by persons
licensed under the Illinois Speech-Language Pathology and
Audiology Practice Act, or (g) the practice of applied
behavior analysis by persons licensed under the Behavior
Analyst Licensing Act.
(Source: P.A. 101-95, eff. 7-19-19; 102-20, eff. 1-1-22.)
Section 15. The Professional Limited Liability Company Act
is amended by changing Section 13 as follows:
(805 ILCS 185/13)
Sec. 13. Nature of business.
(a) A professional limited liability company may be formed
to provide a professional service or services licensed by the
Department except:
(1) the practice of dentistry unless all the members
and managers are licensed as dentists under the Illinois
Dental Practice Act;

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(2) the practice of medicine unless all the managers,
if any, are licensed to practice medicine under the
Medical Practice Act of 1987 and each member is either:
(A) licensed to practice medicine under the
Medical Practice Act of 1987;
(B) a registered medical corporation or
corporations organized pursuant to the Medical
Corporation Act;
(C) a professional corporation organized pursuant
to the Professional Service Corporation Act of
physicians licensed to practice under the Medical
Practice Act of 1987;
(D) a hospital or hospital affiliate as defined in
Section 10.8 of the Hospital Licensing Act; or
(E) a professional limited liability company that
satisfies the requirements of subparagraph (A), (B),
(C), or (D);
(3) the practice of real estate unless all the members
and managers, if any, that actively participate in the
real estate activities of the professional limited
liability company are licensed to practice as a managing
broker or broker pursuant to the Real Estate License Act
of 2000. All nonparticipating members or managers shall
submit affidavits of nonparticipation as required by the
Department and the Real Estate License Act of 2000;
(4) the practice of clinical psychology unless all the

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managers and members are licensed to practice as a
clinical psychologist under the Clinical Psychologist
Licensing Act;
(5) the practice of social work unless all the
managers and members are licensed to practice as a
clinical social worker or social worker under the Clinical
Social Work and Social Work Practice Act;
(6) the practice of marriage and family therapy unless
all the managers and members are licensed to practice as a
marriage and family therapist under the Marriage and
Family Therapy Licensing Act;
(7) the practice of professional counseling unless all
the managers and members are licensed to practice as a
clinical professional counselor or a professional
counselor under the Professional Counselor and Clinical
Professional Counselor Licensing and Practice Act;
(8) the practice of sex offender evaluation and
treatment unless all the managers and members are licensed
to practice as a sex offender evaluator or sex offender
treatment provider under the Sex Offender Evaluation and
Treatment Provider Act; or
(9) the practice of veterinary medicine unless all the
managers and members are licensed to practice as a
veterinarian under the Veterinary Medicine and Surgery
Practice Act of 2004.
(b) Notwithstanding any provision of this Section, any of

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the following professional services may be combined and
offered within a single professional limited liability company
provided that each professional service is offered only by
persons licensed to provide that professional service and all
managers and members are licensed in at least one of the
professional services offered by the professional limited
liability company:
(1) the practice of medicine by physicians licensed
under the Medical Practice Act of 1987, the practice of
podiatry by podiatric physicians licensed under the
Podiatric Medical Practice Act of 1987, the practice of
dentistry by dentists licensed under the Illinois Dental
Practice Act, and the practice of optometry by
optometrists licensed under the Illinois Optometric
Practice Act of 1987;
(2) the practice of clinical psychology by clinical
psychologists licensed under the Clinical Psychologist
Licensing Act, the practice of social work by clinical
social workers or social workers licensed under the
Clinical Social Work and Social Work Practice Act, the
practice of marriage and family counseling by marriage and
family therapists licensed under the Marriage and Family
Therapy Licensing Act, the practice of professional
counseling by professional counselors and clinical
professional counselors licensed under the Professional
Counselor and Clinical Professional Counselor Licensing

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and Practice Act, and the practice of sex offender
evaluation and treatment by sex offender evaluators and
sex offender treatment providers licensed under the Sex
Offender Evaluation and Treatment Provider Act;
(3) the practice of architecture by persons licensed
under the Illinois Architecture Practice Act of 1989, the
practice of professional engineering by persons licensed
under the Professional Engineering Practice Act of 1989,
the practice of structural engineering by persons licensed
under the Structural Engineering Practice Act of 1989, and
the practice of land surveying by persons licensed under
the Illinois Professional Land Surveyor Act of 1989; or
(4) the practice of acupuncture by persons licensed
under the Acupuncture Practice Act, the practice of
massage by persons licensed under the Massage Licensing
Act, the practice of naprapathy by persons licensed under
the Naprapathic Practice Act, the practice of occupational
therapy by persons licensed under the Illinois
Occupational Therapy Practice Act, the practice of
physical therapy by persons licensed under the Illinois
Physical Therapy Act, the practice of applied behavior
analysis by persons licensed under the Behavior Analyst
Licensing Act, and the practice of speech-language
pathology by persons licensed under the Illinois
Speech-Language Pathology and Audiology Practice Act.
(Source: P.A. 102-970, eff. 5-27-22.)

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Section 99. Effective date. This Act takes effect upon
becoming law.