RBT Supervision Documentation: BACB Requirements and a Filled Monthly Log

RBTs must receive ongoing supervision for at least 5% of the hours they spend providing behavior-analytic services each calendar month, in at least two face-to-face, real-time contacts, one of them an observation with a client, according to the BACB RBT Handbook (updated 10/2026, pp. 16-17). Only a BCBA or BCaBA can supervise, and records are kept for at least 7 years.

This page is for the BCBA or BCaBA who keeps the supervision log, for RBTs checking their own month, and for RBT candidates studying supervision for the exam. It has the rules with handbook page numbers, the 5% math, a filled fictional monthly form, the log errors that break the handbook rules, and how supervision differs from 97155 billing when the 2027 CPT codes start. More documentation guides are in ABA Session Notes & Tools.

Rules checked against the RBT Handbook updated 10/2026, as of October 29, 2026. That edition announces no change to supervision for 2027; the 2027 change for RBTs is recertification every 2 years with 12 professional development units (see our RBT renewal guide).

What are the BACB RBT supervision requirements?

The BACB RBT supervision requirements are a monthly minimum (5% of service hours), a structure (two real-time contacts, one observation, one individual), a qualified supervisor on record, and records kept for 7 years. All page numbers below refer to the RBT Handbook updated 10/2026.

The handbook calls this ongoing supervision: it lasts as long as you practice as an RBT, not just your first months. Our free Praxis Learn lesson on working under ongoing supervision (RBT F.3) covers the same rules in exam form.

How much supervision does an RBT need each month?

An RBT needs supervision for at least 5% of the hours they provided behavior-analytic services in that calendar month, so the target is set by the hours actually worked, not by a weekly schedule. Multiply the month’s service hours by 0.05:

Three rules change the arithmetic:

• Each month stands alone. Extra supervision in March does not cover a short April; the handbook sets the minimum “each calendar month” (p. 16).
• Each employer stands alone. An RBT at two organizations meets 5%, two contacts and an observation at both. The handbook’s own example: you “cannot have 3% supervision at organization A and 2% supervision at organization B” (p. 19).
• No services, no supervision. In a month when you provide no behavior-analytic services, monthly supervision is not required, but the other maintenance requirements still apply (p. 21).

Example: in March an RBT works 84 hours at Clinic A and 36 hours at Clinic B. Clinic A’s supervisors must provide at least 4.2 hours (84 × 0.05) and Clinic B’s at least 1.8 hours (36 × 0.05), each with two real-time contacts (at least one individual) and an observation. Six hours from Clinic A alone does not meet Clinic B’s requirement.

Hours change mid-month, so track them weekly. The BACB’s Supervision Checklist for RBTs suggests exactly this: a system that tracks your weekly service hours “to determine whether I need additional supervision.”

What counts as a supervision contact?

A supervision contact counts when the supervisor and RBT interact face to face in real time, in person or by live video, about the RBT’s work with clients. The handbook (p. 17) sets the limits:

• Counts: in-person meetings and observations; live video-conferencing or web-camera observation, if it complies with applicable laws.
• Does not count: phone calls and email.
• May not count: “video monitoring on its own, without real-time interaction or feedback.”
• Observation: at least one contact each month includes direct observation of you providing services. The BACB encourages more observation than the minimum.
• Group: one contact may be a small-group meeting of 2-10 RBTs. If non-RBTs attend, their participation should be limited so the RBTs interact more.
• Not professional development: supervision must be client focused, and one event cannot count toward both supervision and professional development.

Our telehealth guide covers how to document live-video supervision, and direct vs indirect supervision documentation explains which parts of a month need the client present.

Who can supervise an RBT?

Only a BCBA or BCaBA can be an RBT Supervisor, and only a BCBA can be an RBT Requirements Coordinator, according to the RBT Handbook (p. 19). The handbook lists no other credential, so a lead RBT, teacher or office manager cannot supervise. Every supervisor or coordinator must:

1. Complete training based on the Supervisor Training Curriculum Outline (2.0) and upload it to their BACB portal account before supervising (p. 19). The BACB’s RBT checklist describes it as an 8-hour supervision training.
2. Not be related to, subordinate to, employed by, or in a multiple relationship with the RBT (p. 19).
3. Be on record. With no Requirements Coordinator, every RBT Supervisor lists the RBT as a supervisee in their BACB portal account; with a coordinator, only the coordinator must (and may add the supervisors). Without a supervisor or coordinator on record, the RBT cannot practice, bill, or represent themselves as an RBT (pp. 19-20).
4. Have enough client-specific knowledge to direct the RBT’s work: the supervisor and RBT should work for the same organization, or the supervisor should have a contract with the client (p. 20).
5. Cover every client. Having a supervisor for three of your clients but not the fourth is not allowed (p. 20).

The handbook allows two structures (pp. 17-19). In the RBT Supervisor structure, each supervisor is responsible for the services they supervise, and supervisors at one organization work together so all requirements are met. In the RBT Requirements Coordinator structure, the RBT’s Requirements Coordinator (a BCBA; an organization may have several, but each RBT has only one per organization) makes sure all supervisors are qualified and all requirements are met each month, keeps the BACB records current, and may also supervise; supervisors give the coordinator their supervision details. A qualified supervisor is one who meets all of these conditions, not just any BCBA in the building.

What are an RBT supervisor’s responsibilities?

An RBT supervisor is responsible for all services the RBT provides under their supervision and for keeping the supervision records (RBT Handbook pp. 19-21). Supervision itself is client focused and may include (p. 17): setting performance expectations; observation, behavioral skills training and performance feedback; modeling technical, professional and ethical behavior; building problem-solving and ethical decision-making; reviewing written materials such as session notes and data sheets; overseeing service delivery; and evaluating the effects of supervision. Our reading of a common training-quiz question: monitoring client progress belongs to overseeing and evaluating service delivery, while scheduling clients, billing audits and timeclock checks are not on the handbook’s list.

Key details to log for every supervision session

RBT supervision documentation must show the days and times you provided services, the dates and duration of supervision, the format (individual or group), the dates of direct observations, the supervisors’ names, proof of each supervisor’s relationship to the client, and extra records such as session notes if records conflict (RBT Handbook p. 21). Both the RBT and the supervisor or coordinator keep these records for at least 7 years, even after the supervisory relationship ends (p. 21).

For each contact, log:

1. Date, start and end time, and duration in minutes.
2. Format: individual or group (with the number of RBTs), and in person or live video.
3. Observation: yes or no, and a client code (not the client’s name) when yes.
4. Supervisor’s name and credential, and their relationship to the client (same organization or contract).
5. What happened: skills observed, feedback given, behavioral skills training, documents reviewed, next steps.

Two practices the BACB does not require but that help in an audit: a short signed or e-signed monthly summary from both of you, and copies kept outside your employer’s system, because both of you must keep the records for at least 7 years “even if the supervisory relationship has ended” (p. 21).

Filled RBT monthly supervision form (fictional example)

Fictional example. The RBT, supervisors, clinic and client codes are invented.

RBT: J.R. · Organization: Brightpath ABA · Month: October 2026 · Supervisors: A. Lee, BCBA (Requirements Coordinator); M. Ortiz, BCaBA · Both employed by Brightpath, which serves clients C-14 and C-22

Service hours (from the timesheet; daily start and stop times are in the attached export):

Supervision contacts:

Monthly summary:

The mid-month check is the part most logs skip. On October 18, J.R. had worked 55.5 hours (2.78 hours of supervision needed) and had 150 minutes (2.5 hours) logged, so A. Lee asked M. Ortiz to book the October 20 observation then rather than finding the gap on October 31. Blank version to copy:

To check a finished log the way an auditor would, use our RBT supervision audit checklist.

Common RBT supervision audit findings and fixes

The findings below are where a log most easily fails the handbook rules, in our reading; they are not BACB statistics. The BACB can audit current and former RBTs, supervisors and coordinators at any time (RBT Handbook p. 21).

What happens if an RBT misses the 5% supervision requirement?

An RBT who misses supervision should report it to the BACB, and an RBT found substantially noncompliant faces termination of certification or of eligibility to recertify, with no reapplication for six months and enhanced auditing after requalifying, according to the RBT Handbook (p. 21). A Notice of Alleged Violation may also be filed against the supervisor or coordinator.

If you find a shortfall:

1. Stop and check whether you can still meet the month’s minimum before it ends.
2. Report it to the BACB (see the handbook’s Self-Reporting section and our mandatory self-reporting guide, written for BCBAs).
3. Talk with your supervisor about how to meet the requirements from now on, find another supervisor, or apply for voluntary inactive status if you will not be practicing (p. 21).

The question comes up again at recertification: the application asks whether you met the supervision requirements, were not practicing, or did not meet them (p. 27).

Is RBT supervision billable? Supervision vs 97155 in 2027

Supervision of an RBT is generally not billable: the ABA Coding Coalition’s 2027 supplemental guidance (SG) (p. 31) says “supervision activities that do not involve delivery of services directly to patients are generally not reportable or billable to health plans using CPT codes,” though, it adds, some payers may allow them to be billed using HCPCS or other codes. In the supervision context, what a payer pays for is the BCBA’s work on the patient’s treatment: from 2027, mainly 97155 direction with the patient present or 97180 patient-specific technician training without the patient.

From January 1, 2027, 97155 is no longer dual-use. It covers a BCBA or other QHP directing a technician, with analysis, while the technician works face to face with the patient, so it is normally billed alongside a technician code (97148, 97149, 97153, 97154, 97159 or 97160). The ABA Coding Coalition notes one uncommon exception: a QHP directing another QHP who leads a 97158 group. A BCBA treating the patient with no technician bills new code 97173, and 97155 and 97173 are not billed concurrently.

As of October 29, 2026. Sources: ABA Coding Coalition 2027 guidance and the CMS CY 2027 proposed rule. CPT is a registered trademark of the AMA.

Our reading: the BACB handbook does not say that time billed as 97155 cannot also count as one of the RBT’s supervision contacts. When a BCBA directs an RBT during a 97155 session and gives real-time feedback, that time can meet the handbook’s conditions for a contact with observation. The two records still differ. The 97155 note describes the patient’s treatment and the analysis, and the supervision log records the RBT’s performance and feedback. Time spent only on the RBT’s general skills, with no link to the patient, belongs in the supervision log and is not 97155. Check each payer’s policy, because some limit when direction time can be billed. Our CPT 97155 guide covers the 97155 note, and the 97180 log covers training without the patient.

Can RBT supervision happen over telehealth?

Yes: supervision contacts, including the observation, may be conducted by web camera or video-conferencing instead of in person, as long as the contact is real time and complies with applicable laws, per the RBT Handbook (p. 17). In-person, on-site observation is preferred. Log the format as “live video” and keep the session within your organization’s approved, HIPAA-compliant platform.

How is RBT supervision different from BCBA fieldwork?

RBT supervision keeps a practicing RBT certified, while BCBA or BCaBA fieldwork is supervised experience that a trainee accrues to become eligible for the BCBA or BCaBA exam, under the BACB’s separate handbook and forms. Our recommendation: an RBT who is also accruing fieldwork keeps two separate records, one for each requirement. See our BCBA fieldwork documentation guide for the fieldwork side.

What to do next

• Supervisors: copy the column headings from the filled form into your log, add the weekly running total, and check each RBT’s month against the supervision audit checklist before the month closes.
• RBTs and trainees: supervision questions appear in the Ethics domain of the RBT exam. Read the RBT F.3 lesson on ongoing supervision and the F.4 lesson on effective supervision practices, then try the free RBT Ethics practice questions. Our RBT exam study guide has the full plan.

Sources

• Behavior Analyst Certification Board. Registered Behavior Technician Handbook, updated 10/2026 (pp. 16-21, 27).
• Behavior Analyst Certification Board. Supervision Checklist for RBTs, version 7/2025.
• ABA Coding Coalition. 2027 CPT supplemental guidance, October 2026 (pp. 12-13, 31).
• Centers for Medicare & Medicaid Services. CY 2027 Physician Fee Schedule proposed rule, July 16, 2026.

This page explains BACB requirements and billing rules; it is not legal advice. Check the current RBT Handbook and each payer’s policy. CPT is a registered trademark of the American Medical Association.

Reviewed by the Praxis Notes team on October 29, 2026.