Licensed Behavior Analysts respectfully ask to be added to this list pursuant to HB762

"Licensed mental health professional (LMHP)" means a physician, licensed clinical psychologist, licensed professional counselor, licensed clinical social worker, licensed substance abuse treatment practitioner, licensed marriage and family therapist, licensed behavior analyst, or certified psychiatric clinical nurse specialist.

We feel it is important to add the exemptions for behavior analysis in this paragraph:

"Provider" means any person, entity, or organization, excluding an agency of the federal government by whatever name or designation, that delivers (i) services to individuals with mental illness, mental retardation (intellectual disability) developmental disabilities, or substance abuse (substance use disorders), or (ii) services to individuals who receive day support, inhome support, or crisis stabilization services funded through the IFDDS Waiver, or (iii) residential services for individuals with brain injury. The person, entity, or organization shall include a hospital as defined in § 32.1-123 of the Code of Virginia, community services board, behavioral health authority, private provider, and any other similar or related person, entity, or organization. It shall not include any individual practitioner who holds a license issued by a health regulatory board of the Department of Health Professions or who is exempt from licensing pursuant to §§ 54.1-2901, 54.1-3001, 54.1-3501, 54.1-3601, 54.1-3701, and 54.1-2957.17 of the Code of Virginia. 

In addition, we believe that in all of the sections that reference behavior plans and assessments, it should indicate that they are only to be performed/created by licensed professionals acting within their scope of practice.

Thank you for the opportunity to comment.