The Arc of Northern Virginia is a local chapter of the largest non-profit organization supporting thousands of people with intellectual and developmental disabilities (ID/DD) and their families.  Our service area includes the Cities of Alexandria, Fairfax, and Falls Church; and Arlington and Fairfax Counties.

The Arc of Northern Virginia is strongly in support of the proposed regulation change to 12 VAC35-115(B) that would add licensed behavioral analysists to the group of professionals allowed to conduct assessments of behaviors and situations where behaviors occur, prior to allowing the use of restrictive options that can only be used to limit immediate danger to the individual and others, including restraints. 

BCBAs are some of the most qualified professional to make such assessments and suggest any and all positive behavioral supports and alternatives to restrictive options.  Their insight is invaluable.

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In reference to the amended definition for the Independent Review Committee (IRC), will the Behavior Management Committee (BMC) offered in Northern Virginia suffice as the IRC? Also, are there plans to replicate BMC throughout the state to support providers who do not have the ability to have an IRC internally?

Thank you for amending 12VAC35-115-105 to allow a licensed behavior analyst to conduct assessments, this is very helpful!

I am the President/CEO of Community Residences (CR).  CR is a non-profit human service agency providing services and supports to over 1,000 Virginians.  I am commenting on behalf of CR.  CR fully endorses and supports the proposed revised regulations to include BCBA's in the list of professionals identified to conduct behavioral assessments.