Thank you for the opportunity to comment on the proposed regulation changes.

• There is a very big difference between ABA as provided by a someone with training, certification and licensing in this specific field and someone doing behavior therapy who has training in counseling for a wide range of issues. The Commonwealth of Virginia recognizes the expertise in ABA as provided by Board Certified Behavior Analysts and has licensed them to do this. To entrust this to providers with less knowledge and experience is to do a disservice to a very fragile population.
• ABA is typically provided within the home setting when that is where most of the individual's time is spent, but then expands out to the community where we hope that individual will be able to interact for the rest of his/her life. Occasionally we need to address some issues outside of the home in an environment which is more conducive to learning and then generalize that learning back to the home and community.
• ABA is also typically provided in a one-to-one setting as an individual is learning new skills, which are then generalized to a setting in which they can access other people. Some of the training should be in a group setting with the amount of support needed to be successful.