2 comments
The Advisory Board admitted the current text does not comply with the statute. It should be amended to comply with the law or it would be unlawful.
We, the Public Policy Committee of the Virginia Association for Behavior Analysis, are of the opinion that the Regulations Governing the Practice of Behavior Analysis should be amended. First, they should more similarly conform to other professions under the Board of Medicine. Second, to protect consumer safety, they should clarify the qualifications of organizations who can nationally certify someone who is to become licensed as follows. This is to best protect the consumer of these services.
Certifications and other credentials should be accepted as evidence of qualification for licensure to practice behavior analysis in this state only if they are issued by a non-profit credentialing organization that has all of the following features and safeguards:
Third, the regulations must address the time gap between certification and licensure and allow for practice under supervision while certificants are waiting for the paperwork to be completed. Finally, it is necessary to add that licensees must maintain certification in order to renew their license, similar to other professions.
We thank you for your time and dedication to the safety of consumers who receive services provided by licensed behavior analysts and licensed assistant behavior analysts.