Global Institute for Behavior Practitioners and Examiners
Michael Moates, MA, QBA, IBA, LBA, QMHP-T/R
14 March 2022
SUBJECT: MEMORANDA FOR VIRGINIA BOARD OF MEDICINE ON BEHAVIOR ANALYSIS LICENSING
To whom it may concern:
My name is Michael Moates, and I am the individual who wrote to the Board of Medicine to request the rule change that is currently open for comment. I am also the founder of the non-profit organization the Foundation for Transformation DBA Global Institute for Behavior Practitioners and Examiners. I am writing you today to share my comments regarding the requested change in 18VAC85-150-50, and 18VAC85-150-60. To start, the rule is illegal and contrary to the statute. According to 54.1-2957.16, the Board of Medicine “SHALL INCLUDE” the following language “Documentation that the applicant is currently certified as a Board-Certified Behavior Analyst by the Behavior Analyst Certification Board or any other entity that is nationally accredited to certify practitioners of behavior analysis;” The boards current rules to not include this language as the statute legally requires. That means that the Board of Medicines rules is illegal under the statute. The same is true for the Board of Medicine Assistant Behavior Analyst rule.
But let’s move on from the fact that the rule is illegal and talk about the problems not allowing other organizations who are accredited creates for the practice of behavior analysis:
Number of Behavior Analysts Certified by the BACB in the United States of America:
Sports/Fitness – 39 |
Organizational - 365 |
Education - 6701 |
Public Policy – 49 |
Research - 19 |
Corrections - 49 |
Supervision - 177 |
Intellectual Disability - 2734 |
Child Welfare - 99 |
Parent Training - 493 |
Higher Education - 642 |
Pediatrics - 458 |
Clinical Behavior Analysis - 1762 |
Gerontology - 62 |
Addiction – BACB Doesn’t Track |
Animal - BACB Doesn’t Track |
Prevention Behavior - BACB Doesn’t Track |
Life Coaching - BACB Doesn’t Track |
Non-Profit - BACB Doesn’t Track |
LGBTQ - BACB Doesn’t Track |
Learning Disability - BACB Doesn’t Track |
Sexual Behavior - BACB Doesn’t Track |
Environment Preserv - BACB Doesn’t Track |
Security Analysis - BACB Doesn’t Track |
https://manuals.health.mil/pages/DisplayManualHtmlFile/2020-11-25/AsOf/TO15/C18S4.html
It is with this consideration I ask you to approve my request that individuals certified as behavior analysts by NCCA or ANSI be allowed to use that certification to apply for licensure.
Very Respectfully,
Michael Moates, MA, QBA, IBA, LBA, QMHP-T/R
Virginia Licensed Behavior Analyst
Adjunct College Professor
Doctor of Education Candidate
Student Health Advisory Committee
Senior Member, Civil Air Patrol, United States Air Force Auxiliary
Certified Accreditation Evaluator, Distance Education Accreditation Commission