Let me start by saying that I think that if Dr. Hoch is going to post emails between himself and Executive Director Benincosa that he should publish all emails and give the full context. He posted a single email to fit his narrative without giving context.
But allow me to address something he/ Executive Director Benincosa stated:
Qualified Behavior Analyst
Qualified Applied Behavior Analysis Credentialing Board |
Board Certified Behavior Analyst
Behavior Analyst Certification Board |
Cost: Application $350 Exam: Free Coursework Evaluation: Free
Total $350 |
Cost: Application $245 Exam $125 Coursework Evaluation $100
Total is $370 - $470[1] |
Certification Countries: Certification is available globally
Fully translated exams, documents, and applications are provided to diverse cultures |
Certification Countries: Beginning in 2023
Certification is Limited to: US, Canada, Australia, and the United Kingdom
Does not provide translated exams/documents |
Education: Master’s degree or higher |
Education: Master’s degree or higher Doctorate – for BCBA-D Designation |
Recommendation from Supervisor to Be Certified |
No Such Requirement |
Completed Background Check |
No Such Requirement |
Coursework: 270 Hours in specific coursework
Areas: 20 Hours Autism Spectrum Disorder
20 Hours Legal Professional and Ethics
20 Hours Core Principals of Applied Behavior Analysis
30 Hours Antecedent Interventions
40 Hours Skill Acquisition
30 Hours Behavior Reduction Interventions
30 Hours Data Collection Analysis
45 Hours Assessment
20 Hours Training and Supervision |
Coursework: 315 Hours in specific coursework
Areas: 45 Hours of Ethics/Professionalism
90 Hours Philosophical Underpinnings; Concepts & Principles
45 Hours Measurement, Data Collection
45 Hours Assessment
60 Hours Behavior Intervention
30 Hours Personnel Supervision and Management
|
Field Work Experience: 1500 Clock Hours (5% oversight)
750 Hours Must Be in Supervision/Oversight Role
Supervision Conducted By: Qualified Behavior Analyst Board Certified Behavior Analyst Board Certified Behavior Analyst – Doctoral Licensed Behavior Analyst Other Licensed/Certified Professionals with Behavior Analysis in their Scope of Practice (Board Certified Psychologists, School Psychologists, Psychiatrists, Social Worker, Professional/Mental Health Counselors[2])
|
Field Work Experience: 2000 Clock Hours (5% oversight) 1500 Concentrated Clock Hours (10% oversight)
60% of Hours Must Be in “Unrestricted Activities”
Supervision Conducted By: Board Certified Behavior Analyst Board Certified Behavior Analyst – Doctoral Board Certified Psychologist American Board of Professional Psychology in Behavioral and Cognitive Psychology Verified Course Sequence Instructor |
Must Pass the Qualified Behavior Analyst Exam
3 Hours to Complete Exam 125 Questions 1.4 Minutes per question |
Must Pass the Board-Certified Behavior Analyst Exam
4 Hours to Complete Exam 185 Questions 1.2 Minutes per question |
Agreement to Follow Code of Ethics[3] |
Agreement to Follow Code of Ethics[4] |
Bi-Annual Renewal |
2 Year Renewal Period |
Renewal Requirements: 32 Continuing Education Units New Background Investigation
|
Renewal Requirements: 32 Continuing Education Units (4 in Ethics, 3 in Supervision) No Background Investigation |
Program Accreditation: American National Standards Institute[5] (Affiliated with the United States Department of Education) |
Program Accreditation: National Commission for Certifying Agencies (NCCA is Accredited by American National Standards Institute) |
Recognition: Association for Behavior Analysis International Department of Defense |
Recognition: Association for Behavior Analysis International Department of Defense |
[1] There has been discussion that the BACB is a non-profit and QABA is not. Let me clarify that the BACB charges more and makes more of a profit than QABA.
[2] Having a diverse group of supervisors is important. ABA is not just Autism, it is used for developmental disabilities, behavior modification, etc… This includes prisons, psychiatric hospitals, schools, rehabilitation, organizational change, animal behavior and more…
[3] https://qababoard.com/wp-content/uploads/Code-of-Ethics-03-25-21.pdf
[4] https://www.bacb.com/wp-content/uploads/2020/11/Ethics-Code-for-Behavior-Analysts-210902.pdf
[5] https://anabpd.ansi.org/Accreditation/FileServer.aspx?Dirtype%20=%20Attachment&Id=182217&File=QABA%20Certificate.pdf&type=cert
If Professor Hoch is going to comment it would be beneficial if he at least did some basic scholarly research. Also, various times through out his comments, he references on "becoming a QABA." This is not a credential and a basic reading of the website would tell you that. QABA is the organization. ABAT is the technician level. QASP-S is the Bachelor Level. QBA is the Masters level.
I intend to file a Freedom of Information Act request to get the emails between Mr. Hoch and Mrs. Benincosa with George Mason University. I would ask the board to do the same or take Mr. Hoch on his offer to review all the emails. Manipulating emails by only posting one part of them to get what you want is not productive and it does not give the board a full picture.
There is no threat to the commonwealth unless the board continues to allow the BACB's lack of diversity to be dictator. Mr. Hoch would benefit from less providers because more individuals would see him at his practice. Seen here: https://www.psychologytoday.com/us/therapists/theodore-a-hoch-reston-va/448748
It is also important to note that at George Mason University where Mr. Hoch claims to represent their certificate, the one that he claims is designated for BACB certification and therefor licensure is actually listed as a "15-credit non-licensure certificate." The university does not even recognize the course sequence as one that should lead to licensure. You can see that here directly in there catalog: https://catalog.gmu.edu/colleges-schools/education-human-development/school-education/applied-behavior-analysis-graduate-certificate/ and archived here: https://web.archive.org/web/20220122013237/https://catalog.gmu.edu/colleges-schools/education-human-development/school-education/applied-behavior-analysis-graduate-certificate/
I think it is important to note a few things as well:
His comments must be disregarded.
Further the statute leaves no interpretation. The language in the statute "shall" be included in the rules.
There are also many issues of litigation to consider here:
Reference:
Association for Behavior Analysis International. (n.d.). 2021–2022 Individual Membership Application. Retrieved March 17, 2022, from https://www.abainternational.org/media/188058/abaimembershipform_2022.pdf
BCaBA Handbook. (2021). Behavior Analyst Certification Board. Retrieved March 10, 2022, from https://www.bacb.com/wp-content/uploads/2022/01/BCBAHandbook_220110.pdf
Behavior Analyst Certification Board. (2022a). BACB Newsletter - March 2022. BACB Newsletter March 2022. Retrieved March 17, 2022, from https://www.bacb.com/wp-content/uploads/2022/03/BACB_March2022_Newsletter-220316.pdf
Behavior Analyst Certification Board. (2022b, January). BOARD CERTIFIED BEHAVIOR ANALYST® HANDBOOK. BACB. Retrieved March 17, 2022, from https://www.bacb.com/wp-content/uploads/2022/01/BCBAHandbook_220110.pdf
Behavior Analyst Certification Board. (2022c, January). REGISTERED BEHAVIOR TECHNICIAN® HANDBOOK. BACB. Retrieved March 17, 2022, from https://www.bacb.com/wp-content/uploads/2022/01/RBTHandbook_220112.pdf
Behavior Analyst Certification Board. (2022d, January 28). BACB CERTIFICANT DATA. Retrieved March 17, 2022, from https://www.bacb.com/bacb-certificant-data/
Behavioral Intervention Certification Council. (2022). REGISTRY. Retrieved March 17, 2022, from https://behavioralcertification.org/search-registry/
Benincosa, H. (2020a, March 18). Become an Approved Continuing Education Provider. QABA. Retrieved March 17, 2022, from https://qababoard.com/become-an-approved-continuing-education-provider/
Benincosa, H. (2020b, July 21). Guidelines For ABAT, QASP, QBA Coursework Providers. QABA. Retrieved March 17, 2022, from https://qababoard.com/guidelines-for-abat-or-qasp-coursework-providers/
Benincosa, H. (2022, January 10). Qualified Behavior Analyst Scope. QABA. Retrieved March 17, 2022, from https://qababoard.com/qualified-behavior-analyst-scope/
BICC. (n.d.). BCAP. Retrieved March 17, 2022, from https://behavioralcertification.org/guide-to-bcap-registration/
Council for Higher Education Accreditation. (2022). Academy of Hair Design. Retrieved March 17, 2022, from https://www.chea.org/academy-hair-design
George Mason University. (2021). Applied Behavior Analysis Graduate Certificate. Catalog. Retrieved March 17, 2022, from https://catalog.gmu.edu/colleges-schools/education-human-development/school-education/applied-behavior-analysis-graduate-certificate/
Hoch, T. A. (n.d.-a). Theodore A Hoch. Psychology Today. Retrieved March 17, 2022, from https://www.psychologytoday.com/us/therapists/theodore-a-hoch-reston-va/448748
Hoch, T. A. (n.d.-b). THEODORE ANDREW HOCH Vita. George Mason University. Retrieved March 17, 2022, from https://cehd.gmu.edu/assets/files/cv/230.pdf
Laws & Regs. (2022). Virginia Board of Counseling. https://www.dhp.virginia.gov/counseling/counseling_laws_regs.htm
Laws & Regulations. (2022). Virginia Board of Psychology. https://www.dhp.virginia.gov/psychology/psychology_laws_regs.htm
Membership Application. (n.d.). Association for Behavior Analysis International. Retrieved March 10, 2022, from https://www.abainternational.org/media/188058/abaimembershipform_2022.pdf
TRICARE Operations Manual 6010.59-M, April 1, 2015. (2021). Department Of Defense (DoD) Comprehensive Autism Care Demonstration (ACD). Retrieved March 17, 2022, from https://manuals.health.mil/pages/DisplayManualHtmlFile/2021-03-26/AsOf/TO15/C18S4.html