123 comments
The Qualified Applied Behavior Analysis Credentialing Board (QABA) has international accreditation through the American National Standards Institute (ANSI), the golden standard for accreditation.
I agree with the amended language to state that a "certifying body is an entity nationally accredited by ANSI or the NCCA". Many other states have this included in their language including New Jersey, Texas, and others. If you include the name and certifications of the BACB, then QABA and its certifications should be named too, to prevent a monopoly.
QABA certifications and exams have gone through psychometric processes after being created by subject matter experts. Annual analyses of these exams are performed by a psychometrician to confirm reliability and validity. A rigorous annual surveillance (audit) is performed by ANSI to confirm QABA continues to meet the standards for continued accreditation.
Greetings, I am the executive director of the non profit called the Autism Business Association that represents ABA providers nationally and we strongly support providers using accredited certifications with the BACB and QABA Board. National Accreditation is a fair and equally rigorous criteria which is recognized in most state licensing as the criteria. The licensing statutes are for NCCA and ANSI accredited ABA certifications.
We support the state measure that is considering adding the QABA for their state license.
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
I support the state measure that is considering adding the QABA for their state license.
Greetings, My name is Dr. Rosa Patterson and I am a Qualified Behavior Analyst certified with the QABA. I am licensed across states and would support and encourage the addition of the QABA to licensure in the state of Virginia. In doing so would allow individuals the option to pursue licensure with the state of Virginia who are certified with the QABA and increase access to care for those in need of our behavioral services.
I'd like to encourage support for licensure for QABA.
Including licensure for QABA will help countless military families with behavioral health needs, and will prevent a monopoly for many behavioral services.
Amending the verbiage for behavior analysis licensure to include "nationally accredited certifying body" is important to consumer. With national shortages and wait list of providers across the country, allowing more than one board to certify is critical to ensure care is provided to those that need ABA.
Despite the rising prevalence of ASD (estimates at 1%> currently), there are still too few qualified providers, too few institutions providing the necessary course work, and too few credentialing entities to keep up with the exploding needs. Eliminating BACB's monopoly would open the practice to up to more qualified applicants with more diverse educational and professional experiences. We need to continue to hold practitioners to high standards of ethics, service delivery, and academic preparation, but we must debunk the myth that only institutions with "verified course sequences" know how to provide this preparation and that only the BACB knows how to assess applicants knowledge and proficiency for the practice. Just as there are multiple pathways to becoming credentialed in other professional fields, this should also hold true in behavior analytics. This would serve to expand exposure to the broader public about evidence-based practices, provide more qualified practitioners in the field, and more access to services, particularly to families in rural and remote communities.
Greetings,
My name is Heather Smith. I am in strong support of adding the QABA to Virginia's approved providers. In doing so would allow individuals the option to pursue licensure with the state of Virginia who are certified with the QABA and increase access to care for those in need of our behavioral services. We know the access to care is facing limitation challenges, and opening up the opportunity for additional Board Certified providers to license would greatly benefit those in need of essential medical services in behavioral health.
This is to increase access for practitioners and foster the diversity, equity, inclusion initiative.
I am a holder of Qualified Behavior Analysis Credential, practicing the Science of Applied Behavior Analysis in the State of New Jersey write to support having the QBA/ QASP-S/ABA-Tech recognized parallel to the BCBA/ BCaBA/RBT and therefore should either
[i] be included in the licensing law like BACB or
[ii] amendment be made to the language for licensing in the state of Virginia to remove the BACB language and include the following: "nationally accredited certifying body" so QBAs would be included.
The QABA Task lists are comparable with that of BACB, Practicum supervision experience hours requirements are equivalent to that of BACB. Also, the Task Lists include additional requirements and emphasis on Autism. Above all, QABA credentialing LIKE THAT OF BACB is approved by ANSI.
Please do not hesitate to reach me should you have any questions. Email: Home-linkinc@itc-aba
Yours sincerely,
Dr. Usifo Edward Asikhia, QBA.
Home Link International Inc.
629 E. Wood Street Suite 205
Vineland NJ 08360
I am a teacher at our alternative discipline center and the growing expansion of challenges/disabilities exceed the narrow limit of BACB certification. As it stands now, there are such long wait lists and behavior can be used in a variety of fields. The diversity of qualified practitioners will allow for fields outside of Autism to received beneficial services.
I support the language of accredited bodies of behavior analysts.
It is fundamentally wrong for a single, specific certification body to monopolize the ability to obtain a license or practice in Virginia. Other boards exist that have even higher standards (for example, the QABA board is accredited by ANSI), and should be allowed an even playing field. Simply allowing the BACB to be the only certification board represents a guild mentality that should not work its way into Virginia regulations.
I share with you an email exchange between Ms. Hollie Benincosa, Executive Director of the QABA Credentialing Board, and myself, from December 2021. I will gladly share the original emails with you at your request.
From Ms. Benincosa, on 30 December 2021:
Hello Theodore,
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
The QBA certification does not meet the standard for a Licensed Behavior Analyst in the state of Virginia. The current BCBA program standards--especially with regard to accruing supervised fieldwork--should be significantly more rigorous than they are in order to adequately protect consumers. A move to less stringent requirements is a step in the wrong direction when there is still work to be done to move practitioners in Virginia toward compassionate, thorough, and effective behavioral service delivery.
A public and non-profit credentialing organization is essential to the integrity of Behavior Analysis as a discipline. The Behavior Analyst Certification Board requires the highest standards of its certificants to both obtain and maintain certification. Licenses are issued for the protection of the clients, consumers, students, and stakeholders that we serve. Any modification to the standards of licensure would threaten that protection.
To be honest, this comment is not even worth the board's time. Mrs. Salzman doesn't attempt to address any concerns with adding the QBA to the boards requirements. She attempts to use shock words without any citations or facts to scare the Board of Medicine into not adding the QBA or following the LEGAL STATUTE. This is required by law and is not open for negotiation.
The QABA is a public board that is open to review by any public entity. It is accredited by ANSI who reviews its entire process for awarding certifications. It is so interesting that she claims the BCBA requires "high standards" that the QBA does not have when she does not attempt at all to lay these standards out for the board to review.
She says "Any modification to the standards of licensure would threaten that protection." Presumably she is referencing the BCBA standards. It is important to note that the standards are constantly changing. The BACB changed its standards as recently as January 2022 of this year. Further, let's talk about what is not healthy or safe for clients. The BACB has already announced its standards for certification for the year 2032 over 10 years from now. How is that healthy or safe when we don't know how the science of behavior analysis will evolve? That is an unsafe approach. The board should really consider wether this is the right approach. See: https://www.bacb.com/wp-content/uploads/2022/03/BACB_March2022_Newsletter-220316.pdf
"The BACB does not appear to have the money, staff, time, or legal authority to provide the necessary ethical oversight, especially with the literally thousands of members of the Association of Behavior Analysis International (ABAI) and/or BCBAs who practice both within the United States and around the world."
"To further complicate matters, the BCBA credential is not consistent with the generally accepted concept of board certification as recognized in the fields of medicine, psychology, and other human service professions."
See: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC2854065/
"One issue of regulatory concern is that often discussed in behavior analytic circles is that Behavior Analyst Certification Board (BACB) offers a national license. This is false. BACB is not licensing, nor could the BCBA ever be a national license for behavior analysts. Licensure falls under the states rights or powers. It is the prevue of each state to restrict trade within its borders. United States v. Lopez, 514 U.S. 549 (1995) held that the federal government only has the right to create laws that effect interstate commerce."
The federal government recognizes QABA and BICC as certification boards of behavior analysis.
See: https://www.abainternational.org/media/177713/luiselli.pdf
"The BAMLA defines who a professional behavior analyst is, categorizing the knowledge, skills, experiences, and abilities. In addition, it clarifies that a behavior analyst is a person who functions within a particular scope of practice. Finally, it helps to define the profession within a scope of practice that highlights the uniqueness of applied behavior analysis. The BAMLA further specifies the common commitments to expect from a behavior analyst in adherence to an ethical code and generally accepted behavior analytic positioning papers."
“However, for a number of logistical reasons, the BACB can only enforce adherence to the Professional Disciplinary Standards, (not adherence to the Guidelines for Responsible Conduct) and it relies heavily on information from local responsible sources in reviewing allegations against certificants” (BACB). Thus, BCBA will not investigate most forms of impairment, for they are ethical issues."
See: https://www.abainternational.org/media/177719/pritchard.pdf
Something else that MUST be noted is that there appears to be no research on the BACB certification requirements outside of those who are certified by the BACB. Thus, all research completed is biased and must be evaluated for its implicit bias.
Also, for the record, I personally reached out to the BACB to seek their help in making sure that the standards represent everyone not just BCBA's and was ignored.
There are many complaints with regards to customer service because the BACB is not interested in engaging with its community but rather they seek to dominate the industry.
References:
https://www.abainternational.org/media/177713/luiselli.pdf
https://www.abainternational.org/media/177719/pritchard.pdf
Dorsey, M. F., Weinberg, M., Zane, T., & Guidi, M. M. (2009). The case for licensure of applied behavior analysts. Behavior analysis in practice, 2(1), 53–58. https://doi.org/10.1007/BF03391738
I was directed to this form by my organization, and when reading through the comments I must say that this is akin to "insert unsavory word here" measuring contest. Personally, it isn't about which organization is handing out certifications, if singular or multiple - that's not important. What does matter is the consumers we serve, and for better or for worse, the BACB is leading the industry (at least in America), in terms of gold standard. That being the case, if QABA can demonstrate equivalent or superior standards, with evidence, then I see no qualms about also allowing them to practice within the state of Virginia. However, that's not to say that other boards won't try to do the same as I'm sure each of them purports a certain gold standard.
We do have a shortage of practitioners, and the consumers outnumber us a lot. Allowing other individuals with equivalent education/experience only expands our reach to our service population. I do not think however, this is something that can be voted on within a townhall meeting. There needs to be a review of processes and standards to ensure that QABA reaches the bar set forth by the industry.
To the individual who wrote about the lack of diversity within the BACB, I must say that I was not aware of this and I’m quite surprised by this. I’m even more curious to see the metrics of their exam and whether it is standardized from a stats perspective. I very curious about the representative sample they may have used. Then again, there several factors that may account for this discrepancy. But enough on that tangent.
Thanks -
Leozihno
I wholeheartedly wish the goals for licensure were focused on does each certification meet the need for the field. Unfortunately, the BACB and its lobbying arm the APBA, are constantly making derogatory remarks regarding other certification boards including QABA and BICC. These statements require a factual based response and sometimes to defend we must show why the other board would not be a good fit as a standalone board.
The goal should be a collaborative community by which various entities participate and work together. Until the BACB recognizes, like Virginia, that Psychologists, Psychiatrists, and other medical/mental health supervisors are qualified to provide supervision we are going to continue running into this problem.
The BACB is a closed off wall and they do not collaborate well with others.
I do disagree with anon when it comes to the statement about reviewing the standards of QABA or BICC for that matter. That has already been done. ANSI and NCCA have certified that QABA and BICC, respectively, meet the standards to issue certifications. They also meet various other administrative, structural, financial, etc... requirements.
To show anon about the diversity, here is the attachments from the BACB on BCBA's:
You are right, there is a need for more behavior analyst in the field to support the consumers. Just like there is a need for more teachers and doctors. However, the answer isn't to set the standards lower so anyone could do the job. Behavior Analysis is a complex field and we need our best and brightest contributing. If we set our standards lower, we may meet the goal of having more BA, but at what cost?
No one has provided a single shred of evidence that the standards are lower. You guys keep saying that. I say to you. Prove it. Cite empirical evidence. Cite research. Cite anything. We have shown that the BACB is not diverse and does not represent the population. We have done so through the BACB's own data. You guys come here and treat us like less. You dehumanize us and you provide no evidence. Show the board. Show the board what you are saying. If you can't, kindly sit down.
In addition, just because some standards may be different does not make them deficient. The BACB cannot create rules that will work across all 50 states. It is simply impossible. Every state has its own rules on scope of practice and supervising providers. The BACB has no way of adapting unless they create different rules for every state.
The board should disregard all comments that are not supported by evidence and research. These statements of less or deficient are not based in fact and frankly, the law is clear on what the requirements are. Period.
To the Board of Medicine:
Have you noticed how everyone who is commenting against this action is doing so anonymously? That should be a major RED flag.
Good Morning,
I am absolutely in favor of additional credentialing boards being added as long as they meet the following criteria: 1.) are a not for profit organization, 2.) are not disability specific (this is extremely important since we do serve a diverse population of individuals with ABA services throughout the state), and 3.) as long as it meets or exceeds the rigor of the BACB standards for certification.
I agree with certain aspects of the statement made by Crystal Peterson Barker. Here are some things I think are important to address.
First, I do not agree with the non-profit language. There are many for-profit institutions that provide valuable training, education, etc. I also believe this language is unclear. Is she referencing not-for-profit, non-profit, non-government-organization, state non-profit, or 501(c)3 exempt organizations? Many of the colleges that teach ABA programs that are approved by the ABAI and to that point they are not less, they are accredited and are used by the BACB themselves.
Second, I agree wholeheartedly with the language about not being disability specific. I think this is an area where the BACB fails. As previously stated, nearly 80% of those certified by the BACB are Autism Practitioners and that leaves very little room for others to get supervision in areas such as gambling, forensic analysis, sex addiction, ADHD, animal behavior, etc.
Finally, I wholeheartedly disagree with the last statement. The BACB is not the one who should determine what the standards are for behavior analysis. The federal government gave this job to the states in the US Constitution. Further, the BACB has many deficiencies as previously stated. These include lack of provider types, lack of diversity in gender and race, and lack of supervision by state-approved providers.
The state should determine the standard with input from various sources including consumers of behavior analysis, various certification organizations, educational entities, independent behavior analysts, and accreditation boards ANSI and NCCA.
I have read and considered the proposed changes described and the follow-up arguments posed, and I disagree with the conclusion that the path to licensure as a behavior analyst in Virginia should be modified in the manner the petition describes.
The key argument, as I understand it, is that the Board should expand the qualifying components required to become licensed in Virginia and that they should do this by expanding the certification requirements to include other credentialing bodies related to the field of behavior analysis.
The process of certification by the BACB as a BCBA/BCaBA and licensure as an LBA/LaBA in VA is rigorous, I agree. But I believe the best means to ensure that we can serve the communities and individuals (no matter the application of the science) with the highest quality of care and quality and mitigate the risk of harm is to ensure that these criteria remain rigorous.
If we, as representatives of the field on both sides of this discussion, feel that the current process towards licensure as a behavior analyst or assistant behavior analyst in Virginia should change but cannot agree which certification or credentialing body best defines the minimum criteria then, I recommend the Virginia Department of Health Professions – Board of Medicine launch a data-driven investigation and adopt the most rigorous standards and examination criteria to determine eligibility for licensure.
Thank you for considering my opinion,
C. DuVall
I think it is extremely important to act in an ethical way. Treating clients with dignity and respect is something that we should strive for. Children are not lab rats to be tested on, nor are they to be treated with disrespect based on disability.
I think it is important for the board to consider this when evaluating credentials it approves as alternatives.
According to Wikipedia, "The Judge Rotenberg Center (JRC, founded in 1971 as the Behavior Research Institute) is an institution in Canton, Massachusetts, United States, housing people with developmental disabilities, emotional disorders, and autistic-like behaviors. The center has been condemned for torture by the United Nations Special Rapporteur on Torture. The JRC is known for its use of the graduated electronic decelerator (GED), a device that administers electric shocks to residents through remote control. The device was designed by Matthew Israel, the institute's founder."
The JRC Continues to shock students as of today 28 March 2022.
The Board of Directors is made up of:
Josh Pritchard, Ph.D., BCBA-D
Jeffrey Sánchez
On Staff:
Nathan Blenkush, PhD, BCBA-D
It is important to note that the BACB is aware of these allegations and yet at least 3 board members remain and at least 1 on staff remain. I don't know about the Virginia Board of Medicine but I certainly don't condone torture and I think there should be alternatives in the field.
The Board needs to watch these:
https://www.youtube.com/watch?v=PUhPMNdnOW8
https://www.youtube.com/watch?v=XV5D2ZL0icM
This is not who we are. It is not who we want to be. It is a human rights violation. The BACB has taken no action against the individuals allowing this to happen. Alternatives must be put into place to protect the human rights issues being faced.
While conducting research to assist me with forming an opinion on this serious matter, I found that the QABA website did not address several important matters, yet those same items are easy to locate on the BACB website. Here are several examples:
The petitioner mentioned a concern with a lack of diversity. BACB certificant data and demographic data can be found at the following site:
https://www.bacb.com/bacb-certificant-data/
And yes, the field is dominated by white females, but I would like to point out that is also true for many care-taking type professions like education and nursing. This is an issue that needs to be addressed at a different level than this forum allows. I was not able to locate any demographic information on the QABA website - so how are we to know that they are any more diverse?
https://www.census.gov/newsroom/stories/certified-neruses-day.html
BACB information regarding ethics violations can be found here:
https://www.bacb.com/services/o.php?page=100180
It is important for the safety of those we support to have total transparency and accountability - the BACB makes it easy to access the ethics codes, any violations, and support with reporting violations. I could not locate ethics violations on the QABA website. There is a simple form for complaints found here:
https://qababoard.com/wp-content/uploads/QABA-Complaint-Form.pdf
However, there is nothing specific about ethics violations for those unfamiliar with the codes to assist them with reporting. The ethics codes are found in the packet for certification - but that made it very difficult to locate and again, how would a person unfamiliar with the website like a parent locate them and determine what information the need to determine if a violation had occurred?
To be clear, I am not against the QABA - I am only pointing out inconsistencies and misinformation in the claims made by the petitioner. This matter should not be taken lightly, and I hope more rigorous research is conducted before a final decision is made.
I was going to be done responding to people and just share information but since another anonymous user (again should be a red flag for the board) addressed me I would like to respond.
First the respondent has many inaccurate claims.
Again, trying to tell other organizations they have to be exactly like the BACB will lead to the same problems the BACB has. But moreover, had the respondent looked they would have found that QABA has an entire operation in Africa working with people of color to get certified as practitioners. Can be seen here: https://qababoard.com/pages/qaba-in-africa/
QABA has an international standards committee made up of both men and women of color. See here: https://qababoard.com/pages/qaba-international-standards-committee/
The website is offered in 13 different languages supporting people around the world. Same with the coursework and exams. They are offered across the world to diverse backgrounds including both men and women of color.
The represent: The United States, Spain, Philippines, Africa, Nigeria, Ecuador, South Korea, India, Brazil, Czech Republic, Peru, Japan, Pakistan, Egypt, UAE, Poland, Kenya, and Saudi Arabia.
The BACB is pulling out of the international market making it more White Americans. Don't allow yourself to be fooled by misinformation. The BACB is doing nothing to fix this problem and it is a problem for the board because if the law gets struck down because the BACB discriminates against people of color that will cause issues for the board. See: https://www.bacb.com/global-certification/.
Further, the BACB is not attempting to fix the problem at all. They are actually making it more likely that it will be worse by pulling out of the international market. Organizations that represent other mental health fields like the NBCC have organizations across the world like EBCC in Europe. See: https://europeanbcc.eu/. There are US Citizens abroad to including military families, international students, and member of the families of the State Department who should be able to get certified while their families are serving our country.
Anon really does not want to talk about ethics while the BACB allows individuals that it certifies to send electric shocks through children in an attempt to change their behavior.
Also, had anon even done basic research he would have found the following resources on the QABA website. See:
https://qababoard.com/code-of-ethics/
https://qababoard.com/wp-content/uploads/Code-of-Ethics-03-25-21.pdf
https://qababoard.com/wp-content/uploads/QABA-Complaint-Form.pdf
Ultimately the QABA Board does not have the jurisdiction to prosecute such claims and so that would be left to the states or the federal government. It does seem odd that someone on behalf of the BACB did not address my previous statement about the electric current the BACB allows to go through the bodies of kids.
Traditionally, the individual wanting to file a complaint would do so with the Board of Medicine as they have the appropriate jurisdiction. They have an entire form dedicated to it here: https://www.dhp.virginia.gov/PractitionerResources/Enforcement/
All anon had to do to locate that content was go to the about us section of the website. They took 30 seconds so they could write a negative review here.
Here are some other things to note:
ANSI accreditation - https://anabpd.ansi.org/Accreditation/FileServer.aspx?Dirtype%20=%20Attachment&Id=182217&File=QABA%20Certificate.pdf&type=cert
They had to meet these requirements: https://www.ihf-fih.org/resources/pdf/Conformity_assessment-General_requirements_for_bodies_operating_certification_of_persons.pdf
All in all. Another misguided individual attempting to hide behind the keyboard and attack other entities. It has no basis and Virginia law is clear. They clearly spend 30 seconds on the QABA website and then started writing.
The trend appears to continue, in that the petitioner finds it necessary to respond to reasonable comments and concerns by citing “inaccurate claims” and the like, however, fails to address the essence and substance of the comments themselves.
Here’s just one example:
Previously, the petitioner expressed concerns that BACB certificants, overall, lack diversity. A recent comment pointed out that QABA does not include measures of diversity on its own website for their certificant base. Instead of addressing this, the petitioner instead claimed that “QABA has an entire operation in Africa working with people of color to get certified as practitioners” and then shares a link. That may be so, but when you access the link, you land on a page of with very little information and no specifics. In addition, the “Learn More” button on the page merely links you back to the different certifications offered by QABA, nothing more.
The petitioner then argues that “QABA has an international standards committee made up of both men and women of color.” While that sounds great, how does that specifically address the fact that the petitioner continues to claim that BACB certificants, overall, lack diversity—all the while fails to produce QABA certificant data on diversity?
The bigger point here is this: Like several previous “responses,” it is difficult to make sense of what’s being presented because they are replete with logical fallacies. More often than not, we are seeing multiple attempts to invalidate a point by presenting nonsymmetrical data, strawman arguments, or information that is completely off-topic.
I am done replying to all of these anon users who are to scared to put their name to their posts. My hunch is they are all BACB certified. I am not going to engage in whataboutism. I brought up concerns and they are trying to turn the tables.
I can tell you that QABA or BICC does not condone shocking minor children for maladaptive behaviors like the BACB.
The BACB is not the first organization who has tried to write itself into the law.
A similar thing is happening right now in the Commonwealth Board of Counseling where the CACREP accreditation board is trying to make itself required for licensure and of 134 Comments not 1 supports the the restriction of one certification board.
Just like with the BACB, CACREP similarly thinks that it is better than everyone else and want to block off providers during the COVID 19 crisis.
See:
SEE THIS AMAZING PIECE OF WORK TO:
328 VOTE AGAINST ONE SINGLE BOARD.
https://townhall.virginia.gov/L./comments.cfm?stageid=7071&sort=change
Ref: Petition for Rulemaking: Certification for licensure as practitioners of behavior analysis: Regulations Governing the Practice of Behavior Analysis (18 VAC 85-150)
Dear Board Members,
As the Board considers the petition for certification for licensure as practitioners of behavior analysis, the ANSI National Accreditation Board (ANAB) would like to provide information relating to the international/national standard for assessing the competence of personnel certification bodies and the accompanying accreditation requirements.
The ANSI National Accreditation Board (ANAB) is an affiliate of the American National Standards Institute (ANSI) and the largest multi-disciplinary accreditation body in the western hemisphere, with more than 2,500 organizations accredited in approximately 80 countries. ANSI oversees the creation, promulgation, and use of thousands of norms and guidelines that directly affect businesses in nearly every sector: from acoustical devices to construction equipment, from roads and bridges to energy distribution, and healthcare. ANAB accredits personnel certification bodies based on the international standard ISO/IEC 17024: Conformity assessment- Requirements for bodies operating certification of persons. This standard is also adopted as an American National Standard. ANAB has accredited over 225 programs under this standard including several in the healthcare sector such as those offered by the American Board of Multiple Specialties in Podiatry, ASCP Board of Certification, Inteleos, Lymphology Association of North America, National Board of Certification in Occupational Therapy, ABRET Neurodiagnostic Credentialing and Accreditation, AONN Foundation for Learning, and Academy of Lactation Policy and Practice. A complete listing of all accredited programs can be found at https://anabpd.ansi.org/Accreditation/credentialing/personnel-certification/ALLdirectoryListing?menuID=2&prgID=201&statusID=4
The ANAB accreditation process – itself based on an international standard (ISO/IEC 17011: Requirements for accreditation bodies accrediting conformity assessment bodies) – is extremely rigorous and ensures that only those organizations that meet the stringent requirements under the standard are accredited. Independent third-party accreditation is an “accountability mechanism” to ensure the quality and legitimacy of organizations offering credentials. ANAB accreditation provides an added layer of legal defensibility against invalid claims. The accountability and transparency built into the ANAB process support conformity assessment attestations and can result in reduced liability insurance.
Benefits of Accrediting Credentialing Organizations to ISO/IEC 17024
Accreditation is a key component of an effective standardization system, assuring industry and governmental decision-makers that credentialing organizations are competent and their results can be trusted. The standard was developed by the International Organization for Standardization (ISO) based on the need for public protection by establishing that individuals have the required competencies to perform
their job. The standard has been recognized by several U.S. federal agencies as a critical requirement for personnel certification bodies that offer certification in areas related to public health, environment, and
national security. ANAB is a signatory to the International Accreditation Forum (IAF) Multilateral Recognition Arrangement for ISO/IEC 17024, which brings global acceptance of its accreditation program,
The following are the key requirements under the standard:
a) the involvement of appropriate experts;
b) the use of an appropriate structure that fairly represents the interests of all parties significantly concerned, without any interest predominating;
c) the identification and alignment of prerequisites, if applicable, with the competence requirements;
d) the identification and alignment of the assessment mechanisms with the competence requirements;
e) a job or practice analysis that is conducted and updated to:
To ensure that the credentials they promote meet industry and quality standards, many federal and state agencies rely on ANAB accreditation. Some examples include:
ANAB has accredited the QABA Credentialing Board under ISO/IEC 17024 for (a) Applied Behavior Analysis Technician, (b) Qualified Autism Services Practitioner- Supervisor (QASP-S) and Qualified Behavior Analyst (QBA). These programs have demonstrated compliance with the stringent requirements of the standard.
We support the petition to amend the regulation to accept certification from an entity that is nationally recognized to certify practitioners of behavior analysis. We recommend ANAB be recognized as an accreditation body for the licensing of Applied Behavior Analysis and the QABA certification programs accredited by ANAB be included in the licensing of Applied Behavior Analysis.
Please feel free to contact me for any additional questions or clarification.
Sincerely,
Vijay Krishna, MBA, ED.D.
Vice President, Credentialing
ANSI National Accreditation Board
1899, L Street Suite 1100, Washington DC 20036.
I disagree to add QABA. The BCBA helps make sure that BCBA's, BCaBA's, and RBT's are practicing within their scope and that they are providing ethical services to their clients. ABA has a bad rap from the past and with the help of the BACB it is helping change the way people look at ABA therapy. We need to continue to on providing ethical practices of ABA with clear guidelines and qualifications for everyone that is practicing ABA.
Breakdown of last response:
I disagree to add QABA.
The BCBA helps make sure that BCBA's, BCaBA's, and RBT's are practicing within their scope and that they are providing ethical services to their clients. - If this statement is true, why does the BACB continue to allow certified members who shock and electrocyte children with Autism.
ABA has a bad rap from the past and with the help of the BACB it is helping change the way people look at ABA therapy. - Really? Again, shocking minor children. If that is the change you want then you would literally be a sadist.
We need to continue to on providing ethical practices of ABA with clear guidelines and qualifications for everyone that is practicing ABA. - Thank you for making me laugh today. The BACB has no idea what ethics are. They literally certify people who shock children.
Here is the video: https://www.youtube.com/watch?v=-aUIhWmDPeI
Here are the BCBA's: https://www.judgerc.org/board-of-directors.html
Josh Pritchard, Ph.D., BCBA-D
Nathan Blenkush, PhD, BCBA-D
It’s curious that six people affiliated with QABA, including its owner, have posted on this page in support of the QABA position. Yet none of them have disclosed their relationship with QABA. Interesting business ethics.
Andrew Patterson, Executive Director of the Autism Business Association, owns the
shell corporation (Elevated Autism Services Team LLC) that owns QABA
Ira Heilveil – filed paperwork in California for Elevated Autism Services Team
Rosa Patterson – wife of QABA owner, Andrew Patterson
Eric Linder – current QABA board member
Jessica Swanson – current QABA board member
Valencia Church-Williams – current QABA board member
I think that an example of "transparency" would be not posting derisive comments about others anonymously.
I am a public official with several public social media accounts and a website that is heavily trafficked. I am not difficult to find and my intentions are difficult to discern. I am also a proud member of QABA board and it was never a secret. However, my posting included my own thoughts and opinions and do not necessarily reflect the stance of the QABA board. This is why I did not mention my affiliation in the post.
"Anonymous", should you have other questions/comments/concerns please feel free to reach out to me directly at vchurchwilliams@thebridgeconsultinggroupllc.com.
Breaking News - Anonymous Calls Out People Who Use Their Name While Being Anonymous
I support anyone who comments anonymously! The evidence in the comments is clear. If you comment, either way, you will be attacked.
I also DO NOT support allowing this change to occur in Virginia. We must protect the consumers.
... that consumers will be hurt by being diverse, allowing collaboration, and opening up the field to those who are qualified.
I do not support the QABA licensure.
This is not a vote... your "vote" does not matter. The purpose of this form is to give facts and opinion so the board can determine what is appropriate.
I want to start off by saying that the following is my opinion as an individual behavior analyst, and as such, only represents that, as is the purpose of legislative comment forums. My comments are entirely directed to the board that will review this petition. If someone feels that it is his/her/their best option to attempt to correct my personal opinion, or that somehow my personal opinion as a behavior analyst is threatening, then I am truly sorry that that is the position that that individual feels that they are in. Providing behavioral health services to people in need should never result in practitioners needing to be on the defensive/offensive. We're able to be most effective when we work together. It is clear to me that there are many passionate voices willing to speak on this topic, as there should be. No petition or legislative matter should be met with ambivalence. I also appreciate any issue that could push behavior analysis further and occasion self-reflection to improve our field.
I am incredibly disheartened by a few things (not all, but many) regarding this petition and the process. Primarily, the divisiveness and cutting down of one another as professionals and even people, in a public forum. Regardless of one's opinion on the content of this petition, I am concerned about the commentary being a reflection of our field and the practitioners therein. I wonder what members of the public may be turned off from all of us behavior analysts, who already may have a reputation for not working together for the common good outside of ABA. I am also concerned about the underrepresentation of individuals/families receiving services in public comment forums. And finally, there are ALWAYS things to improve on, for every board, certifying entity, etc., because people are imperfect, and we are the ones who make decisions.
I admit to not being as familiar with the QABA as I am with the BACB, so let me preface with that. I also wasn't as concerned about the petition before reading this forum as I am now. I would like to think that I approached from a position of wanting to learn more, and trying to figure out where the opposition is coming from, while being as objective as possible (knowing there's an intrinsic bias as I'm certified by the BACB). From reading the QABA code of ethics, it's evident that there are many similarities between the BACB code of ethics. I started there because it's often the lifeblood of an organization, and an organization's values can be made clear by reading what guides the practice of the certificant participating in that credential. What I saw was a great start to an ethical code (very similar to previous iterations of the BACB's code of ethics and professional conduct). I wasn't able to (upon first glance) see many differences in intent. When I looked for how data was used and incorporated, I saw an underrepresentation of reliance on data and function to drive decision making. I also didn't see any information regarding assent, and there wasn't any information that I could spot other than in the research section that spoke to obtaining informed consent from the client/guardian, and/or what to do if the individual receiving services declines. Additionally, with an international entity, some of the aspects of the ethical code may conflict with country laws, but there is no guidance to say which should be followed. For example, there are currently 71 countries that criminalize homosexuality/bisexuality, and 15 that criminalize gender fluidity/trans expression, yet the code of ethics gives no guidance on how to balance that and anti-discrimination policies.
https://www.humandignitytrust.org/lgbt-the-law/map-of-criminalisation/
The other component that is concerning to me is the limitation of the code of ethics and QABA credential to apply to treating "individuals with autism spectrum disorders and related disorders." If a practitioner with a QABA credential were to decide to work with animal training, or informing public safety policy, what would prevent that person from doing so if under the same license? It would then fall to the public/employer to determine the appropriateness of that practitioners experience given the role that he/she/they are in, which takes away the regulation and protection inherent in licensure for the public. One could say that if that practitioner is practicing within his/her/their "scope," that it shouldn't matter, however, the QABA code of ethics (per the introduction), applies to practitioners working with "individuals with autism spectrum disorders and related disorders."
After some poking around, I was able to find information about what happens if a complaint is made on the website. If I was a consumer, I would have difficulty being able to figure out how to use the QABA board for protection using the complaint process, especially because the complaint form is only to be used between certificants, and the website states that complete information up to and including the complaint-filer's certification number would need to be submitted. Though I truly appreciate the intent to expand services throughout the world given how lucky we are in the United States to even be having this conversation, how is the complaint made by individuals worldwide who can't read or speak other languages? Who is explaining all of this to them so that they benefit from protection as well? What if the person needing to submit a complaint (the purpose of any credentialing board) is a member of the public and is unable to bring issues to the attention of the board? How are cultural norms identified and incorporated, and ensuring that women and children, LGBTQ+ youth, and others who may be disempowered in this country and across the world are able to be protected from unethical practices? I couldn't easily find the infrastructure around any of these questions (which is the lens a consumer would use), which worries me. Keeping ABA practice within the US is not the best course of action either, to be sure. I would, however, want to ensure first that no harm could possibly be done to those impacted by ABA services, especially if one is an ambassador of ABA throughout the world.
I am all in favor of having credentialing that is the optimal balance of protection for consumers, and easier access to services for individuals who would benefit from them, but not if there aren't enough protections in place for the individuals that ABA impacts. I worry that it may be a little too hasty and to narrow a focus for the QABA to be included in certifying entities for licensure in Virginia before some of these questions have thorough and easy to find answers.
Thank you for your consideration of my comment.
No organization is perfect both have flaws. But both the BACB and QABA have high standards and are accredited. We should let them both practice. They have meet the requirements of the accreditation boards and have 3rd party review by reputable NGO's.
I received a letter from the attorney of the BACB in the last few days.
When confronted about the BCBA's certified running the center that shocks children, the BACB says "The BACB also does not have jurisdiction over service delivery agencies." So I guess the BACB will allow the leaders shocking children to stay certified in violation of their own ethics code.
I am happy to send this email to the board to review.
Did you know that the BCBA has given up discipling behavior analysts... see:
https://www.bacb.com/services/o.php?page=100180
The entire purpose of the BACB was to provide competent behavior analysts but they don't even enforce their own ethics code anymore with the exception of line technicians.
If they will not punish someone for leading an organization shocking those with Autism where is the line?
Please check facts. The webpage cited by the petitioner as showing that the BACB does not enforce its ethics code with anyone except RBTs actually shows just the opposite.