We, the public policy committee of the Virginia Association for Behavior Analysis thank you for the opportunity to comment on this appendix.  We ask that you consider adding the skills and expertise of Licensed Behavior Analysts (LBAs) to the document in the following ways:

1. Adding the option of an LBA as part of the multidisciplinary team for 23-hour crisis stabilization and Residential Crisis Stabilization programs to assist with ameliorating behavioral health crises,
2. Including the option of an LBA on the team that treats an individual following a behavioral crisis to reduce the likelihood that the individual will require this more restrictive level of care in the future and to decrease the likelihood of hospitalization, and
3. Considering LBA training and/or oversight of Crisis Education and Prevention Plans (CEPPs), especially where there are more complex behavioral needs.