The prerequisites required of a BCaBA to gain that certification and then to receive licensure as an LABA in Virginia are substantial and include proven skills from assessment to treatment to data decision making to supervision/training and more of unlicensed individuals.

The proposed updates to the ABA portions of Intensive Community Based Support Services remove the ability of the BCaBA to engage in scope of practices that align with their education and training. 

Removal of those activities:

1. Devalue and negate the work of those professionals
2. Strain, and therefore, decrease current available rosters of service delivery providers of ABA to needy VA Medicaid members
3. Appears to be contradictory to the language regarding scope of practice for behavior analytic services as described in the Virginia Register

Please reconsider the current proposals to maintain quality and quantity service delivery to families in need and keep the BCaBAs able to work as per their certified skills