I'm writing to request that BCaBAs be able to continue providing the supervisory level of services currently allowed while being provided guidance for any additional skills/expertise through their supervising BCBA.  This would allow them to continue to use the credential that they have earned through 180 hours of graduate level coursework and 1000+ hours of fieldwork training.  There is currently an abundance of BCaBAs at most ABA centers in the state of Virginia.  If BCaBAs were pulled from their supervisory role, many children would lose valuable ABA services due to lack of supervisors in the BCBA role. At many companies in Virginia, already, there is a shortage of behavior analysts in general which creates long waits for children to be able to contact behavioral therapy services. 

If this concern cannot be addressed, please consider providing additional time for current BCaBAs to continue their supervisory position throughout schooling and/or additional training if they would like to pursue their BCBA. This will allow continued training and supervision for the BCaBA without impacting the client's current services.

Thank you for your consideration.