Virginia Regulatory Town Hall View Comments

Department of Health Professions

Board of Medicine

Regulations Governing the Practice of Behavior Analysis [18 VAC 85 ‑ 150]

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3/17/22 6:56 pm

Commenter: Theodore A. Hoch, Ed.D., B.C.B.A.-D., L.B.A.

Great concern regarding the QABA credential - Part 1

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,

As QABA continues to grow both nationally and internationally, there is a great need for more coursework providers who offer the QABA coursework options to meet the demands of certification.

As a VCS provider for the BACB, I believe you already have a majority of the coursework to offer the Qualified Behavior Analyst (QBA), parallel to the BCBA; and the QASP-S, parallel to the BCaBA, for those seeking certification. Many students are researching universities and providers that have this coursework so they do not have to question their education and take supplemental coursework to meet the QABA standards. Being a QABA Coursework Provider is beneficial to both George Mason University and the students. Students will have the confidence to know that George Mason University provides the courses needed to become certified with QABA. Attached are the QBA Competency Standards along with the QASP-S standards.

As a Pre-Approved Coursework Provider, your university will be added to our ever growing list of approved providers for students. You may review this list of providers on our website at https://qababoard.com/pages/qaba-community/. QABA also markets new providers on our social media as Spotlight Providers (Facebook, Instagram, and LinkedIn).

Since the BACB has pulled out of the international credentialing program, many students are contacting QABA since we are the only internationally accredited credentialing board for applied behavior analysis. With accreditation through ANSI, who meets the ISO 170124 standards, we have certificants in more than 29 countries (and growing)! Certificants in various countries, including the US, can move to another country and know that their certificate is recognized worldwide.

To review the requirement to become a QABA Pre-Approved Coursework Provider, please visit our website at https://qababoard.com/guidelines-for-abat-or-qasp-coursework-providers/. The initial application fee is $200 USD with an annual renewal fee of $100 USD.

If you would like any additional information or have questions, please do not hesitate to contact me.

Have a safe and wonderful New Year!

Hollie

My reply, from 30 December 2021:

Thank you -

I looked through the materials on your website and available at the links there. A coupe of questions:

1) 3890 of the 5748 individuals listed as credentialed on your public registry either have expired credentials, or credentials that will expire on 1 January 2022. This means that effective 2 Jan 2022, 1858 individuals will hold active credentials through our organization. Is this correct?

2) In which states / countries would the QBA credential meet requirements for behavior analyst licensure?

3) On the bottom of the QABA Public Registry, there is a statement that ends with this line: “In addition, these individuals are providing behavior health services under the supervision of a certified professional or licensed professional with ABA or ASD in the scope of their field.” Is this statement to be interpreted to mean that practitioners with QBA or other credentialing through your organization may not work independently, under their own credential, and must work under supervision of another professional?

4) It appears that most providers of coursework listed on your webpage are not university programs, but are private entities. Is this correct?

Thanks, and best wishes -

Ted Hoch

I received no reply.

I am greatly concerned with the puffery I saw that the QABA's website that day, and with the manner in which claims were made regarding number of credentialed folks. It appeared that a large number of those counted included parties whose credentials had expired and not been renewed.

I'm also concerned regarding the extent to which "training" is accepted to become a QABA, which is not university coursework, should my reading of their website on that date have been correct.

The required coursework and supervised experience needed to become a QABA is much less rigorous and has far less depth than that required to become a BCBA or BCABA. Indeed, the Board can view this for themselves by visiting the QABA's website (https://qababoard.com/pages/qaba-community/) and by visiting the BACB's website (www.bacb.com) and the Association for Behavior Analysis' website (www.abainternational.org - please review sections pertaining to Verified Course Sequences - VCSs - and Accredited Programs).

It is imperative to protect the citizens of the Commonwealth by ensuring that those providing behavior analysis services are adequately credentialed. I do not believe the the QABA credential is comparable to the BCBA or BCABA credential, and it should not be substitutable for either of those credentials for those seeking LBA or LABA licensure.

I will gladly forward the original email correspondence between Ms. Benincosa and myself to the Board, should the Board request.

CommentID: 120808