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