Virginia Regulatory Town Hall
Agency
Department of Health Professions
 
Board
Board of Medicine
 
chapter
Regulations Governing the Practice of Behavior Analysis [18 VAC 85 ‑ 150]
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3/21/22  11:58 am
Commenter: Michael Moates, MA, QBA, IBA, LBA, QMHP-T, EdD Candidate

Further Reading with Quotes for the Board to Consider
 

"The BACB does not appear to have the money, staff, time, or legal authority to provide the necessary ethical oversight, especially with the literally thousands of members of the Association of Behavior Analysis International (ABAI) and/or BCBAs who practice both within the United States and around the world."

"To further complicate matters, the BCBA credential is not consistent with the generally accepted concept of board certification as recognized in the fields of medicine, psychology, and other human service professions."

See: https://www.ncbi.nlm.nih.gov/pmc/articles/PMC2854065/

"One issue of regulatory concern is that often discussed in behavior analytic circles is that Behavior Analyst Certification Board (BACB) offers a national license. This is false. BACB is not licensing, nor could the BCBA ever be a national license for behavior analysts. Licensure falls under the states rights or powers. It is the prevue of each state to restrict trade within its borders. United States v. Lopez, 514 U.S. 549 (1995) held that the federal government only has the right to create laws that effect interstate commerce."

The federal government recognizes QABA and BICC as certification boards of behavior analysis.

See: https://www.abainternational.org/media/177713/luiselli.pdf

"The BAMLA defines who a professional behavior analyst is, categorizing the knowledge, skills, experiences, and abilities. In addition, it clarifies that a behavior analyst is a person who functions within a particular scope of practice. Finally, it helps to define the profession within a scope of practice that highlights the uniqueness of applied behavior analysis. The BAMLA further specifies the common commitments to expect from a behavior analyst in adherence to an ethical code and generally accepted behavior analytic positioning papers."

“However, for a number of logistical reasons, the BACB can only enforce adherence to the Professional Disciplinary Standards, (not adherence to the Guidelines for Responsible Conduct) and it relies heavily on information from local responsible sources in reviewing allegations against certificants” (BACB). Thus, BCBA will not investigate most forms of impairment, for they are ethical issues."

See: https://www.abainternational.org/media/177719/pritchard.pdf

 

Something else that MUST be noted is that there appears to be no research on the BACB certification requirements outside of those who are certified by the BACB. Thus, all research completed is biased and must be evaluated for its implicit bias. 

Also, for the record, I personally reached out to the BACB to seek their help in making sure that the standards represent everyone not just BCBA's and was ignored. 

There are many complaints with regards to customer service because the BACB is not interested in engaging with its community but rather they seek to dominate the industry.

References:

https://www.abainternational.org/media/177713/luiselli.pdf

https://www.abainternational.org/media/177719/pritchard.pdf

Dorsey, M. F., Weinberg, M., Zane, T., & Guidi, M. M. (2009). The case for licensure of applied behavior analysts. Behavior analysis in practice2(1), 53–58. https://doi.org/10.1007/BF03391738

CommentID: 120833