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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3/22/22  12:50 pm
Commenter: Michael Moates, MA

Reply to Anon
 

No one has provided a single shred of evidence that the standards are lower. You guys keep saying that. I say to you. Prove it. Cite empirical evidence. Cite research. Cite anything. We have shown that the BACB is not diverse and does not represent the population. We have done so through the BACB's own data. You guys come here and treat us like less. You dehumanize us and you provide no evidence. Show the board. Show the board what you are saying. If you can't, kindly sit down.

In addition, just because some standards may be different does not make them deficient. The BACB cannot create rules that will work across all 50 states. It is simply impossible. Every state has its own rules on scope of practice and supervising providers. The BACB has no way of adapting unless they create different rules for every state.

The board should disregard all comments that are not supported by evidence and research. These statements of less or deficient are not based in fact and frankly, the law is clear on what the requirements are. Period.

CommentID: 120839