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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3/23/22  11:29 am
Commenter: Michael Moates, MA

Reply to Crystal Peterson Barker
 

I agree with certain aspects of the statement made by Crystal Peterson Barker. Here are some things I think are important to address.

First, I do not agree with the non-profit language. There are many for-profit institutions that provide valuable training, education, etc. I also believe this language is unclear. Is she referencing not-for-profit, non-profit, non-government-organization, state non-profit, or 501(c)3 exempt organizations? Many of the colleges that teach ABA programs that are approved by the ABAI and to that point they are not less, they are accredited and are used by the BACB themselves.

Second, I agree wholeheartedly with the language about not being disability specific. I think this is an area where the BACB fails. As previously stated, nearly 80% of those certified by the BACB are Autism Practitioners and that leaves very little room for others to get supervision in areas such as gambling, forensic analysis, sex addiction, ADHD, animal behavior, etc.

Finally, I wholeheartedly disagree with the last statement. The BACB is not the one who should determine what the standards are for behavior analysis. The federal government gave this job to the states in the US Constitution. Further, the BACB has many deficiencies as previously stated. These include lack of provider types, lack of diversity in gender and race, and lack of supervision by state-approved providers. 

The state should determine the standard with input from various sources including consumers of behavior analysis, various certification organizations, educational entities, independent behavior analysts, and accreditation boards ANSI and NCCA.

CommentID: 120844