While I have read the commentary here regularly, I have been reluctant to post commentary due to the combative, inflammatory, and ad hominem posture of responses to valid concerns. But I cannot in good faith let the deadline pass without adding voice to the concerns others have made regarding the petition at hand. 

Others have made these points more eloquently, so I will be brief. My concerns echo many others and include:

1. The process of becoming eligible for and attaining certification under QABA is not sufficiently rigorous as to protect consumers. Insufficient fieldwork is required, insufficient breadth of coursework in behavior analysis is required, and the examination itself has insufficient security protocols in place.
2. QABA's for-profit status raises grave concerns for me, as the motive must necessarily be retaining profit margins. This can easily lead to damaging policy changes and relaxation of rigor. Additionally, it means that the company can be sold or acquired by a bad actor. Combined with other transparency concerns, this status makes it quite difficult to determine who is actually steering the ship.
3. Behavior analysis is a broad field and licensure allows for practice in the entirety of the scope of practice. QABA's intense focus on autism interventions does not provide the background and experience required to ensure consumer protection in all areas of behavior analytic practice.
4. Many of the consumers of behavior analytic treatment, along with those that fund that treatment, are already faced with complicated decisions in choosing between various providers, multiple evidence-based practice approaches, and treatment outcome data. The one thing they can currently be assured of is that the professional providing the intervention has been credentialed by a rigorous certification board and licensed by a responsible board of medicine. While I am not in vigorous opposition to other credentialing pathways being accepted for Virginia licensure, the QABA is not the correct choice.