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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4/12/22  9:10 pm
Commenter: Anonymous

it is simple
 

text from the law enacted by the legislature

"Documentation that the applicant is currently certified as a Board Certified Behavior Analyst by the Behavior Analyst Certification Board or any other entity that is nationally accredited to certify practitioners of behavior analysis;" the text is required to be in the rule. It is not. the rule is not lawful.

the board understood this because it has been included the langauge for years

https://law.justia.com/codes/virginia/2014/title-54.1/section-54.1-2957.16/

https://law.justia.com/codes/virginia/2015/title-54.1/section-54.1-2957.16/

https://law.justia.com/codes/virginia/2016/title-54.1/chapter-29/section-54.1-2957.16/

https://law.justia.com/codes/virginia/2017/title-54.1/chapter-29/section-54.1-2957.16/

https://law.justia.com/codes/virginia/2018/title-54.1/chapter-29/section-54.1-2957.16/

https://law.justia.com/codes/virginia/2019/title-54-1/chapter-29/section-54-1-2957-16/

https://law.justia.com/codes/virginia/2020/title-54-1/chapter-29/section-54-1-2957-16/

https://law.justia.com/codes/virginia/2021/title-54-1/chapter-29/section-54-1-2957-16/

it continues to be in the language today

this was never about what is best

they ganged up to try to block behavior analysts from even being able to renew the licenes by copying and pasting the same post

copied from this

people used to think for themselves 

its interesting that they think the rules should not apply to them

https://virginiaaba.org/public-comment-due-6-27-18/

https://www.townhall.virginia.gov/l/viewcomments.cfm?commentid=65428

https://www.townhall.virginia.gov/l/viewcomments.cfm?commentid=65452

https://www.townhall.virginia.gov/l/viewcomments.cfm?commentid=65507

https://www.townhall.virginia.gov/l/viewcomments.cfm?commentid=65507

CommentID: 121394