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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4/13/22  3:05 pm
Commenter: James Santoyo

Oppose
 

I’ve been practicing as a Licensed Behavior Analyst in Virginia since 2013 and I oppose this petition. The individuals who receive our services deserve the best protection and utmost quality of care and treatment. To provide a high level of protection to consumers of behavior analytic services, the following should be adhered to by credentialing boards that are accepted as qualification for licensure:

1) Credentialing boards should have standards that are equal to or greater than those currently required by Virginia law.

2) Credentialing boards should hold non-profit status to ensure transparency with consumers, regulators, and the general public.

3) Credentialing boards should focus on certifying individuals in behavior analysis and not one specific population.

At this time, the only credentialing board that meets these criteria is the Behavior Analyst Certification Board (BACB).

CommentID: 121441