As a Board Certified Behavior Analyst licensed to practice in the state of Virginia, I felt compelled to comment and express my lack of favor for the petition “to remove the specific requirement for BACB certification and accept certification from an entity that is nationally accredited to certify practitioners of behavior analysis”. The scope of practice for a Licensed Behavior Analyst in the state of Virginia as specified in the Regulations Governing the Practice of Behavior Analysis  (18VAC85-150-110) includes “Design, implementation, and evaluation of environmental modifications using the principles and methods of behavior analysis to produce socially significant improvement in human behavior including the use of direct observation, measurement, and functional analysis of the relationship between environment and behavior; and 2. Supervision of licensed assistant behavior analysts and unlicensed personnel”. This scope of practice far outreaches the world of Autism – touching, but certainly not limited to behavioral gerontology, behavioral pediatrics, treatment of substance abuse disorders, brain injury rehabilitation, education, environmental sustainability, health and fitness, and organizational behavior management. QABA’s website states they are a credentialing agency “dedicated to ensuring the highest standard of care among professionals providing applied behavior analysis services for individuals with autism spectrum disorders and related disabilities.” This specification within QABAs language – and therefore their training and scope of practice – of course presents a disservice to those seeking professional service within the many other fields a BCBA is qualified to provide service to. When I have an injury to a bone, an orthopedic surgeon is my best bet – for any other ailment, I want a more globally trained doctor. We have a responsibility to those seeking service within behavioral pediatrics, substance abuse disorders, TBI, among others – to ensure their service is being provided by a behavior analyst with training in that field – not limited to autism. I value a world in which there are enough trained and competent providers to serve everyone needing behavior analytic services – I do not value a world in which we compromise that service just to increase quantity of providers.