Thank you to my colleagues for bringing this to my attention. I had not intended to comment anymore and I do with the intention of being respectful but there seems to be some confusion and misinformation.
I just want to clarify that my petition was not directed at any one agency. Not the BACB, QABA, BICC, etc
My petition referenced any organization that is accredited by ANSI or NCCA in behavior analysis. The goal was to bring the rule into compliance of the statute which requires the language used in the statute to be listed in the rule and it is not.
Having Autism coursework in addition to behavior analysis coursework should not disqualify someone, it should be considered an asset as long as it is in addition to the other required coursework/testing requirements.
It is for both QABA and BICC in my opinion.
Here are the competencies:
QBA: https://qababoard.com/wp-content/uploads/QBA-Competency-Standards-2022.pdf
QASP-S: https://qababoard.com/wp-content/uploads/QASP-S-Competency-Standards-January-2022.pdf
BCAP: https://behavioralcertification.org/wp-content/uploads/2021/03/BCAP-Candidate-Handbook-20210218.pdf
Here are the scopes of practice:
QBA: https://qababoard.com/qualified-behavior-analyst-scope/
QASP-S: https://qababoard.com/qasp-s-scope/
Also, ANSI has clearly stated that the QABA credentials are not Autism certificates but rather Behavior Analysis certifications.
See: https://townhall.virginia.gov/L/viewcomments.cfm?commentid=121046
Some have asked about job analysis: https://www.behavioralcertification.org/Content/Documents/Job_Analysis_Executive_Summary_2017.pdf
Also, something else I thought of, the FBI Behavior Analysis Unit is located in Quantico, Virginia. Has the Board of Medicine considered asking them for input?
Autism is one piece of each credential. They are tested in the Applied Behavior Analysis areas separately. Having Autism in the name does not make it only autism it just makes it a additional specialization.
I respect the anonymous commenters passion. I agree with them that if the board has reason to suspect foul play they should investigate who is commenting. The IP address, location, etc is all information that is traceable. If they all are having related locations, IP's, etc the board should not consider the comments.
You would have to be pretty uneducated to not know these kinds of things can be tracked.
I do not believe this is the case and I also suggest that there are many BCBA's also randomly commenting today. I believe that this is because it is the last day of the commenting period and many others have posted on various websites and social media.
I leave it to the board and IT to investigate and I hope they will. The board should only consider comments that are accurate.