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  8:42 pm
Commenter: Ken Crum, ServiceSource

Behavior Analysis Comments
 

ServiceSource is a large day and employment services provider in Northern Virginia. We support hundreds of individuals with developmental disabilities, behavioral health needs as well as people with sensory and physical disabilities. Due to the pandemic, there are increased behavioral support needs and a lack of resources to address concerns. Additionally, there is a significant financial strain placed on providers to hire or contract with licensed/certified behaviorists.

ServiceSource supports the continued emphasis on strict bylaws, qualifications and other requirements that are implemented by a single entity, since this provides a structure of how services, plans, and interventions are outlined. It also ensures that the qualification process and educational requirements are heavily monitored, ensuring that the behavioral health professional undergoes rigorous and high-quality training. The qualification process is dictated by certain bylaws, ethic codes, and principles of applied behavior analysis, something that can be overlooked by entities unfamiliar or new to ABA principles.

We also support acquiring a more diverse workforce and recommend increasing the number of behavioral health professionals with specialties in differing concentrations and we believe that their basis of ABA knowledge should be consistent and monitored by a single entity.  

Ultimately, it would be beneficial for behavioral health professionals providing services to Virginians be accredited under one national entity. With additional accreditation boards, there is no guarantee ensuring services rendered are based on rigorously tested and empirical based studies, and the potential for pseudoscience or bogus interventions may grow exponentially.  

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