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  11:41 pm
Commenter: Jennifer Wade, M.Ed, BCBA, LBA

Oppose the Petition
 

Good evening, 

I have worked in the field of ABA in the Commonwealth of Virginia for over 20 years.  I have been a Board Certified Behavior Analyst since 2010 and became a Licensed Behavior Analyst in 2012, when licensure became available.  I am heavily invested in our community, our clients, our families, and our profession.  

I agree with many of the remarks of others in opposition to the petition.  For me, the area that is most concerning is this:  At a time when our field is being flooded with new practitioners, we CANNOT lower our standards.  For the sake of our clients and for the sake of our field, we must ensure that professionals practicing in our Commonwealth are held to the same standards (or higher) than those that are currently in place.  The Board and the relevant Working Group worked tirelessly a decade ago to create the licensure requirements and guidance documents that exist to this day.  If those need to be amended with proper consideration and for valid reasons, so be it.  Lowering the expectation for coursework and supervised fieldwork is unacceptable and not a valid reason to revise what is currently in place.   

Thank you for your consideration.

CommentID: 121466