My name is Christy Evanko.  This comment is not on behalf of any organization for which I work or am a member but is solely my comment.  I do not work for the Behavior Analyst Certification Board in any manner, but I want do disclose that I am a certificant.  I was born in Virginia, moved away, but have lived here for over 20 years since moving back.  I am committed to Virginians and their safety as I hope I have shown with my prior actions.  I am a practitioner, but I am also a past consumer of behavior analysis services and those services were life-changing for my family.  I will always be grateful. 

I have been so dismayed by reading the comments in both the incorrect usage of behavior analytic terms to prove one’s point and the vitriol that that been applied when someone posts.  The point of public comment is for people to share their opinions so that the Board can make an informed decision.  I don’t feel that in this particular process, people felt comfortable sharing their opinions, and I am concerned that the process has been impeded, both by people not posting for fear of retribution and people posting under false names to further a narrative.  My experience with the Board of Medicine is that they are a thoughtful group who looks at all angles and understands the law.  I am hopeful they will go through this comment and explore all the relevant issues, despite the many distractions and attempts to redirect.

DHP licenses are about the safety of the consumer. 

• It is my opinion that understanding and applying the science of behavior analysis is a powerful responsibility that should not be taken lightly. 
• It is my opinion that there has been too much focus on using the science to “cure” a disorder and not enough focus on changing behavior to create a better life for someone and the people around them, despite any diagnosis. 
• It is my opinion as a consumer that I want to know I’m protected because the person who is providing services is certified by an organization that is transparent and has educational experiences that are rigorous and evaluated by ongoing job analysis studies – studies that, as a consumer, I have easy access to. 
• It is my opinion that if the Board of Medicine amends its regulations to include any nationally-accredited certification that it will lead to a race to the bottom from for-profit companies that place their requirements just below the lowest one that exists, so that people who are trying to escape putting in the necessary work (based on rigorous job analysis studies) will choose that certification over a more difficult one.  I’m not saying that any current company is doing this, but that the potential exists if there are not safeguards in place. 
• It is my opinion that it would be safe for another certification company to be accepted for licensure in Virginia, but that company would need to be non-profit/transparent, and the certification would need to be irrespective of diagnosis (meaning that there is not specific coursework required with respect to a diagnosis because diagnosis is not in our scope), have rigorous requirements based on job analysis studies, and require education from independently evaluated providers (e.g., universities). 

This is a public comment forum, and these are my opinions.  This science and this field are important to me, and I trust the Board will consider the decision carefully with the consumer/patient in mind.

Thank you,

Christy