It appears it did not post correctly. 

Here: 

I am so glad this is over. I want to leave you with some final thoughts to consider.

I am so tired of being degraded, dehumanized, threatened, stalked, etc. Members from the BACB have called my employer, certification board, etc. They have stalked me online. It just was extremely unprofessional behavior for an organization that is wanting to set the standard.

In spite of this, we all pushed through. We fought till the end and when the board takes up this action, we know that they will do so with all of the information.

Final Points:

Behavior Analyst Certification Board (Wants to be the popular kid but is really the bully):

• 70% of BCBA’s are white, less than 1% are American Indian, less than 1% are Pacific Islander, 10% are Hispanic, 6% are Asian, and 3% are black. There is no diversity. https://www.bacb.com/bacb-certificant-data/
• 86%  of BCBA’s are female, 12% are male, with the rest as other or not identified. There is an issue of finding male therapists. https://www.bacb.com/bacb-certificant-data/
• 72% of are focused on Autism Spectrum Disorder. https://www.bacb.com/bacb-certificant-data/
• The BACB is withdrawing from the international market. https://www.bacb.com/global-certification/
• The BACB does not offer its testing in other languages besides English. https://www.bacb.com/global-certification/
• The BACB does not recognize clinical psychiatrists engaged in behavior analysis as supervisors. https://www.bacb.com/bcba-handbook
• The BACB does not accept CEU’s from Psychiatrists, Psychologists, etc… only its BCBA’s. They would not allow you as doctors to even teach continuing education courses https://www.bacb.com/wp-content/ACE-Provider-Handbook
• The BACB continues to certify the leadership at the Judge Rotenberg Center that is shocking children. https://www.youtube.com/watch?v=Ko-ip3MImik
• The United Nations has designated practices lead by BCBA's as torture. We treat prisoners at Guantanamo Bay better.  https://abcnews.go.com/Nightline/shock-therapy-massachussetts-school/story?id=11047334
• The BCBAs on this board are (the BACB has been notified and they have stated they intend to do nothing about this):

  • Board of Directors: Henry Slucki, Ph.D. 

    Jessica E. Van Stratton, Ph.D., BCBA-D, LBA

    Richard Malott, Ph.D., BCBA-D

    Josh Pritchard, Ph.D., BCBA-D

    Ronald Van Houten, Ph.D.

    W. Joseph Wyatt, Ph.D.

    On Staff:

    Nathan Blenkush, PhD, BCBA-D

• The BACB seeks to oust other qualified supervisors from supervising behavior technicians, assistant behavior analysts, and aspiring behavior analysts. While psychologists, psychiatrists, social workers, professional counselors, and other related fields retain the right to practice behavior analysis, the BACB does not recognize them as supervisors of behavior analysis. https://www.bacb.com/wp-content/ACE-Provider-Handbook
• The BACB has already stated its standards for 10 years from now despite not knowing how academic research will present. https://www.bacb.com/wp-content/mar2022_Newsletter
• They are trying to build an anti-competitive licensure monopoly.
• The BACB threatens other non-profits who attempt to work in behavior analysis.
• The BACB leadership team is 100% white people. https://www.bacb.com/about/staff-leadership/
• The BACB talks negatively about other boards calling them Autism specific. This is just libelous as stated by ANSI. https://townhall.virginia.gov/L/viewcomments.cfm?commentid=121046 No comment on this discussion post has provided evidence that alternative certification boards are acting in bad faith or unethically.
• No poster has provide evidence that any other board is less qualified.
• The BACB cannot possibly meet the requirements of different populations across all 50 states.
• BCBA's personally benefit from less providers. They have long waitlists which hurts the client. ABA treatment is more effective the earlier it starts.
• Here is a BCBA being arrested for assault. https://www.kktv.com/2021/11/10/behavior-analyst-loses-license-this-11-call-action/

Qualified Applied Behavior Analysis Credentialing Board (Top Alternative, the A Student):

• The QABA Board has not only each of the requirements of the BACB however they have even more requirements.
• They are not an autism specific board. Autism is in addition to the behavior analysis requirements. https://qababoard.com/wp-content/uploads/QBA-Competency-Standards-2022.pdf
• They require a psychometric exam. https://qababoard.com/taking-examinations
• The require supervision experience hours. https://qababoard.com/wp-content/uploads/QABA-Supervision-Log-January-2022.pdf
• They require a federal and state background check. https://qababoard.com/background-attestation-form/
• They require a masters degree. https://qababoard.com/wp-content/uploads/QBA-Candidate-Handbook-March-2022.pdf
• They require coursework in applied behavior analysis. https://qababoard.com/wp-content/uploads/QBA-Competencies-Worksheet-January-2022.pdf
• They have an ethics code. https://qababoard.com/code-of-ethics/
• They are run by an independent board of directors. https://qababoard.com/leadership/
• They also have an international standards committee. https://qababoard.com/pages/qaba-international-standards-committee/
• They have an Africa based operation. https://qababoard.com/pages/qaba-in-africa/
• They are accredited by ANSI in Behavior Analysis. https://qababoard.com/
• They are recognized by the Department of Defense. https://manuals.health.mil/pages/DisplayManualHtmlFile/2021-03-26/AsOf/TO15/C18S4.html
• Exam and certification materials are offered in alternative languages. https://www.qababoard.net/
• QABA offers discounts to 3rd world countries that are developing the practice of behavior analysis. https://www.youtube.com/watch?v=fL4n_hgW4lc
• They have a designated scope of practice and competency requirements. https://qababoard.com/wp-content/uploads/QBA-Competency-Standards-2022.pdf
• There is no evidence that QABA is less qualified. In fact, they require more educational subjects than the BACB. It could also be argued an organization that is not entangled with the certification of people shocking children is better.

Behavioral Intervention Certification Council:

• They have additional requirements beyond what the BACB requires. https://www.behavioralcertification.org/Content/Documents/BCAP_Exam_Content_Outline.pdf
• They are accredited by NCCA. https://ice.learningbuilder.com/Public/MemberSearch/ProgramVerification?model.MemberName=behavior&SearchAliases=false&model.Role=&model.MemberRoleLabel=&attr.Industry=&attr.Name=&performSearch=true
• They require supervision experience. https://behavioralcertification.org/wp-content/uploads/2021/10/BCAT_2_year_documentation_of_supervision-2.pdf
• They require at least a masters degree. https://behavioralcertification.org/wp-content/uploads/2021/03/BCAP-Candidate-Handbook-20210218.pdf
• They require behavior analysis coursework. https://behavioralcertification.org/wp-content/uploads/2021/03/BCAP-Candidate-Handbook-20210218.pdf
• They have a code of conduct. https://www.behavioralcertification.org/Content/Documents/BICC_Code_of_Conduct_2019_2020.pdf
• They require passage of a psychometric exam. https://behavioralcertification.org/wp-content/uploads/2021/03/BCAP-Candidate-Handbook-20210218.pdf
• They have an independent board of directors. https://behavioralcertification.org/about-us-autism-spectrum-disorder/board-directors/
• They have conducted a job analysis. https://www.behavioralcertification.org/Content/Documents/Job_Analysis_Executive_Summary_2017.pdf
• They require a background check. https://www.behavioralcertification.org/Content/Documents/SaferPlaces_Disclosure_and_Authorization.pdf
• They have a designated scope of practice and competency requirements. https://www.behavioralcertification.org/Content/Documents/BCAP_Exam_Content_Outline.pdf

International Behavior Analysis Organization:

• They are not an autism specific board. 
• They require a psychometric exam or you can qualify based on accredited BCBA or QBA equivalency. https://theibao.com/docs/IBA-Exam-Procedures-v101.pdf
• The require supervision experience hours. https://theibao.com/docs/IBA-Requirements-v101-ENG.pdf
• They require a masters degree or additional experience.  https://theibao.com/docs/IBA-Requirements-v101-ENG.pdf
• They require coursework in applied behavior analysis. https://theibao.com/docs/IBA-Requirements-v101-ENG.pdf
• They have an ethics code. https://theibao.com/docs/IBAO-Ethical-Guidelines-V100.pdf
• They are run by an advisory board. https://theibao.com/professional_advisory_board
• Exam and certification materials are offered and being developed in alternative languages. 
• They have a designated scope of practice and competency requirements. https://theibao.com/docs/IBA-REOs-V100.pdf
• They are not currently accredited. This information is provided to the board for reference.

Third Party Boards:

• The Virginia Association for Behavior Analysis requires a masters degree only for membership. https://virginiaaba.org/choose-membership/
• The Association for Behavior Analysis International recognizes QABA, BICC, and IBAO in addition to the BACB. https://www.abainternational.org/media/188058/abaimembershipform_2022.pdf

State of Virginia:

• The State of Virginia is already has already recognized alternative certifications we are simply asking you to codify it in the rules to be consistent.
• The law requires the board by saying “shall include” “Documentation that the applicant is currently certified as a Board-Certified Behavior Analyst by the Behavior Analyst Certification Board or any other entity that is nationally accredited to certify practitioners of behavior analysis;” (Emphasis Added) http://www.dhp.virginia.gov/media/dhpweb/docs/med/leg/Ch29_Medicine.pdf
• No other mental health board in Virginia requires certification by one entity. See: https://www.dhp.virginia.gov/counseling/  https://www.dhp.virginia.gov/counseling/counseling_laws_regs.htm  https://www.dhp.virginia.gov/psychology/psychology_laws_regs.htm
• Most other Virginia Licensing Boards offered grandfather periods for previously practicing professionals where the Behavior Analysis occupation was not provided the same. See: § 54.1-3509, § 54.1-3514, 
• It is likely unlawful to force association to one organization under the First Amendment.
• It is likely unlawful for a government entity to force association that is a violation of someones religious beliefs. Re shocking children and the First Amendment.
• Given the above, there is a pending court preliminary injunction to strike down any law that only allows for licensure via the BACB. If the board wants to protect itself it might consider adding an alternative.
• More certification boards would allow your constituents the choice to choose their providers.
• More certification boards would require the BACB to compete and raise the bar/standard to meet other certification boards which require additional courses, experiences, and even simple things like a background check.
• More providers would also decrease the waitlists for ABA services. Search for waitlist using the find feature and you will see these providers have a “long” “extensive” waitlists. https://www.leapahead.org/ https://www.greenboxaba.org/ https://www.chattanoogaautismcenter.org/outpatient-clinic http://learnwithmasc.org/about-us/services/ https://villagemindset.org/staff/stacie-dizzley-streeter-bcba/ https://www.blueridgehorizonaba.com/locations 
• News articles on the same. https://www.localdvm.com/news/virginia/local-clinics-join-forces-to-combat-aba-practitioner-shortage-as-autism-cases-climb/

Quotes:

https://www.ncbi.nlm.nih.gov/pmc/articles/PMC2854065/

"The BACB does not appear to have the money, staff, time, or legal authority to provide the necessary ethical oversight, especially with the literally thousands of members of the Association of Behavior Analysis International (ABAI) and/or BCBAs who practice both within the United States and around the world."

"To further complicate matters, the BCBA credential is not consistent with the generally accepted concept of board certification as recognized in the fields of medicine, psychology, and other human service professions."

This is stated by their own certified people. 

Michael Dorsey, PhD, BCBA

Michael Weinberg, PhD, BCBA

Thomas Zane, PhD, BCBA

Megan Guidi, MSEd, BCBA

https://www.abainternational.org/media/177713/luiselli.pdf

"One issue of regulatory concern is that often discussed in behavior analytic circles is that Behavior Analyst Certification Board (BACB) offers a national license. This is false. BACB is not licensing, nor could the BCBA ever be a national license for behavior analysts. Licensure falls under the states rights or powers. It is the prevue of each state to restrict trade within its borders. United States v. Lopez, 514 U.S. 549 (1995) held that the federal government only has the right to create laws that effect interstate commerce."

This is stated by their own certified people. 

Joseph Cautilli, PhD, BCBA-D

Halina Dziewulska, MSEd. BCBA

I respectfully ask you to help us give patients the right to choose.  Give them the opportunity to have increased quality care by raising competition that forces people to compete to be the best provider. I encourage you to look at links and documents also feel free to reach out to me should you have any question. There were a lot of statements made in this comments section. Very few actually included references or documentation to back up such claims.

Help me step in to the future and:

Empower your patients with the right to choose by raising the bar of competition. More standards = forcing people to be the best.

Very Respectfully,

Prof. Michael Moates, MA, QBA, IBA, LBA, LMHP

Global Institute for Behavior Practitioners and Examiners, a non-profit organization

Doctor of Education Candidate

University Professor

Student Health Advisory Committee

Senior Member, Civil Air Patrol, United States Air Force Auxiliary

Certified Accreditation Evaluator