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Virginia Regulatory Town Hall
Department of Health Professions
Board of Medicine
Regulations Governing the Practice of Behavior Analysis [18 VAC 85 ‑ 150]
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4/14/22  12:02 am
Commenter: Prof. Michael Moates, MA, QBA, LBA, LMHP

Give Patients the Right to Choose and Raise the Standard By Adding Competition

It appears it did not post correctly. 


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):

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


Behavioral Intervention Certification Council:

International Behavior Analysis Organization:

Third Party Boards:

State of Virginia:


"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

"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


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