BCBAs and BCABAs are in high demand across Virginia.  Therefore, I believe it is unrealistic to limit the oversight of ABA services to BCBAs and BCABA.  However, it is imperative provide additional guidance on scope of practice for LMHPs, beyond “acting within the scope of practice as defined by the applicable health regulatory board”.   I recommend furthering the “scope of practice” requirement defined in this manual to include: completion of ABA related CE’s; providing ABA under the supervision/guidance of a BCBA; formal training or CE's in assessment tools such as the VB-MAPP and ABLLS-R; and data collection and analysis).

There is a high risk of “ABA" supervision and services being provided by individuals who will choose or be forced to make ABA within their “scope of practice” without having sufficient training.   This will dilute and jeopardize the quality of "ABA" services provided to children and families.