The Qualified Applied Behavior Analysis Credentialing Board (QABA) has international accreditation through the American National Standards Institute (ANSI), the golden standard for accreditation.

I agree with the amended language to state that a "certifying body is an entity nationally accredited by ANSI or the NCCA". Many other states have this included in their language including New Jersey, Texas, and others.  If you include the name and certifications of the BACB, then QABA and its certifications should be named too, to prevent a monopoly.

QABA certifications and exams have gone through psychometric processes after being created by subject matter experts. Annual analyses of these exams are performed by a psychometrician to confirm reliability and validity. A rigorous annual surveillance (audit) is performed by ANSI to confirm QABA continues to meet the standards for continued accreditation. 

Greetings, I am the executive director of the non profit called the Autism Business Association that represents ABA providers nationally and we strongly support providers using accredited certifications with the BACB and QABA Board. National Accreditation is a fair and equally rigorous criteria which is recognized in most state licensing as the criteria. The licensing statutes are for NCCA and ANSI accredited ABA certifications. 

We support the state measure that is considering adding the QABA for their state license.

Global Institute for Behavior Practitioners and Examiners

Michael Moates, MA, QBA, IBA, LBA, QMHP-T/R

14 March 2022

SUBJECT: MEMORANDA FOR VIRGINIA BOARD OF MEDICINE ON BEHAVIOR ANALYSIS LICENSING

To whom it may concern:

My name is Michael Moates, and I am the individual who wrote to the Board of Medicine to request the rule change that is currently open for comment. I am also the founder of the non-profit organization the Foundation for Transformation DBA Global Institute for Behavior Practitioners and Examiners. I am writing you today to share my comments regarding the requested change in 18VAC85-150-50, and 18VAC85-150-60.  To start, the rule is illegal and contrary to the statute. According to 54.1-2957.16, the Board of Medicine “SHALL INCLUDE” the following language “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;” The boards current rules to not include this language as the statute legally requires. That means that the Board of Medicines rules is illegal under the statute. The same is true for the Board of Medicine Assistant Behavior Analyst rule.

But let’s move on from the fact that the rule is illegal and talk about the problems not allowing other organizations who are accredited creates for the practice of behavior analysis:

• Most professions of mental health if not all are regulated by the states and not external certification boards. The top 6 mental health fields are medicine, psychology, counseling, social work, marriage and family therapy, and chemical dependency. While some states may require an applicant to pass a board exam, certification is not usually a requirement of licensure. But the BACB will not allow individuals to take their exam unless they plan to get certified. Further, the BACB is a monopoly that has engaged in anti-competitive behavior through collusion with the Association of Professional Behavior Analysts.
• The Behavior Analyst Certification Board and Association for Professional Behavior Analyst have a history of advocating against allowing other organizations who are accredited to certify behavior analysis claiming that they are Autism specific, but the Behavior Analyst Certification Board posts data on its website showing the field of the practitioners it certifies. 72% of its certificants are practitioners in the field of Autism Spectrum Disorder and 10% choose not to identify. That leaves 12% of individuals to work in other fields. The BACB is a mainly Autism focused agency. This leaves very little room for individuals that want to work in changing behaviors of gambling, addiction, brain injury rehabilitation, correction and rehabilitation, and many other areas. It leaves no room for those interested in forensic behavior analysis, behavior analysis research, child abuse/welfare analysis, psychiatric/mental hospital behavior analysis, animal behavior, and many other areas. To put it into perspective here are the other fields tracked by the Behavior Analyst Certification Board:

Number of Behavior Analysts Certified by the BACB in the United States of America:

• The BACB is governed by a board of directors that would personally benefit from the restriction of behavior practitioners. Half of the board members own their own business or are in leadership positions at companies that would benefit from the lack of service providers because that would make them the go to choose.
• 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. They recognize their certified BCBA's and their approved VC Instructors. But a psychiatrist at a mental health institution engaged in the reduction of maladaptive behaviors cannot supervise technicians according to the organization.
• Their ally and lobbying arm the Association of Professional Behavior Analysts is claims to "Representing the interests of appropriately credentialed professional and paraprofessional practitioners of applied behavior analysis" but really what they mean is we are here to advance the promotion the Behavior Analyst Certification Board and we will fight to block any other types of certified practitioners. Their about us page reads like a propaganda advertisement for the BACB.
• The much more inspired Association for Behavior Analysis International seeks to work with and recognize various credentialing boards including the American Psychological Association, National Association of School Psychologists, Qualified Applied Behavior Analysis Credentialing Board, Behavioral Intervention Certification Council, and International Behavior Analysis Organization. The reality of it is the BACB has no intention of collaborating with the mental health community. They lack diversity shown by their closing off certification from the international community and unwillingness to work with other mental health fields. If we don't address this now it, they will continue to harm the field of behavior analysis.
• The BACB lacks diversity and is even getting worse at its standards for diversity. 85% of certificants are female with just over 13% of certificants as male. 0.38% are American Indian/Natives. 6.61% are Asian. 9% of Behavior Analysts are African American. 21% are Hispanic. This is a real problem for disadvantaged communities and people who prefer a male analyst in healthcare. The BACB used to certify analysts globally. The no longer do and are even cutting down on the international community. This means individuals who want to practice internationally will be unable to because they cannot under any circumstances become certified. 
• The BACB advocates against other organizations who seek to certify behavior practitioners but let’s look at who is in favor of adding additional organizations. These include the State of Hawaii Council on Developmental Disabilities, the Behavioral Intervention Certification Council, Hawai’i Psychological Association, Qualified Applied Behavior Credentialing Board, the Department of Defense, Hawaii Association of Marriage and Family Therapists, Center for Autism and Related Disorders, Autism Behavior Services on behalf of military families, and individuals concerned about providing supervision within their scope of practice. You can read 100’s of comments here and below that is the policy of the Department of Defense: https://www.capitol.hawaii.gov/Session2017/Testimony/SB739_TESTIMONY_CPH_02-24-17.PDF                                                                                                                                                                         

https://manuals.health.mil/pages/DisplayManualHtmlFile/2020-11-25/AsOf/TO15/C18S4.html

• The BACB and APBA will attempt to mislead you into believing that requiring certification from one organization is routine, but this is entirely inaccurate. What is typically required is the passage of an examination by an organization. Unfortunately, the BACB is not like most organizations that offer examinations because they do not allow individuals to take the exam based on the federal or state government requirements nor do they allow individuals to take the exams without becoming certified by their agency. The BACB differs in this from other organizations such as National Board for Certified Counselors, Association of State and Provincial Psychological Boards, Association of Social Work Boards, International Certification and Reciprocity Consortium, Educational Testing Service, and many others. These cover Counseling, Psychology, Social Work, and Chemical/Substance Abuse, and School Psychology. These agencies are the leaders in mental health, and they allow individuals who are qualified to take their exams without requiring certification. In the case of Advanced Nurse Practitioners, there are multiple boards that are accepted for APRN practice.

It is with this consideration I ask you to approve my request that individuals certified as behavior analysts by NCCA or ANSI be allowed to use that certification to apply for licensure.

Very Respectfully,

Michael Moates, MA, QBA, IBA, LBA, QMHP-T/R

Virginia Licensed Behavior Analyst

Adjunct College Professor

Doctor of Education Candidate

Student Health Advisory Committee 

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

Certified Accreditation Evaluator, Distance Education Accreditation Commission

I support the state measure that is considering adding the QABA for their state license.

Greetings, My name is Dr. Rosa Patterson and I am a Qualified Behavior Analyst certified with the QABA. I am licensed across states and would support and encourage the addition of the QABA to licensure in the state of Virginia. In doing so would allow individuals the option to pursue licensure with the state of Virginia who are certified with the QABA and increase access to care for those in need of our behavioral services. 

I'd like to encourage support for licensure for QABA.

Including licensure for QABA will help countless military families with behavioral health needs, and will prevent a monopoly for many behavioral services. 

Amending the verbiage for behavior analysis licensure to include "nationally accredited certifying body" is important to consumer. With national shortages and wait list of providers across the country, allowing more than one board to certify is critical to ensure care is provided to those that need ABA.  

Despite the rising prevalence of ASD (estimates at 1%> currently), there are still too few qualified providers, too few institutions providing the necessary course work, and too few credentialing entities to keep up with the exploding needs. Eliminating BACB's monopoly would open the practice to up to more qualified applicants with more diverse educational and professional experiences. We need to continue to hold practitioners to high standards of ethics, service delivery, and academic preparation, but we must debunk the myth that only institutions with "verified course sequences" know how to provide this preparation and that only the BACB knows how to assess applicants knowledge and proficiency for the practice. Just as there are multiple pathways to becoming credentialed in other professional fields, this should also hold true in behavior analytics. This would serve to expand exposure to the broader public about evidence-based practices, provide more qualified practitioners in the field, and more access to services, particularly to families in rural and remote communities.

Greetings, 

My name is Heather Smith. I am in strong support of adding the QABA to Virginia's approved providers. In doing so would allow individuals the option to pursue licensure with the state of Virginia who are certified with the QABA and increase access to care for those in need of our behavioral services.  We know the access to care is facing limitation challenges, and opening up the opportunity for additional Board Certified providers to license would greatly benefit those in need of essential medical services in behavioral health. 

This is to increase access for practitioners and foster the diversity, equity, inclusion initiative.

I am a teacher at our alternative discipline center and the growing expansion of challenges/disabilities exceed the narrow limit of BACB certification. As it stands now, there are such long wait lists and behavior can be used in a variety of fields. The diversity of qualified practitioners will allow for fields outside of Autism to received beneficial services.

I support the language of accredited bodies of behavior analysts.

It is fundamentally wrong for a single, specific certification body to monopolize the ability to obtain a license or practice in Virginia.   Other boards exist that have even higher standards (for example, the QABA board is accredited by ANSI), and should be allowed an even playing field.   Simply allowing the BACB to be the only certification board represents a guild mentality that should not work its way into Virginia regulations.

I share with you an email exchange between Ms. Hollie Benincosa, Executive Director of the QABA Credentialing Board, and myself, from December 2021.  I will gladly share the original emails with you at your request.  

From Ms. Benincosa, on 30 December 2021:

Hello Theodore,

Let me start by saying that I think that if Dr. Hoch is going to post emails between himself and Executive Director Benincosa that he should publish all emails and give the full context. He posted a single email to fit his narrative without giving context. 

But allow me to address something he/ Executive Director Benincosa stated:

• As QABA continues to grow both nationally and internationally, there is a great need for more coursework providers who offer the QABA coursework options to meet the demands of certification.
  • Mrs. Benincosa is absolutely correct. As each day goes by, the Behavior Analyst Certification Board becomes less and less diverse. They are pulling out of the international market, have less than 6,500 BCBA's that are male, less than 200 American Indians, less than 3,000 African Americans, and have nearly 40,000 White Behavior Analysts. (Behavior Analyst Certification Board, nd). Seen here: https://www.bacb.com/bacb-certificant-data/ The fact that a professor from George Mason University is advocating against diversity is deeply troubling to me.
• QABA has done extensive research and has multiple board that work in conjunction with approval of course sequences. As a Virginia Licensed Behavior Analyst and Qualified Behavior Analyst by the QABA, I can tell you first hand that there is a rigorous process by which they evaluate all coursework that is consider for both the coursework for licensure and coursework for continuing education. Seen here: https://qababoard.com/guidelines-for-abat-or-qasp-coursework-providers/ and here https://qababoard.com/become-an-approved-continuing-education-provider/
• Mr. Hoch asks about the number of individuals with expiring credentials. There are around 2,000 individuals certified and that is just QABA. My petition relates to any certified entities who are accredited to certify behavior analysts. There are an additional nearly 4,000 individuals certified by the Behavior Intervention Certification Council. Seen here: https://behavioralcertification.org/search-registry/ Part of the reason the number of credentials are expiring is due to the fact that the BACB has engaged in illegal anti-competitive behavior and formed a monopoly by lobbying across the United States. 
• Mr. Hoch asks in what countries/states, the QABA certification would meet the requirements. Keeping in mind that there are still roughly 20 states that do not license behavior analysts these states have QABA practitioners. The Military Healthcare Service and Tricare recognize QABA as meeting certification to practice ABA and that is the same for many other insurance companies as well. Seen here: https://manuals.health.mil/pages/DisplayManualHtmlFile/2021-03-26/AsOf/TO15/C18S4.html Also, to Mr. Hoch's point, there is an issue of the BACB holding a monopoly over the practice of behavior analysis but again 85% of their certified are Autism practitioners leaving very little room for supervision in other areas with some even less than 50 supervisors in the United States. Seen here: https://www.bacb.com/bacb-certificant-data/
• Mr. Hoch asks about independent practice of Qualified Behavior Analysts but if he had done his due diligence like most scholars and professors do, he would have looked at the QBA standards which state "QBA certificants are mastery-level interventionists with advanced knowledge of applied behavior analysis (ABA) and have training and experience with individuals with autism spectrum disorders (ASD). QBAs provide program planning, assessment, data analysis and direct-care oversight for all aspects of behavior programs. Additionally, QBAs supervise the direct-care instructional staff (ABAT/behavior technicians), mid-tier supervisors (QASP-S), and collaborative care providers." The statement he is referencing is likely something that was inputted prior to the QBA creation. Can be seen here: https://qababoard.com/qualified-behavior-analyst-scope/
• He ask about the individuals who offer coursework for certification. QABA does not require you to be a university to teach coursework for the certifications and neither does the BACB. In fact, the RBT (offered by the BACB) is a 40 hour sequence taught by a BCBA similar to a QBA. Seen here: https://www.bacb.com/wp-content/uploads/2022/01/RBTHandbook_220112.pdf The BCaBA/BCBA coursework is limited to institutions listed in CHEA (United States ONLY). But, many of the CHEA members are not "university programs" as Mr. Hoch put it. In addition, in order to be a QBA, you have to have a Masters Degree that meets the educational requirements of 270 hours of coursework. As an adjunct professor myself, I can tell you that colleges and accreditation boards allow individuals at the Masters level to teach college classes. The benefit here is to allow individuals who live outside of the United States to have more opportunities to learn. In addition, QBA's have much diversity in teaching in native languages across the world whereas the BACB does not. Here is an example of the what makes up CHEA membership: Academy of Hair Design. Seen here: https://www.chea.org/academy-hair-design There is no way that you can tell me an organization like this is more qualified to teach behavior analysis than a Qualified Behavior Analyst with 1500 hours of experience, a masters or doctorate degree, and has passed a rigorous psychometric exam. To Mr. Hoch's point, why does the BACB allow non-accredited institutions to offer academic coursework for credit?
• It is interesting that Mr. Hoch invokes the name of the "Association for Behavior Analysis" presumably the Association for Behavior Analysis International which recognizes various other credentialing boards including QABA, BICC, IBAO, and various mental health fields. So I believe that argument is invalid. You can see that here: https://www.abainternational.org/media/188058/abaimembershipform_2022.pdf
• Mr. Hoch claims the requirements to become a "QABA" presumably "QBA" is less rigorous so lets compare them side by side:

If Professor Hoch is going to comment it would be beneficial if he at least did some basic scholarly research. Also, various times through out his comments, he references on "becoming a QABA." This is not a credential and a basic reading of the website would tell you that. QABA is the organization. ABAT is the technician level. QASP-S is the Bachelor Level. QBA is the Masters level. 

I intend to file a Freedom of Information Act request to get the emails between Mr. Hoch and Mrs. Benincosa with George Mason University. I would ask the board to do the same or take Mr. Hoch on his offer to review all the emails. Manipulating emails by only posting one part of them to get what you want is not productive and it does not give the board a full picture. 

There is no threat to the commonwealth unless the board continues to allow the BACB's lack of diversity to be dictator. Mr. Hoch would benefit from less providers because more individuals would see him at his practice. Seen here: https://www.psychologytoday.com/us/therapists/theodore-a-hoch-reston-va/448748

It is also important to note that at George Mason University where Mr. Hoch claims to represent their certificate, the one that he claims is designated for BACB certification and therefor licensure is actually listed as a "15-credit non-licensure certificate." The university does not even recognize the course sequence as one that should lead to licensure. You can see that here directly in there catalog: https://catalog.gmu.edu/colleges-schools/education-human-development/school-education/applied-behavior-analysis-graduate-certificate/ and archived here: https://web.archive.org/web/20220122013237/https://catalog.gmu.edu/colleges-schools/education-human-development/school-education/applied-behavior-analysis-graduate-certificate/

I think it is important to note a few things as well:

1. Mr. Hoch does not hold a degree or certificate in behavior analysis. Seen here: https://cehd.gmu.edu/assets/files/cv/230.pdf
2. The pathway by which he became a Board Certified Behavior Analyst does not require a single course in behavior analysis. Seen here as he does not have a degree/certificate in behavior analysis: https://www.bacb.com/wp-content/uploads/2022/01/BCBAHandbook_220110.pdf
3. Mr. Hoch's degrees in psychology were prior to any licensure requirements for behavior analysis so he got grandfathered in but would not qualify today and will not qualify in the future. Seen here: https://www.bacb.com/wp-content/uploads/2022/03/BACB_March2022_Newsletter-220316.pdf
4. Mr. Hoch has Licenses in Virginia Applied Psychologist and Virginia Licensed Professional Counselor. But he would not meet the licensing requirements for either of these licenses. All in all, Mr. Hoch only has his license due to grandfather clauses.
5. He has made misrepresentations on his post and can't even identify the credential he is talking about.

His comments must be disregarded. 

Further the statute leaves no interpretation. The language in the statute "shall" be included in the rules.

There are also many issues of litigation to consider here:

1. Anti-trust monopoly.
2. EOC Violations.
3. Diversity Discrimination.
4. Finally, the challenging of the rule given the statute language.

Reference:

Association for Behavior Analysis International. (n.d.). 2021–2022 Individual Membership Application. Retrieved March 17, 2022, from https://www.abainternational.org/media/188058/abaimembershipform_2022.pdf

BCaBA Handbook. (2021). Behavior Analyst Certification Board. Retrieved March 10, 2022, from https://www.bacb.com/wp-content/uploads/2022/01/BCBAHandbook_220110.pdf

Behavior Analyst Certification Board. (2022a). BACB Newsletter - March 2022. BACB Newsletter March 2022. Retrieved March 17, 2022, from https://www.bacb.com/wp-content/uploads/2022/03/BACB_March2022_Newsletter-220316.pdf

Behavior Analyst Certification Board. (2022b, January). BOARD CERTIFIED BEHAVIOR ANALYST® HANDBOOK. BACB. Retrieved March 17, 2022, from https://www.bacb.com/wp-content/uploads/2022/01/BCBAHandbook_220110.pdf

Behavior Analyst Certification Board. (2022c, January). REGISTERED BEHAVIOR TECHNICIAN® HANDBOOK. BACB. Retrieved March 17, 2022, from https://www.bacb.com/wp-content/uploads/2022/01/RBTHandbook_220112.pdf

Behavior Analyst Certification Board. (2022d, January 28). BACB CERTIFICANT DATA. Retrieved March 17, 2022, from https://www.bacb.com/bacb-certificant-data/

Behavioral Intervention Certification Council. (2022). REGISTRY. Retrieved March 17, 2022, from https://behavioralcertification.org/search-registry/

Benincosa, H. (2020a, March 18). Become an Approved Continuing Education Provider. QABA. Retrieved March 17, 2022, from https://qababoard.com/become-an-approved-continuing-education-provider/

Benincosa, H. (2020b, July 21). Guidelines For ABAT, QASP, QBA Coursework Providers. QABA. Retrieved March 17, 2022, from https://qababoard.com/guidelines-for-abat-or-qasp-coursework-providers/

Benincosa, H. (2022, January 10). Qualified Behavior Analyst Scope. QABA. Retrieved March 17, 2022, from https://qababoard.com/qualified-behavior-analyst-scope/

BICC. (n.d.). BCAP. Retrieved March 17, 2022, from https://behavioralcertification.org/guide-to-bcap-registration/

Council for Higher Education Accreditation. (2022). Academy of Hair Design. Retrieved March 17, 2022, from https://www.chea.org/academy-hair-design

George Mason University. (2021). Applied Behavior Analysis Graduate Certificate. Catalog. Retrieved March 17, 2022, from https://catalog.gmu.edu/colleges-schools/education-human-development/school-education/applied-behavior-analysis-graduate-certificate/

Hoch, T. A. (n.d.-a). Theodore A Hoch. Psychology Today. Retrieved March 17, 2022, from https://www.psychologytoday.com/us/therapists/theodore-a-hoch-reston-va/448748

Hoch, T. A. (n.d.-b). THEODORE ANDREW HOCH Vita. George Mason University. Retrieved March 17, 2022, from https://cehd.gmu.edu/assets/files/cv/230.pdf

Laws & Regs. (2022). Virginia Board of Counseling. https://www.dhp.virginia.gov/counseling/counseling_laws_regs.htm

Laws & Regulations. (2022). Virginia Board of Psychology. https://www.dhp.virginia.gov/psychology/psychology_laws_regs.htm

Membership Application. (n.d.). Association for Behavior Analysis International. Retrieved March 10, 2022, from https://www.abainternational.org/media/188058/abaimembershipform_2022.pdf

TRICARE Operations Manual 6010.59-M, April 1, 2015. (2021). Department Of Defense (DoD) Comprehensive Autism Care Demonstration (ACD). Retrieved March 17, 2022, from https://manuals.health.mil/pages/DisplayManualHtmlFile/2021-03-26/AsOf/TO15/C18S4.html

The QBA certification does not meet the standard for a Licensed Behavior Analyst in the state of Virginia.  The current BCBA program standards--especially with regard to accruing supervised fieldwork--should be significantly more rigorous than they are in order to adequately protect consumers.  A move to less stringent requirements is a step in the wrong direction when there is still work to be done to move practitioners in Virginia toward compassionate, thorough, and effective behavioral service delivery.

A public and non-profit credentialing organization is essential to the integrity of Behavior Analysis as a discipline. The Behavior Analyst Certification Board requires the highest standards of its certificants to both obtain and maintain certification. Licenses are issued for the protection of the clients, consumers, students, and stakeholders that we serve. Any modification to the standards of licensure would threaten that protection.

To be honest, this comment is not even worth the board's time. Mrs. Salzman doesn't attempt to address any concerns with adding the QBA to the boards requirements. She attempts to use shock words without any citations or facts to scare the Board of Medicine into not adding the QBA or following the LEGAL STATUTE. This is required by law and is not open for negotiation. 

The QABA is a public board that is open to review by any public entity. It is accredited by ANSI who reviews its entire process for awarding certifications. It is so interesting that she claims the BCBA requires "high standards" that the QBA does not have when she does not attempt at all to lay these standards out for the board to review.

She says "Any modification to the standards of licensure would threaten that protection." Presumably she is referencing the BCBA standards. It is important to note that the standards are constantly changing. The BACB changed its standards as recently as January 2022 of this year. Further, let's talk about what is not healthy or safe for clients. The BACB has already announced its standards for certification for the year 2032 over 10 years from now. How is that healthy or safe when we don't know how the science of behavior analysis will evolve? That is an unsafe approach. The board should really consider wether this is the right approach. See: https://www.bacb.com/wp-content/uploads/2022/03/BACB_March2022_Newsletter-220316.pdf

"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."

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

"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."

The federal government recognizes QABA and BICC as certification boards of behavior analysis.

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

"The BAMLA defines who a professional behavior analyst is, categorizing the knowledge, skills, experiences, and abilities. In addition, it clarifies that a behavior analyst is a person who functions within a particular scope of practice. Finally, it helps to define the profession within a scope of practice that highlights the uniqueness of applied behavior analysis. The BAMLA further specifies the common commitments to expect from a behavior analyst in adherence to an ethical code and generally accepted behavior analytic positioning papers."

“However, for a number of logistical reasons, the BACB can only enforce adherence to the Professional Disciplinary Standards, (not adherence to the Guidelines for Responsible Conduct) and it relies heavily on information from local responsible sources in reviewing allegations against certificants” (BACB). Thus, BCBA will not investigate most forms of impairment, for they are ethical issues."

See: https://www.abainternational.org/media/177719/pritchard.pdf

Something else that MUST be noted is that there appears to be no research on the BACB certification requirements outside of those who are certified by the BACB. Thus, all research completed is biased and must be evaluated for its implicit bias. 

Also, for the record, I personally reached out to the BACB to seek their help in making sure that the standards represent everyone not just BCBA's and was ignored. 

There are many complaints with regards to customer service because the BACB is not interested in engaging with its community but rather they seek to dominate the industry.

References:

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

https://www.abainternational.org/media/177719/pritchard.pdf

Dorsey, M. F., Weinberg, M., Zane, T., & Guidi, M. M. (2009). The case for licensure of applied behavior analysts. Behavior analysis in practice, 2(1), 53–58. https://doi.org/10.1007/BF03391738

I was directed to this form by my organization, and when reading through the comments I must say that this is akin to "insert unsavory word here" measuring contest.  Personally, it isn't about which organization is handing out certifications, if singular or multiple - that's not important.  What does matter is the consumers we serve, and for better or for worse, the BACB is leading the industry (at least in America), in terms of gold standard.  That being the case, if QABA can demonstrate equivalent or superior standards, with evidence, then I see no qualms about also allowing them to practice within the state of Virginia.  However, that's not to say that other boards won't try to do the same as I'm sure each of them purports a certain gold standard.

We do have a shortage of practitioners, and the consumers outnumber us a lot.  Allowing other individuals with equivalent education/experience only expands our reach to our service population.  I do not think however, this is something that can be voted on within a townhall meeting.  There needs to be a review of processes and standards to ensure that QABA reaches the bar set forth by the industry. 

To the individual who wrote about the lack of diversity within the BACB, I must say that I was not aware of this and I’m quite surprised by this.  I’m even more curious to see the metrics of their exam and whether it is standardized from a stats perspective.  I very curious about the representative sample they may have used.  Then again, there several factors that may account for this discrepancy.  But enough on that tangent. 

Thanks -

Leozihno

I wholeheartedly wish the goals for licensure were focused on does each certification meet the need for the field. Unfortunately, the BACB and its lobbying arm the APBA, are constantly making derogatory remarks regarding other certification boards including QABA and BICC. These statements require a factual based response and sometimes to defend we must show why the other board would not be a good fit as a standalone board. 

The goal should be a collaborative community by which various entities participate and work together. Until the BACB recognizes, like Virginia, that Psychologists, Psychiatrists, and other medical/mental health supervisors are qualified to provide supervision we are going to continue running into this problem.

The BACB is a closed off wall and they do not collaborate well with others.

I do disagree with anon when it comes to the statement about reviewing the standards of QABA or BICC for that matter. That has already been done. ANSI and NCCA have certified that QABA and BICC, respectively, meet the standards to issue certifications. They also meet various other administrative, structural, financial, etc... requirements.

To show anon about the diversity, here is the attachments from the BACB on BCBA's:

You are right, there is a need for more behavior analyst in the field to support the consumers. Just like there is a need for more teachers and doctors. However, the answer isn't to set the standards lower so anyone could do the job. Behavior Analysis is a complex field and we need our best and brightest contributing. If we set our standards lower, we may meet the goal of having more BA, but at what cost? 

No one has provided a single shred of evidence that the standards are lower. You guys keep saying that. I say to you. Prove it. Cite empirical evidence. Cite research. Cite anything. We have shown that the BACB is not diverse and does not represent the population. We have done so through the BACB's own data. You guys come here and treat us like less. You dehumanize us and you provide no evidence. Show the board. Show the board what you are saying. If you can't, kindly sit down.

In addition, just because some standards may be different does not make them deficient. The BACB cannot create rules that will work across all 50 states. It is simply impossible. Every state has its own rules on scope of practice and supervising providers. The BACB has no way of adapting unless they create different rules for every state.

The board should disregard all comments that are not supported by evidence and research. These statements of less or deficient are not based in fact and frankly, the law is clear on what the requirements are. Period.

To the Board of Medicine:

Have you noticed how everyone who is commenting against this action is doing so anonymously? That should be a major RED flag. 

Good Morning,

I am absolutely in favor of additional credentialing boards being added as long as they meet the following criteria: 1.) are a not for profit organization, 2.) are not disability specific (this is extremely important since we do serve a diverse population of individuals with ABA services throughout the state), and 3.) as long as it meets or exceeds the rigor of the BACB standards for certification.

I agree with certain aspects of the statement made by Crystal Peterson Barker. Here are some things I think are important to address.

First, I do not agree with the non-profit language. There are many for-profit institutions that provide valuable training, education, etc. I also believe this language is unclear. Is she referencing not-for-profit, non-profit, non-government-organization, state non-profit, or 501(c)3 exempt organizations? Many of the colleges that teach ABA programs that are approved by the ABAI and to that point they are not less, they are accredited and are used by the BACB themselves.

Second, I agree wholeheartedly with the language about not being disability specific. I think this is an area where the BACB fails. As previously stated, nearly 80% of those certified by the BACB are Autism Practitioners and that leaves very little room for others to get supervision in areas such as gambling, forensic analysis, sex addiction, ADHD, animal behavior, etc.

Finally, I wholeheartedly disagree with the last statement. The BACB is not the one who should determine what the standards are for behavior analysis. The federal government gave this job to the states in the US Constitution. Further, the BACB has many deficiencies as previously stated. These include lack of provider types, lack of diversity in gender and race, and lack of supervision by state-approved providers. 

The state should determine the standard with input from various sources including consumers of behavior analysis, various certification organizations, educational entities, independent behavior analysts, and accreditation boards ANSI and NCCA.

I have read and considered the proposed changes described and the follow-up arguments posed, and I disagree with the conclusion that the path to licensure as a behavior analyst in Virginia should be modified in the manner the petition describes.

The key argument, as I understand it, is that the Board should expand the qualifying components required to become licensed in Virginia and that they should do this by expanding the certification requirements to include other credentialing bodies related to the field of behavior analysis.

The process of certification by the BACB as a BCBA/BCaBA and licensure as an LBA/LaBA in VA is rigorous, I agree. But I believe the best means to ensure that we can serve the communities and individuals (no matter the application of the science) with the highest quality of care and quality and mitigate the risk of harm is to ensure that these criteria remain rigorous. 

If we, as representatives of the field on both sides of this discussion, feel that the current process towards licensure as a behavior analyst or assistant behavior analyst in Virginia should change but cannot agree which certification or credentialing body best defines the minimum criteria then, I recommend the Virginia Department of Health Professions – Board of Medicine launch a data-driven investigation and adopt the most rigorous standards and examination criteria to determine eligibility for licensure.

Thank you for considering my opinion,

C. DuVall

I think it is extremely important to act in an ethical way. Treating clients with dignity and respect is something that we should strive for. Children are not lab rats to be tested on, nor are they to be treated with disrespect based on disability.

I think it is important for the board to consider this when evaluating credentials it approves as alternatives. 

According to Wikipedia, "The Judge Rotenberg Center (JRC, founded in 1971 as the Behavior Research Institute) is an institution in Canton, Massachusetts, United States, housing people with developmental disabilities, emotional disorders, and autistic-like behaviors. The center has been condemned for torture by the United Nations Special Rapporteur on Torture. The JRC is known for its use of the graduated electronic decelerator (GED), a device that administers electric shocks to residents through remote control. The device was designed by Matthew Israel, the institute's founder."

The JRC Continues to shock students as of today 28 March 2022.

The Board of Directors is made up of:

Henry Slucki, Ph.D. 

Thomas Brady

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

Richard Malott, Ph.D., BCBA-D

Josh Pritchard, Ph.D., BCBA-D

Jeffrey Sánchez

Ronald Van Houten, Ph.D.

W. Joseph Wyatt, Ph.D.

On Staff:

Nathan Blenkush, PhD, BCBA-D

It is important to note that the BACB is aware of these allegations and yet at least 3 board members remain and at least 1 on staff remain. I don't know about the Virginia Board of Medicine but I certainly don't condone torture and I think there should be alternatives in the field.

The Board needs to watch these:

https://www.youtube.com/watch?v=PUhPMNdnOW8

https://www.youtube.com/watch?v=XV5D2ZL0icM

This is not who we are. It is not who we want to be. It is a human rights violation. The BACB has taken no action against the individuals allowing this to happen. Alternatives must be put into place to protect the human rights issues being faced.

While conducting research to assist me with forming an opinion on this serious matter, I found that the QABA website did not address several important matters, yet those same items are easy to locate on the BACB website. Here are several examples:

The petitioner mentioned a concern with a lack of diversity. BACB certificant data and demographic data can be found at the following site:

https://www.bacb.com/bacb-certificant-data/

And yes, the field is dominated by white females, but I would like to point out that is also true for many care-taking type professions like education and nursing. This is an issue that needs to be addressed at a different level than this forum allows. I was not able to locate any demographic information on the QABA website - so how are we to know that they are any more diverse?

https://www.census.gov/newsroom/stories/certified-neruses-day.html

BACB information regarding ethics violations can be found here:

https://www.bacb.com/services/o.php?page=100180

It is important for the safety of those we support to have total transparency and accountability - the BACB makes it easy to access the ethics codes, any violations, and support with reporting violations. I could not locate ethics violations on the QABA website. There is a simple form for complaints found here:

https://qababoard.com/wp-content/uploads/QABA-Complaint-Form.pdf

However, there is nothing specific about ethics violations for those unfamiliar with the codes to assist them with reporting. The ethics codes are found in the packet for certification - but that made it very difficult to locate and again, how would a person unfamiliar with the website like a parent locate them and determine what information the need to determine if a violation had occurred?

To be clear, I am not against the QABA - I am only pointing out inconsistencies and misinformation in the claims made by the petitioner. This matter should not be taken lightly, and I hope more rigorous research is conducted before a final decision is made.

I was going to be done responding to people and just share information but since another anonymous user (again should be a red flag for the board) addressed me I would like to respond.

First the respondent has many inaccurate claims.

Again, trying to tell other organizations they have to be exactly like the BACB will lead to the same problems the BACB has. But moreover, had the respondent looked they would have found that QABA has an entire operation in Africa working with people of color to get certified as practitioners. Can be seen here: https://qababoard.com/pages/qaba-in-africa/

QABA has an international standards committee made up of both men and women of color. See here: https://qababoard.com/pages/qaba-international-standards-committee/

The website is offered in 13 different languages supporting people around the world. Same with the coursework and exams. They are offered across the world to diverse backgrounds including both men and women of color. 

The represent: The United States, Spain, Philippines, Africa, Nigeria, Ecuador, South Korea, India, Brazil, Czech Republic, Peru, Japan, Pakistan, Egypt, UAE, Poland, Kenya, and Saudi Arabia.

The BACB is pulling out of the international market making it more White Americans. Don't allow yourself to be fooled by misinformation. The BACB is doing nothing to fix this problem and it is a problem for the board because if the law gets struck down because the BACB discriminates against people of color that will cause issues for the board. See: https://www.bacb.com/global-certification/.

Further, the BACB is not attempting to fix the problem at all. They are actually making it more likely that it will be worse by pulling out of the international market. Organizations that represent other mental health fields like the NBCC have organizations across the world like EBCC in Europe. See: https://europeanbcc.eu/. There are US Citizens abroad to including military families, international students, and member of the families of the State Department who should be able to get certified while their families are serving our country.

Anon really does not want to talk about ethics while the BACB allows individuals that it certifies to send electric shocks through children in an attempt to change their behavior.

Also, had anon even done basic research he would have found the following resources on the QABA website. See:

https://qababoard.com/code-of-ethics/

https://qababoard.com/wp-content/uploads/Code-of-Ethics-03-25-21.pdf

https://qababoard.com/wp-content/uploads/QABA-Complaint-Form.pdf

Ultimately the QABA Board does not have the jurisdiction to prosecute such claims and so that would be left to the states or the federal government. It does seem odd that someone on behalf of the BACB did not address my previous statement about the electric current the BACB allows to go through the bodies of kids.

Traditionally, the individual wanting to file a complaint would do so with the Board of Medicine as they have the appropriate jurisdiction. They have an entire form dedicated to it here: https://www.dhp.virginia.gov/PractitionerResources/Enforcement/

All anon had to do to locate that content was go to the about us section of the website. They took 30 seconds so they could write a negative review here.

Here are some other things to note:

ANSI accreditation - https://anabpd.ansi.org/Accreditation/FileServer.aspx?Dirtype%20=%20Attachment&Id=182217&File=QABA%20Certificate.pdf&type=cert

https://anabpd.ansi.org/Accreditation/credentialing/personnel-certification/AllDirectoryDetails?&prgID=201&OrgId=2168&statusID=4

They had to meet these requirements: https://www.ihf-fih.org/resources/pdf/Conformity_assessment-General_requirements_for_bodies_operating_certification_of_persons.pdf

All in all. Another misguided individual attempting to hide behind the keyboard and attack other entities. It has no basis and Virginia law is clear. They clearly spend 30 seconds on the QABA website and then started writing.

The trend appears to continue, in that the petitioner finds it necessary to respond to reasonable comments and concerns by citing “inaccurate claims” and the like, however, fails to address the essence and substance of the comments themselves.

Here’s just one example:

Previously, the petitioner expressed concerns that BACB certificants, overall, lack diversity. A recent comment pointed out that QABA does not include measures of diversity on its own website for their certificant base. Instead of addressing this, the petitioner instead claimed that “QABA has an entire operation in Africa working with people of color to get certified as practitioners” and then shares a link. That may be so, but when you access the link, you land on a page of with very little information and no specifics. In addition, the “Learn More” button on the page merely links you back to the different certifications offered by QABA, nothing more.

The petitioner then argues that “QABA has an international standards committee made up of both men and women of color.” While that sounds great, how does that specifically address the fact that the petitioner continues to claim that BACB certificants, overall, lack diversity—all the while fails to produce QABA certificant data on diversity?

The bigger point here is this: Like several previous “responses,” it is difficult to make sense of what’s being presented because they are replete with logical fallacies. More often than not, we are seeing multiple attempts to invalidate a point by presenting nonsymmetrical data, strawman arguments, or information that is completely off-topic. 

I am done replying to all of these anon users who are to scared to put their name to their posts. My hunch is they are all BACB certified. I am not going to engage in whataboutism. I brought up concerns and they are trying to turn the tables.

I can tell you that QABA or BICC does not condone shocking minor children for maladaptive behaviors like the BACB.

The BACB is not the first organization who has tried to write itself into the law.

A similar thing is happening right now in the Commonwealth Board of Counseling where the CACREP accreditation board is trying to make itself required for licensure and of 134 Comments not 1 supports the the restriction of one certification board.

Just like with the BACB, CACREP similarly thinks that it is better than everyone else and want to block off providers during the COVID 19 crisis.

See:

https://townhall.virginia.gov/L/comments.cfm?stageid=8872

SEE THIS AMAZING PIECE OF WORK TO:

328 VOTE AGAINST ONE SINGLE BOARD.

https://townhall.virginia.gov/L./comments.cfm?stageid=7071&sort=change

Ref:  Petition for Rulemaking: Certification for licensure as practitioners of behavior analysis: Regulations Governing the Practice of Behavior Analysis (18 VAC 85-150)

Dear Board Members,

As the Board considers the petition for certification for licensure as practitioners of behavior analysis, the ANSI National Accreditation Board (ANAB) would like to provide information relating to the international/national standard for assessing the competence of personnel certification bodies and the accompanying accreditation requirements.

The ANSI National Accreditation Board (ANAB) is an affiliate of the American National Standards Institute (ANSI) and the largest multi-disciplinary accreditation body in the western hemisphere, with more than 2,500 organizations accredited in approximately 80 countries. ANSI oversees the creation, promulgation, and use of thousands of norms and guidelines that directly affect businesses in nearly every sector: from acoustical devices to construction equipment, from roads and bridges to energy distribution, and healthcare. ANAB accredits personnel certification bodies based on the international standard ISO/IEC 17024: Conformity assessment- Requirements for bodies operating certification of persons. This standard is also adopted as an American National Standard. ANAB has accredited over 225 programs under this standard including several in the healthcare sector such as those offered by the American Board of Multiple Specialties in Podiatry, ASCP Board of Certification, Inteleos, Lymphology Association of North America, National Board of Certification in Occupational Therapy, ABRET Neurodiagnostic Credentialing and Accreditation, AONN Foundation for Learning, and Academy of Lactation Policy and Practice. A complete listing of all accredited programs can be found at https://anabpd.ansi.org/Accreditation/credentialing/personnel-certification/ALLdirectoryListing?menuID=2&prgID=201&statusID=4

The ANAB accreditation process – itself based on an international standard (ISO/IEC 17011: Requirements for accreditation bodies accrediting conformity assessment bodies) – is extremely rigorous and ensures that only those organizations that meet the stringent requirements under the standard are accredited. Independent third-party accreditation is an “accountability mechanism” to ensure the quality and legitimacy of organizations offering credentials. ANAB accreditation provides an added layer of legal defensibility against invalid claims. The accountability and transparency built into the ANAB process support conformity assessment attestations and can result in reduced liability insurance.

Benefits of Accrediting Credentialing Organizations to ISO/IEC 17024 

Accreditation is a key component of an effective standardization system, assuring industry and governmental decision-makers that credentialing organizations are competent and their results can be trusted. The standard was developed by the International Organization for Standardization (ISO) based on the need for public protection by establishing that individuals have the required competencies to perform

their job. The standard has been recognized by several U.S. federal agencies as a critical requirement for personnel certification bodies that offer certification in areas related to public health, environment, and

national security. ANAB is a signatory to the International Accreditation Forum (IAF) Multilateral Recognition Arrangement for ISO/IEC 17024, which brings global acceptance of its accreditation program,

The following are the key requirements under the standard: 

• Credibility: The certification examination must be fair, valid, and reliable. A valid test correctly measures whether an individual has the necessary competencies for the job. Validity is an indicator to establish that the process measures what is intended to measure. Exam reliability shows that the test measures a person’s abilities in a consistent manner. 
• Impartiality: The certification body should establish its structure, policies, and procedures to ensure impartiality and objectivity and manages conflict of interest arising from certification activities. 
• Independence: The certification functions should be independent of training to ensure that confidentiality, information security, and impartiality are not compromised. 
• Transparency: The certification body is required to have an active complaints process to resolve complaints against its activities as well as complaints against individuals that it has certified. 
• Accountability: As per the standard, the certification body should have a due process for taking away the credential for unethical or incompetent behavior. 
• Balanced representation of stakeholders: The standard requires that the certification body should involve key stakeholders in making certification-related decisions. Additionally, subject matter experts (SMEs) should be involved in creating the certification scheme requirement based on a valid job or practice analysis. 
• Certification scheme: The standard requires a certification body to demonstrate that, in the development and review of the certification scheme the following are included:

a) the involvement of appropriate experts;

b) the use of an appropriate structure that fairly represents the interests of all parties significantly concerned, without any interest predominating;

c) the identification and alignment of prerequisites, if applicable, with the competence requirements;

d) the identification and alignment of the assessment mechanisms with the competence requirements;

e) a job or practice analysis that is conducted and updated to:

• identify the tasks for successful performance;
• identify the required competence for each task;
• identify prerequisites (if applicable);
• confirm the assessment mechanisms and examination content;
• identify the re-certification requirements and interval.
• Other requirements: The standard is very comprehensive and covers all aspects of certification including test security, recertification, resource requirement, confidentiality, the competence of personnel involved with the certification activities, financial requirements, and use of certificates and logo marks. Further, the certification body should develop a management system for continual improvement of its certification program. 

To ensure that the credentials they promote meet industry and quality standards, many federal and state agencies rely on ANAB accreditation. Some examples include: 

• Virginia Department of Health as specified in 12VAC5-421-55 of the Virginia Food Regulations requires ANSI/ANAB accredited Certified Food Protection Manager (CFPM).

• ANAB’s 17024 accreditation is the only program recognized by the U.S. Department of Defense (DoD) under DoD 8570 for Information Assurance. 
• ANAB’s 17024 accreditation program is recognized by the White House National Science and Technology Committee on Forensic Science as meeting the highest standard in accreditation. 
• ANAB’s 17024 accreditation is recognized by the U.S. Occupational Safety and Health Administration (OSHA) for crane operator certification and by New York, West Virginia, and California in licensing requirements for crane operators. 
• ANAB’s 17024 accreditation is a requirement for licensing of elevator inspectors in several states. 
• ANAB’s 17024 accreditation is recognized under the North American Securities Administrators Association (NASAA) model rule on the use of senior-specific certifications and professional designations. 
• ANAB’s 17024 accreditation is recognized by the U.S. Department of Energy (DOE) as the accreditor under the Better Building Workforce Guidelines. 
• The U.S. Department of Health and Human Services selected ANAB as the approved accreditor for its Health Information Technology (HIT) Certification Program.

ANAB has accredited the QABA Credentialing Board under ISO/IEC 17024 for (a) Applied Behavior Analysis Technician, (b) Qualified Autism Services Practitioner- Supervisor (QASP-S) and Qualified Behavior Analyst (QBA). These programs have demonstrated compliance with the stringent requirements of the standard.

We support the petition to amend the regulation to accept certification from an entity that is nationally recognized to certify practitioners of behavior analysis. We recommend ANAB be recognized as an accreditation body for the licensing of Applied Behavior Analysis and the QABA certification programs accredited by ANAB be included in the licensing of Applied Behavior Analysis. 

Please feel free to contact me for any additional questions or clarification.

Sincerely,

Vijay Krishna, MBA, ED.D.

Vice President, Credentialing

ANSI National Accreditation Board

1899, L Street Suite 1100, Washington DC 20036.

I disagree to add QABA. The BCBA helps make sure that BCBA's, BCaBA's, and RBT's are practicing within their scope and that they are providing ethical services to their clients. ABA has a bad rap from the past and with the help of the BACB it is helping change the way people look at ABA therapy. We need to continue to on providing ethical practices of ABA with clear guidelines and qualifications for everyone that is practicing ABA.

Breakdown of last response:

I disagree to add QABA.

The BCBA helps make sure that BCBA's, BCaBA's, and RBT's are practicing within their scope and that they are providing ethical services to their clients. - If this statement is true, why does the BACB continue to allow certified members who shock and electrocyte children with Autism.

ABA has a bad rap from the past and with the help of the BACB it is helping change the way people look at ABA therapy. - Really? Again, shocking minor children. If that is the change you want then you would literally be a sadist.

We need to continue to on providing ethical practices of ABA with clear guidelines and qualifications for everyone that is practicing ABA. - Thank you for making me laugh today. The BACB has no idea what ethics are. They literally certify people who shock children.

Here is the video: https://www.youtube.com/watch?v=-aUIhWmDPeI

Here are the BCBA's: https://www.judgerc.org/board-of-directors.html

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.

Nathan Blenkush, PhD, BCBA-D

It’s curious that six people affiliated with QABA, including its owner, have posted on this page in support of the QABA position. Yet none of them have disclosed their relationship with QABA. Interesting business ethics.

Andrew Patterson, Executive Director of the Autism Business Association, owns the
shell corporation (Elevated Autism Services Team LLC) that owns QABA

Ira Heilveil – filed paperwork in California for Elevated Autism Services Team

Rosa Patterson – wife of QABA owner, Andrew Patterson

Eric Linder – current QABA board member

Jessica Swanson – current QABA board member

Valencia Church-Williams – current QABA board member

I think that an example of "transparency" would be not posting derisive comments about others anonymously.

I am a public official with several public social media accounts and a website that is heavily trafficked. I am not difficult to find and my intentions are difficult to discern. I am also a proud member of QABA board and it was never a secret. However, my posting included my own thoughts and opinions and do not necessarily reflect the stance of the QABA board. This is why I did not mention my affiliation in the post.

"Anonymous", should you have other questions/comments/concerns please feel free to reach out to me directly at vchurchwilliams@thebridgeconsultinggroupllc.com.

Breaking News - Anonymous Calls Out People Who Use Their Name While Being Anonymous

I support anyone who comments anonymously! The evidence in the comments is clear. If you comment, either way, you will be attacked. 

I also DO NOT support allowing this change to occur in Virginia. We must protect the consumers. 

... that consumers will be hurt by being diverse, allowing collaboration, and opening up the field to those who are qualified.

I do not support the QABA licensure.

This is not a vote... your "vote" does not matter. The purpose of this form is to give facts and opinion so the board can determine what is appropriate. 

I want to start off by saying that the following is my opinion as an individual behavior analyst, and as such, only represents that, as is the purpose of legislative comment forums. My comments are entirely directed to the board that will review this petition. If someone feels that it is his/her/their best option to attempt to correct my personal opinion, or that somehow my personal opinion as a behavior analyst is threatening, then I am truly sorry that that is the position that that individual feels that they are in. Providing behavioral health services to people in need should never result in practitioners needing to be on the defensive/offensive. We're able to be most effective when we work together. It is clear to me that there are many passionate voices willing to speak on this topic, as there should be. No petition or legislative matter should be met with ambivalence. I also appreciate any issue that could push behavior analysis further and occasion self-reflection to improve our field.

I am incredibly disheartened by a few things (not all, but many) regarding this petition and the process. Primarily, the divisiveness and cutting down of one another as professionals and even people, in a public forum. Regardless of one's opinion on the content of this petition, I am concerned about the commentary being a reflection of our field and the practitioners therein. I wonder what members of the public may be turned off from all of us behavior analysts, who already may have a reputation for not working together for the common good outside of ABA.  I am also concerned about the underrepresentation of individuals/families receiving services in public comment forums. And finally, there are ALWAYS things to improve on, for every board, certifying entity, etc., because people are imperfect, and we are the ones who make decisions.

I admit to not being as familiar with the QABA as I am with the BACB, so let me preface with that. I also wasn't as concerned about the petition before reading this forum as I am now. I would like to think that I approached from a position of wanting to learn more, and trying to figure out where the opposition is coming from, while being as objective as possible (knowing there's an intrinsic bias as I'm certified by the BACB). From reading the QABA code of ethics, it's evident that there are many similarities between the BACB code of ethics. I started there because it's often the lifeblood of an organization, and an organization's values can be made clear by reading what guides the practice of the certificant participating in that credential. What I saw was a great start to an ethical code (very similar to previous iterations of the BACB's code of ethics and professional conduct). I wasn't able to (upon first glance) see many differences in intent. When I looked for how data was used and incorporated, I saw an underrepresentation of reliance on data and function to drive decision making. I also didn't see any information regarding assent, and there wasn't any information that I could spot other than in the research section that spoke to obtaining informed consent from the client/guardian, and/or what to do if the individual receiving services declines. Additionally, with an international entity, some of the aspects of the ethical code may conflict with country laws, but there is no guidance to say which should be followed. For example, there are currently 71 countries that criminalize homosexuality/bisexuality, and 15 that criminalize gender fluidity/trans expression, yet the code of ethics gives no guidance on how to balance that and anti-discrimination policies. 

https://www.humandignitytrust.org/lgbt-the-law/map-of-criminalisation/

The other component that is concerning to me is the limitation of the code of ethics and QABA credential to apply to treating "individuals with autism spectrum disorders and related disorders." If a practitioner with a QABA credential were to decide to work with animal training, or informing public safety policy, what would prevent that person from doing so if under the same license? It would then fall to the public/employer to determine the appropriateness of that practitioners experience given the role that he/she/they are in, which takes away the regulation and protection inherent in licensure for the public. One could say that if that practitioner is practicing within his/her/their "scope," that it shouldn't matter, however, the QABA code of ethics (per the introduction), applies to practitioners working with "individuals with autism spectrum disorders and related disorders." 

After some poking around, I was able to find information about what happens if a complaint is made on the website. If I was a consumer, I would have difficulty being able to figure out how to use the QABA board for protection using the complaint process, especially because the complaint form is only to be used between certificants, and the website states that complete information up to and including the complaint-filer's certification number would need to be submitted. Though I truly appreciate the intent to expand services throughout the world given how lucky we are in the United States to even be having this conversation, how is the complaint made by individuals worldwide who can't read or speak other languages? Who is explaining all of this to them so that they benefit from protection as well? What if the person needing to submit a complaint (the purpose of any credentialing board) is a member of the public and is unable to bring issues to the attention of the board? How are cultural norms identified and incorporated, and ensuring that women and children, LGBTQ+ youth, and others who may be disempowered in this country and across the world are able to be protected from unethical practices? I couldn't easily find the infrastructure around any of these questions (which is the lens a consumer would use), which worries me. Keeping ABA practice within the US is not the best course of action either, to be sure. I would, however, want to ensure first that no harm could possibly be done to those impacted by ABA services, especially if one is an ambassador of ABA throughout the world.

I am all in favor of having credentialing that is the optimal balance of protection for consumers, and easier access to services for individuals who would benefit from them, but not if there aren't enough protections in place for the individuals that ABA impacts. I worry that it may be a little too hasty and to narrow a focus for the QABA to be included in certifying entities for licensure in Virginia before some of these questions have thorough and easy to find answers.

Thank you for your consideration of my comment.

No organization is perfect both have flaws. But both the BACB and QABA have high standards and are accredited. We should let them both practice. They have meet the requirements of the accreditation boards and have 3rd party review by reputable NGO's.

I received a letter from the attorney of the BACB in the last few days.

When confronted about the BCBA's certified running the center that shocks children, the BACB says "The BACB also does not have jurisdiction over service delivery agencies." So I guess the BACB will allow the leaders shocking children to stay certified in violation of their own ethics code.

I am happy to send this email to the board to review.

Did you know that the BCBA has given up discipling behavior analysts... see:

https://www.bacb.com/services/o.php?page=100180

The entire purpose of the BACB was to provide competent behavior analysts but they don't even enforce their own ethics code anymore with the exception of line technicians. 

If they will not punish someone for leading an organization shocking those with Autism where is the line?

Please check facts. The webpage cited by the petitioner as showing that the BACB does not enforce its ethics code with anyone except RBTs actually shows just the opposite.