Regarding the Exceptional Rate for ID Waiver Individuals, please accept the following public comment:

"Behavioral specialist" means a person who possesses any of the following credentials: (i) endorsement by the Partnership for People with Disabilities at Virginia Commonwealth University as a positive behavioral supports facilitator; (ii) board certification as a behavior analyst (BCBA) or board certification as an associate behavior analyst (BCABA); or (iii) licensure by the Commonwealth as either a psychologist, a licensed professional counselor (LPC), a licensed clinical social worker (LCSW), or a psychiatric clinical nurse specialist.

Number ii should read “licensure by the Commonwealth as either a behavior analyst (LBA) or assistant behavior analyst (LABA)”

In order to practice behavior analysis in Virginia, one must be licensed according to § 54.1-2957.16.  Also, the a in BCaBA is lowercase and stands for “assistant.”  When referring to a licensed person, the A is capitalized, but still refers to “assistant.”

Thank you for your consideration.