Add a provision to the regulations that will allow applicants for licensure who are certified by the BACB to practice under the guidance and supervision of an LBA while their licensure application is being processed. Currently certification by the BACB is the main requirement for licensure in the Commonwealth of Virginia. Applicants who are certified by the BACB have met all coursework standards, supervision standards and degree standards that are required to become licensed in the commonwealth of Virginia. Applicants have passed a rigorous exam that demonstrates their ability to competently practice ABA. Furthermore, applicants follow a rigorous ethical code whereby the applicant is responsible for adhering to the legal and ethical codes of their professional community. By allowing applicants to work under the supervision and direction of an LBA the commonwealth can ensure that applicants are providing services that “in the judgment of the licensed behavior analyst, the task or procedures can be properly and safely performed… and the delegation does not jeopardize the health or safety of the client.” The current practice of waiting for licensure hinders the access of treatment for clients and harms small business. Currently in some parts of Virginia potential clients are placed on waiting lists for up to 12 months. Allowing applicants to practice ABA under the supervision and delegation of an LBA will significantly shorten the wait time for potential clients. Furthermore, the current licensure process takes 3-4 months. This long waiting periods makes it difficult to recruit and hire BCBAs and BCaBAs who are not currently licensed by the Board of Medicine, thus negatively impacting the growth of small businesses.