Department of Health Professions
Board of Medicine
Regulations Governing the Practice of Behavior Analysis
[18 VAC 85 ‑ 150]
Public Petition for Rulemaking: Certification for licensure as practitioners of behavior analysis
CLOSED Opened on 3/14/2022 and Ended on 4/13/2022
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123 comments
| Comment Title | Commenter | |
|---|---|---|
| Give Patients the Right to Choose and Raise the Standard By Adding Competition | Prof. Michael Moates, MA, QBA, LBA, LMHP | 4/14/22 12:02 am |
| Give Patients the Right to Choose and Raise the Standard By Adding Competition | Prof. Michael Moates, MA, QBA, LBA, LMHP | 4/14/22 12:01 am |
| Comment | Christy Evanko | 4/14/22 12:00 am |
| Give Patients the Right to Choose and Raise the Standard By Adding Competition | Prof. Michael Moates, MA, QBA, LBA, LMHP | 4/13/22 11:58 pm |
| Oppose the Petition | Jennifer Wade, M.Ed, BCBA, LBA | 4/13/22 11:41 pm |
| Consent Violations | Jabrad M Rahad | 4/13/22 9:08 pm |
| Support | W. S. Harris | 4/13/22 9:03 pm |
| Opposed | Katherine Robinson | 4/13/22 8:58 pm |
| Behavior Analysis Comments | Ken Crum, ServiceSource | 4/13/22 8:42 pm |
| Oppose Petition | Beth Newcomb | 4/13/22 8:38 pm |
| Game of who is bigger | A concerned parent | 4/13/22 4:53 pm |
| Note of Intimate Relationship | Anonymous (121453) | 4/13/22 4:16 pm |
| CASP Public Comment on Behavior Analysis Petition | Council of Autism Service Providers | 4/13/22 4:08 pm |
| Chicken Soup for the Soul | Kaitlyn Poten Behavior Asst | 4/13/22 4:04 pm |
| Clarity | Michael Moates, MA | 4/13/22 4:00 pm |
| Not in Favor | Emily Rotola | 4/13/22 3:56 pm |
| In favor of petition | Hollie Benincosa | 4/13/22 3:34 pm |
| Interesting. | Anonymous (121447) | 4/13/22 3:32 pm |
| Confusion on autism-focused credentials? | Anonymous (121446) | 4/13/22 3:29 pm |
| Name | Lina Tomas | 4/13/22 3:21 pm |
| So much Narcissism | Lina Toma? | 4/13/22 3:14 pm |
| Copy Paste Repeat | Zac Larson | 4/13/22 3:12 pm |
| Oppose | James Santoyo | 4/13/22 3:05 pm |
| Why the lie | Rosi Talleia | 4/13/22 3:04 pm |
| Concerns | Courtney Vaughan | 4/13/22 2:46 pm |
| Misnomer | Raheed Morishani | 4/13/22 2:36 pm |
| Oppose the petition | Jody Liesfeld | 4/13/22 2:18 pm |
| Yes | Raymond Henderson | 4/13/22 1:49 pm |
| Support for Rulemaking | Kim Jung | 4/13/22 12:50 pm |
| Public Comment on this Petition | Virginia Association for Behavior Analysis | 4/13/22 12:03 pm |
| BACB Only Creates Single Standard Without Need For Improvement | Sammy Linderson: ABA Student | 4/13/22 10:17 am |
| Not Yay Nor Nay - Seek Advice of Relate Fields | Ross Norris DLitt | 4/13/22 10:02 am |
| Oppose the Petition | Lisa Falke | 4/13/22 9:53 am |
| Long overdue | Arlondo Ortiz Ramirez | 4/13/22 9:42 am |
| Support for Petiton | Lawerence B. Watson, Psy.D. | 4/13/22 9:30 am |
| Petition Concerns | Kate Lewis | 4/13/22 9:14 am |
| for clarity ABAI recognizes QABA BICC IBAO NASP APA | Anonymous (121406) | 4/13/22 8:37 am |
| Comments regarding behavior analyst certifying organizations | G. Bourland, Assoc. for Behavior Analysis International Licensing Committee | 4/12/22 11:46 pm |
| it is simple | Anonymous (121394) | 4/12/22 9:10 pm |
| Petition Opposed | Elizabeth Matthews, BCBA, LBA | 4/12/22 5:39 pm |
| End the Monopoly | Anonymous (121380) | 4/12/22 4:59 pm |
| Concerns | Adam Warman | 4/12/22 2:35 pm |
| My last post and apologies | Prof. Michael Moates, MA, QBA, LBA, LMHP | 4/12/22 1:13 pm |
| Shaping versus coercion | Anonymous (121361) | 4/12/22 1:06 pm |
| Yes, include new language | Anonymous (121358) | 4/12/22 12:19 pm |
| See | Anonymous (121347) | 4/12/22 11:00 am |
| There is an anon | Anonymous (121346) | 4/12/22 11:00 am |
| There is no "Anon" | Anonymous (121344) | 4/12/22 10:45 am |
| Police Report Filed | Michael Moates, MA | 4/12/22 9:38 am |
| It is sad the BACB Anon Rep has to lie and defame | Michael Moates, MA | 4/12/22 9:16 am |
| Some of these anonymous comments are pretty good! | Anonymous (121301) | 4/11/22 9:32 pm |
| Careful! The sands are shifting! | Anonymous (121300) | 4/11/22 9:31 pm |
| It is remarkable that the QABA chose him as their spokesperson and petitioner. | Anonymous (121298) | 4/11/22 9:23 pm |
| Past behavior predicting future behavior. | Anonymous (121297) | 4/11/22 9:16 pm |
| VACP Not Valid | Michael Moates, MA | 4/11/22 3:12 pm |
| VACP position on ABA petition for rule making | Dr. Ed Tiller, VACP president | 4/11/22 2:47 pm |
| Litigation Filed | Michael Moates, MA | 4/11/22 1:41 pm |
| BACB VS. QABA | Anonymous (121121) | 4/11/22 1:02 pm |
| Letter to Congress | Michael Moates, MA | 4/11/22 10:11 am |
| Proved his point | Anonymous (121116) | 4/9/22 2:01 pm |
| Regarding "There is absolutely no evidence." | Anonymous (121115) | 4/9/22 12:09 pm |
| Shock | Anonymous (121114) | 4/9/22 11:32 am |
| Regarding "Additional Concerns About the Practice of ABA" | Anonymous (121113) | 4/9/22 11:27 am |
| Regarding the comment, "Something Else that is a Bit Confusing" | Anonymous (121112) | 4/9/22 11:18 am |
| Anonymous | Anonymous (121111) | 4/9/22 11:14 am |
| Hypocrite, much? | Michael Moates, MA | 4/8/22 10:23 am |
| Something Else That Is A Bit Confusing | Michael Moates, MA | 4/7/22 6:42 pm |
| Harassment | Anonymous (121108) | 4/7/22 6:36 pm |
| Additional Concerns About the Practice of ABA | Michael Moates, MA | 4/7/22 6:27 pm |
| Anon is wrong | Michael Moates, MA | 4/7/22 4:22 pm |
| Re: "Similar discussions of counseling" | Anonymous (121104) | 4/7/22 2:28 pm |
| Spain | Anonymous (121103) | 4/7/22 1:44 pm |
| Reply to Anon | Michael Moates, MA | 4/7/22 11:01 am |
| re: "BACB Update" | Anonymous (121100) | 4/7/22 10:21 am |
| Update from the BACB | Michael Moates, MA | 4/6/22 10:25 pm |
| My Opinion... | Anonymous (121098) | 4/6/22 5:30 pm |
| Disheartened | Hannah Robicheau, LBA | 4/6/22 4:51 pm |
| People Clearly Don't Understand This Is Not A Vote | Anonymous (121094) | 4/5/22 10:37 am |
| I do not support the QABA licensure. | Anonymous, Public School Division | 4/5/22 10:29 am |
| There is absolutely no evidence... | Anonymous (121088) | 4/5/22 9:27 am |
| I support the anonymous comments. | Anonymous (121087) | 4/5/22 8:45 am |
| Breaking News - Anonymous Calls Out People Who Use Their Name While Being Anonymous | Anonymous (121085) | 4/4/22 8:55 pm |
| Re:QABA transparency? | Dr. Valencia Church-Williams | 4/4/22 7:46 pm |
| QABA transparency? | Anonymous (121083) | 4/4/22 6:15 pm |
| Response to Last Anon | Michael Moates, MA | 4/4/22 3:31 pm |
| High Standards are Necessary | Anonymous (121079) | 4/4/22 3:30 pm |
| Disagree | Anonymous (121077) | 4/4/22 12:15 pm |
| Comments from ANSI National Accreditation Board | Vijay Krishna, ANSI National Accreditation Board | 3/31/22 2:00 pm |
| 328 OPPOSE SINGLE BOARD | Michael Moates, MA | 3/30/22 8:46 pm |
| Similar Discussions of Counseling | Michael Moates, Global Institute for Behavior Practitioners and Examiners | 3/30/22 8:04 pm |
| Reply to Anon | Michael Moates, MA | 3/29/22 9:51 am |
| On the Petitioner’s “Responses” | Anonymous (120944) | 3/29/22 9:35 am |
| Response to Anon | Michael Moates | 3/28/22 5:58 pm |
| Statement | Anon | 3/28/22 3:09 pm |
| Another Reason Alternatives Must Be Considered - Shocking Children | Michael Moates, MA, QBA, LBA | 3/28/22 9:00 am |
| Concerns with Proposed Changes | C. DuVall | 3/23/22 11:11 pm |
| Reply to Crystal Peterson Barker | Michael Moates, MA | 3/23/22 11:29 am |
| Additional Credentialing Agencies | Crystal Peterson Barker | 3/23/22 9:21 am |
| Comment to Board | Michael Moates, MA | 3/22/22 12:58 pm |
| Reply to Anon | Michael Moates, MA | 3/22/22 12:50 pm |
| Re: Misty Kieschnick | Anonymous (120837) | 3/22/22 9:23 am |
| Response to Anon | Michael Moates | 3/21/22 6:18 pm |
| Suggestion | Anon | 3/21/22 2:44 pm |
| Further Reading with Quotes for the Board to Consider | Michael Moates, MA, QBA, IBA, LBA, QMHP-T, EdD Candidate | 3/21/22 11:58 am |
| Reply to Caroline Salzman, BCBA, LBA | Michael Moates, MA, QBA, IBA, LBA, QMHP-T | 3/21/22 11:25 am |
| Do not allow QBA as a part of VA Licensure | Caroline Salzman, BCBA, LBA | 3/21/22 10:58 am |
| We owe it to service recipients to push for more rigorous requirements. | Emily Wilson, Blossom Behavioral Services | 3/21/22 8:24 am |
| Response to Theodore A. Hoch, Ed.D., B.C.B.A.-D., L.B.A. | Michael Moates, MA, QBA, LBA, QMHP-T, Ed.D. Candidate | 3/17/22 10:30 pm |
| Great concern regarding the QABA credential - Part 1 | Theodore A. Hoch, Ed.D., B.C.B.A.-D., L.B.A. | 3/17/22 6:56 pm |
| End the monopoly! | Ira Heilveil | 3/16/22 11:43 pm |
| This change is necessary to provide to the growing number of mental health and disability issues.. | Misty Kieschnick | 3/16/22 11:11 pm |
| VIRGINIA PUBLIC COMMENT FOR LICENSING- INCLUSION OF QABA CREDENTIALING | Home Link International Inc | 3/16/22 9:41 pm |
| Support for other credentialing agencies (i.e., QABA) | Beatriz Querol-Cintron, BCBA, LABA, QABA | 3/16/22 8:18 pm |
| Strongly Agree to Add QABA to Virginia | Heather Smith, Autism Behavior Services Inc. | 3/16/22 6:18 pm |
| Expand Opportunities for Service Provision for Clients & Their Families | Dr. Valencia Church-Williams, Ed.D, QBA, CAS | 3/16/22 4:27 pm |
| Approve "nationally accredited certifying body" verbiage | Jessica Swanson, MA, BCBA, QBA, LBA, CAS | 3/16/22 3:10 pm |
| Support for QABA Licensing | Eric Linder, Former CA Legislator | 3/16/22 3:02 pm |
| ADD QABA to Licensing for ABA | Dr. Rosa Patterson, QBA | 3/16/22 2:49 pm |
| QABA Virginia State License | B.Jaramillo, BCBA, QBA | 3/16/22 2:33 pm |
| Global Institute for Behavior Practitioners and Examiners (Non-Profit Organization) Comment | Michael Moates, MA, QBA, LBA, QMHP-T, Ed.D. Candidate | 3/16/22 2:23 pm |
| QABA State License | ABSI | 3/16/22 2:08 pm |
| We support equal and fair criteria for ABA licensing | Autism Business Association | 3/16/22 1:58 pm |
| Include QABA Credentialing parallel to the BACB | Anonymous (120781) | 3/16/22 1:11 pm |
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