The current regulations have allowed for quality provision of behavior analytic services by licensed practitioners.  It is recommended that the regulations remain as written and the process for certification by the BACB serve as the first requirement for licensure in the state of Virginia.

If an Advisory Board is established, it should contain Board Certified/Licensed Behavior Analysts as well as Board Certified/Licensed Assistant Behavior Analysts, along with members of the community.  This would be an effective way to inform future language of the regulations and make any changes that may be needed.

Thank you for your consideration to support the regulations as written.