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