Ref:  Petition for Rulemaking: Certification for licensure as practitioners of behavior analysis: Regulations Governing the Practice of Behavior Analysis (18 VAC 85-150)

Dear Board Members,

As the Board considers the petition for certification for licensure as practitioners of behavior analysis, the ANSI National Accreditation Board (ANAB) would like to provide information relating to the international/national standard for assessing the competence of personnel certification bodies and the accompanying accreditation requirements.

The ANSI National Accreditation Board (ANAB) is an affiliate of the American National Standards Institute (ANSI) and the largest multi-disciplinary accreditation body in the western hemisphere, with more than 2,500 organizations accredited in approximately 80 countries. ANSI oversees the creation, promulgation, and use of thousands of norms and guidelines that directly affect businesses in nearly every sector: from acoustical devices to construction equipment, from roads and bridges to energy distribution, and healthcare. ANAB accredits personnel certification bodies based on the international standard ISO/IEC 17024: Conformity assessment- Requirements for bodies operating certification of persons. This standard is also adopted as an American National Standard. ANAB has accredited over 225 programs under this standard including several in the healthcare sector such as those offered by the American Board of Multiple Specialties in Podiatry, ASCP Board of Certification, Inteleos, Lymphology Association of North America, National Board of Certification in Occupational Therapy, ABRET Neurodiagnostic Credentialing and Accreditation, AONN Foundation for Learning, and Academy of Lactation Policy and Practice. A complete listing of all accredited programs can be found at https://anabpd.ansi.org/Accreditation/credentialing/personnel-certification/ALLdirectoryListing?menuID=2&prgID=201&statusID=4

The ANAB accreditation process – itself based on an international standard (ISO/IEC 17011: Requirements for accreditation bodies accrediting conformity assessment bodies) – is extremely rigorous and ensures that only those organizations that meet the stringent requirements under the standard are accredited. Independent third-party accreditation is an “accountability mechanism” to ensure the quality and legitimacy of organizations offering credentials. ANAB accreditation provides an added layer of legal defensibility against invalid claims. The accountability and transparency built into the ANAB process support conformity assessment attestations and can result in reduced liability insurance.

Benefits of Accrediting Credentialing Organizations to ISO/IEC 17024 

Accreditation is a key component of an effective standardization system, assuring industry and governmental decision-makers that credentialing organizations are competent and their results can be trusted. The standard was developed by the International Organization for Standardization (ISO) based on the need for public protection by establishing that individuals have the required competencies to perform

their job. The standard has been recognized by several U.S. federal agencies as a critical requirement for personnel certification bodies that offer certification in areas related to public health, environment, and

national security. ANAB is a signatory to the International Accreditation Forum (IAF) Multilateral Recognition Arrangement for ISO/IEC 17024, which brings global acceptance of its accreditation program,

The following are the key requirements under the standard: 

• Credibility: The certification examination must be fair, valid, and reliable. A valid test correctly measures whether an individual has the necessary competencies for the job. Validity is an indicator to establish that the process measures what is intended to measure. Exam reliability shows that the test measures a person’s abilities in a consistent manner. 
• Impartiality: The certification body should establish its structure, policies, and procedures to ensure impartiality and objectivity and manages conflict of interest arising from certification activities. 
• Independence: The certification functions should be independent of training to ensure that confidentiality, information security, and impartiality are not compromised. 
• Transparency: The certification body is required to have an active complaints process to resolve complaints against its activities as well as complaints against individuals that it has certified. 
• Accountability: As per the standard, the certification body should have a due process for taking away the credential for unethical or incompetent behavior. 
• Balanced representation of stakeholders: The standard requires that the certification body should involve key stakeholders in making certification-related decisions. Additionally, subject matter experts (SMEs) should be involved in creating the certification scheme requirement based on a valid job or practice analysis. 
• Certification scheme: The standard requires a certification body to demonstrate that, in the development and review of the certification scheme the following are included:

a) the involvement of appropriate experts;

b) the use of an appropriate structure that fairly represents the interests of all parties significantly concerned, without any interest predominating;

c) the identification and alignment of prerequisites, if applicable, with the competence requirements;

d) the identification and alignment of the assessment mechanisms with the competence requirements;

e) a job or practice analysis that is conducted and updated to:

• identify the tasks for successful performance;
• identify the required competence for each task;
• identify prerequisites (if applicable);
• confirm the assessment mechanisms and examination content;
• identify the re-certification requirements and interval.
• Other requirements: The standard is very comprehensive and covers all aspects of certification including test security, recertification, resource requirement, confidentiality, the competence of personnel involved with the certification activities, financial requirements, and use of certificates and logo marks. Further, the certification body should develop a management system for continual improvement of its certification program. 

To ensure that the credentials they promote meet industry and quality standards, many federal and state agencies rely on ANAB accreditation. Some examples include: 

• Virginia Department of Health as specified in 12VAC5-421-55 of the Virginia Food Regulations requires ANSI/ANAB accredited Certified Food Protection Manager (CFPM).

• ANAB’s 17024 accreditation is the only program recognized by the U.S. Department of Defense (DoD) under DoD 8570 for Information Assurance. 
• ANAB’s 17024 accreditation program is recognized by the White House National Science and Technology Committee on Forensic Science as meeting the highest standard in accreditation. 
• ANAB’s 17024 accreditation is recognized by the U.S. Occupational Safety and Health Administration (OSHA) for crane operator certification and by New York, West Virginia, and California in licensing requirements for crane operators. 
• ANAB’s 17024 accreditation is a requirement for licensing of elevator inspectors in several states. 
• ANAB’s 17024 accreditation is recognized under the North American Securities Administrators Association (NASAA) model rule on the use of senior-specific certifications and professional designations. 
• ANAB’s 17024 accreditation is recognized by the U.S. Department of Energy (DOE) as the accreditor under the Better Building Workforce Guidelines. 
• The U.S. Department of Health and Human Services selected ANAB as the approved accreditor for its Health Information Technology (HIT) Certification Program.

ANAB has accredited the QABA Credentialing Board under ISO/IEC 17024 for (a) Applied Behavior Analysis Technician, (b) Qualified Autism Services Practitioner- Supervisor (QASP-S) and Qualified Behavior Analyst (QBA). These programs have demonstrated compliance with the stringent requirements of the standard.

We support the petition to amend the regulation to accept certification from an entity that is nationally recognized to certify practitioners of behavior analysis. We recommend ANAB be recognized as an accreditation body for the licensing of Applied Behavior Analysis and the QABA certification programs accredited by ANAB be included in the licensing of Applied Behavior Analysis. 

Please feel free to contact me for any additional questions or clarification.

Sincerely,

Vijay Krishna, MBA, ED.D.

Vice President, Credentialing

ANSI National Accreditation Board

1899, L Street Suite 1100, Washington DC 20036.