I want to start off by saying that the following is my opinion as an individual behavior analyst, and as such, only represents that, as is the purpose of legislative comment forums. My comments are entirely directed to the board that will review this petition. If someone feels that it is his/her/their best option to attempt to correct my personal opinion, or that somehow my personal opinion as a behavior analyst is threatening, then I am truly sorry that that is the position that that individual feels that they are in. Providing behavioral health services to people in need should never result in practitioners needing to be on the defensive/offensive. We're able to be most effective when we work together. It is clear to me that there are many passionate voices willing to speak on this topic, as there should be. No petition or legislative matter should be met with ambivalence. I also appreciate any issue that could push behavior analysis further and occasion self-reflection to improve our field.

I am incredibly disheartened by a few things (not all, but many) regarding this petition and the process. Primarily, the divisiveness and cutting down of one another as professionals and even people, in a public forum. Regardless of one's opinion on the content of this petition, I am concerned about the commentary being a reflection of our field and the practitioners therein. I wonder what members of the public may be turned off from all of us behavior analysts, who already may have a reputation for not working together for the common good outside of ABA.  I am also concerned about the underrepresentation of individuals/families receiving services in public comment forums. And finally, there are ALWAYS things to improve on, for every board, certifying entity, etc., because people are imperfect, and we are the ones who make decisions.

I admit to not being as familiar with the QABA as I am with the BACB, so let me preface with that. I also wasn't as concerned about the petition before reading this forum as I am now. I would like to think that I approached from a position of wanting to learn more, and trying to figure out where the opposition is coming from, while being as objective as possible (knowing there's an intrinsic bias as I'm certified by the BACB). From reading the QABA code of ethics, it's evident that there are many similarities between the BACB code of ethics. I started there because it's often the lifeblood of an organization, and an organization's values can be made clear by reading what guides the practice of the certificant participating in that credential. What I saw was a great start to an ethical code (very similar to previous iterations of the BACB's code of ethics and professional conduct). I wasn't able to (upon first glance) see many differences in intent. When I looked for how data was used and incorporated, I saw an underrepresentation of reliance on data and function to drive decision making. I also didn't see any information regarding assent, and there wasn't any information that I could spot other than in the research section that spoke to obtaining informed consent from the client/guardian, and/or what to do if the individual receiving services declines. Additionally, with an international entity, some of the aspects of the ethical code may conflict with country laws, but there is no guidance to say which should be followed. For example, there are currently 71 countries that criminalize homosexuality/bisexuality, and 15 that criminalize gender fluidity/trans expression, yet the code of ethics gives no guidance on how to balance that and anti-discrimination policies. 

https://www.humandignitytrust.org/lgbt-the-law/map-of-criminalisation/

The other component that is concerning to me is the limitation of the code of ethics and QABA credential to apply to treating "individuals with autism spectrum disorders and related disorders." If a practitioner with a QABA credential were to decide to work with animal training, or informing public safety policy, what would prevent that person from doing so if under the same license? It would then fall to the public/employer to determine the appropriateness of that practitioners experience given the role that he/she/they are in, which takes away the regulation and protection inherent in licensure for the public. One could say that if that practitioner is practicing within his/her/their "scope," that it shouldn't matter, however, the QABA code of ethics (per the introduction), applies to practitioners working with "individuals with autism spectrum disorders and related disorders." 

After some poking around, I was able to find information about what happens if a complaint is made on the website. If I was a consumer, I would have difficulty being able to figure out how to use the QABA board for protection using the complaint process, especially because the complaint form is only to be used between certificants, and the website states that complete information up to and including the complaint-filer's certification number would need to be submitted. Though I truly appreciate the intent to expand services throughout the world given how lucky we are in the United States to even be having this conversation, how is the complaint made by individuals worldwide who can't read or speak other languages? Who is explaining all of this to them so that they benefit from protection as well? What if the person needing to submit a complaint (the purpose of any credentialing board) is a member of the public and is unable to bring issues to the attention of the board? How are cultural norms identified and incorporated, and ensuring that women and children, LGBTQ+ youth, and others who may be disempowered in this country and across the world are able to be protected from unethical practices? I couldn't easily find the infrastructure around any of these questions (which is the lens a consumer would use), which worries me. Keeping ABA practice within the US is not the best course of action either, to be sure. I would, however, want to ensure first that no harm could possibly be done to those impacted by ABA services, especially if one is an ambassador of ABA throughout the world.

I am all in favor of having credentialing that is the optimal balance of protection for consumers, and easier access to services for individuals who would benefit from them, but not if there aren't enough protections in place for the individuals that ABA impacts. I worry that it may be a little too hasty and to narrow a focus for the QABA to be included in certifying entities for licensure in Virginia before some of these questions have thorough and easy to find answers.

Thank you for your consideration of my comment.