The mission of the Virginia Association for Behavior Analysis (VABA or VirginiaABA) is to promote and support the practice, research, and dissemination of behavior analysis throughout the Commonwealth of Virginia. VABA recognizes that the law and regulations to license practitioners of behavior analysis afford important protections for consumers, funders, the state, and the profession, and that the law and regulations apply to the practice of behavior analysis regardless of client population, setting, funding source, and the like.

VABA has adopted a “Position on Credentials to Serve as Qualification for Licensure to Practice Behavior Analysis”(http://virginiaaba.org/wp-content/uploads/2022/03/Position-on-Credentials.pdf) that we feel is important when evaluating certifications that are to be accepted for licensure. Here are some highlights:
–     Entities that certify professional practitioners of ABA should be nonprofit organizations. Internal Revenue Service regulations require nonprofit (tax exempt) organizations to serve and be accountable to the public; have no owners, shareholders, or investors; and use any surplus revenues to benefit the communities they serve. The organization should be governed by an independent board of volunteer directors and make its bylaws and other governing policies available to the public. That is, nonprofit credentialing organizations must be transparent about how they are governed and operated, how their credentialing and other standards are developed and implemented, and other aspects of their credentialing programs. That allows applicants for and holders of the credentials, consumers, employers, funders, and governments to easily access critical information about the organization. The overwhelming majority of U.S. organizations that issue professional certifications in healthcare and human services are nonprofits. A notable example is the American Psychological Association’s Criteria for the Recognition of Organizations that Provide Certifications in Specialties and Subspecialties in Professional Psychology, which has as its first criterion “The certifying body is a non-profit organization that has published bylaws, standards, and procedures and is governed by an independent board of directors, with specified procedures for selection and tenure of board members such that control does not rest with one individual or group of individuals indefinitely” (emphases added). https://www.apa.org/ed/graduate/specialize/recognition-criteria.pdf
–     Certifying entities should conduct job analysis studies using well-established procedures and standards to identify the competencies required to practice ABA with any client or service recipient, not just a subset (e.g., those with a specific diagnosis). The studies should involve large numbers of subject matter experts, credentialed members of the profession, and experts in psychometrics (test construction and validation). The resulting list of competencies should drive the contents of the professional examinations that are required to obtain the certifications. It may also inform decisions about other certification eligibility requirements (often called task lists or exam outlines), and related standards should be readily available to the public. These job analysis studies should be regularly repeated to ensure they are keeping up with the profession. 

At this time, we do not know of any certification organizations beyond the Behavior Analyst Certification Board (BACB) that meet these criteria. Therefore, we do not support the petition. Thank you for your consideration.