The current regulations governing the practice of Behavior Analysis in the state of Virginia are representative of the field of BA and as written, 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.

The development of an advisory board containing board-certified and licensed practitioners would be the most effective way to oversee licensed professionals and inform the future language of the regulations. This will ensure the behavior analyst's right to practice as well as the consumer's right to evidence-based intervention is not infringed upon.

Thank you for your consideration to support the regulations governing the practice of behavior analysis as written.