Dear Members of the Board of Medicine,

The Virginia Autism Project (VAP) urges the Board of Medicine to approve the emergency regulations governing the practice of Behavior Analysis as they are currently written with no changes or amendments.

VAP is a grassroots, state-wide coalition of families affected by autism.  We formed April 2, 2009 and have led the effort to secure insurance coverage for the treatment and therapy for children with a diagnosis of Autism, including working with legislators for both the autism insurance bill (HB2467) and the ABA licensure bill (HB1106). 

VAP thanks the Board of Medicine for its hard work on the regulations and is pleased to have received reports from around the Commonwealth of how the regulations are working for individual families of children aged 2 through 6, but also older persons on the autism spectrum. 

The model for ABA is a tiered service delivery approach which relies upon the use of Behavioral Technicians.  This model has been the primary mechanism for achieving many of the significant improvements in cognitive, language, social, behavioral, and adaptive domains that have been documented in the peer-reviewed literature.  This model has also helped to ensure that treatment is delivered to families in hard to access rural and urban areas as well as families who have complex needs.

Many of our members have been receiving services using this model and they are pleased with the progress.  For children aged 2 through 6, insurance companies have been regularly covering both the services provided by the LBA and LABA as well as the services provided by persons supervised by the LBA (Paraprofessional), according to the law.

We, the VAP, are also pleased with the progress that has been made in helping persons with ASD and their families.  The National Standards Project led by the National Autism Center (http://www.nationalautismcenter.org/nsp/) shows that ABA is the most researched and effective treatment for persons with ASD and we, the VAP, are thankful that the licensure regulations are enabling families in Virginia to receive the services they need.  

Please approve the emergency regulations and make them permanent regulations as they are currently written.

Respectfully,

Virginia Autism Project -Board of Directors and Area Directors

Teresa L. Champion

Lynn Wallis Miller

Jodi Mulford Folta

Mark Llobell

Patricia Chandler Taylor

Lisa Bragg

Nicole Brenner

Ryan Watson