I am a licensed behavior analyst, I have my PhD in clinical psychology, and I support the current regulations governing the practice of behavior analysis, as written. It is imperative that non-licensed personnel continue to be allowed to implement ABA programs, under the direction and supervision of licensed behavior analysts. Limiting the implementation of ABA programs to only licensed behavior analysts, as some have suggested, would severely restrict access to services for individuals with autism spectrum disorders and is not in line with what has been shown to be effective through the research literature. In Lovaas’ seminal 1987 publication demonstrating the effectiveness of ABA, non-licensed personnel were the ones who implemented the interventions (Lovaas, 1987). In addition, since 2000 alone, hundreds of articles have been published in peer-reviewed journals demonstrating that interventions utilizing the principles of ABA are effective for individuals on the autism spectrum. In the majority of those articles the interventions were being implemented by non-licensed individuals with training in behavior analysis, under the supervision of Board Certified Behavior Analysts. The BACB recommends 1 hour of supervision by a behavior analyst for every 5 to 10 hours of direct service provided, a recommendation also supported by the research literature. I support the regulations as they are currently written because they rely upon a model of service delivery that is supported in the literature and they have the potential to increase access to much needed services for individuals on the autism spectrum across the Commonwealth. I respectfully ask the Board to take this information into consideration as they review the regulations.

Lovaas, O.I. (1987). Behavioral treatment and normal educational and intellectual functioning in young autistic children. Journal of Consulting and Clinical Psychology, 55,3-9.