Life Span changes of an imbalance of behavioral health issues of vulnerability cause personnel genocide of involuntory separation from state service.  Possible family planning of a hypothesis of premiscurity of a personality analysis test.  

The signs of stress and premenstrual syndrome prior to my first mental breakdown of changes in my body was noticeable to me and I notified my superiors.  I went to human resources and was recommended to seek Value Options.  I had talked to different nurses about three months prior to getting an authorization for counseling sessions through the state to help cope with stress and pms symptoms.  On going questioning of suicide and my personal life was not a happy moment.   The constant calling and questioning of my personal life became annoying for me.   

My body was going through changes that was beyond my control.  On going stressor of blotting was unbearable and embarrassing.  Doctor after doctor visits to fix the problem of blotting was of no help.  I tried everything from over the counter medications but nothing seem to work.  Evidence Base Practice of protocol was violated against policy and my sensitive family life was not taken into consideration.  The integrity of the sworn in statement under oath wasn't considered.  

I would like to have the opportunity to walk across the stage and receive my tenth year award as a Correctional Officer that I deserve, worked hard for and endured until involuntory separation from state service.

Evidence Base Practice caused an adverse termination from state service.  Administration process act of welfare, health, and safety as a citizen was denied to prevent employee burnt out.  Mandatory overtime caused a relapse of a mental breakdown.  The weak state of employee burntout and behavior health issues caused an adverse that wasn't part of my strategic plan. 

Behavioral health classified as misconduct (unprofessional) is unfair, unjust and wrong.  Mental Health alert system as a blacklist of denial of school admissions and employment is wrong.  Where is my future of education to obtain a higher degree?  Where is my guarantee of longevity pay for abuse of more than minimum risk against protocol?

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To Whom It May Concern:

The Virginia Autism Project (VAP) and Autism Speaks (AS) submit the following comments on the Emergency Regulations Governing the Practice of Behavior Analysis.  (18VAC 85-150-10 et seq, effective dates September 19, 2012 to September 18, 2013).

First, VAP and AS would like to thank the members of the Working Group and the  Board of Medicine for their methodical and careful consideration of the profession of Board Certified Behavior Analysts (BCBA® ) and Board Certified Assistant Behavior Analysts (BCaBA® )

The report that we have received from BCBAs in the Commonwealth of Virginia, is that the licensure application process is straight forward and efficient.  Thank you for the continued professionalism and attention to detail everyone has demonstrated in this difficult process.

Second, we present the following comments for deliberation:

• Section 18VAC85-150-130.  Supervision of unlicensed personnel.

This section has concerned many in the practice of behavior analysis.  The law defines the practice of behavior analysis to mean “the design, implementation, and evaluation of environmental modifications, using behavior stimuli and consequences, to produce socially significant improvement in human behavior; including the use of direct observation, measurement, and functional analysis of the relationship between environment and behavior.”

“The formal training of professionals certified by the Behavior Analyst Certification Board, Inc. (BACB) is similar to that of other medical and behavioral health professionals. That is, they are initially trained within academia and then begin working in a supervised clinical setting with clients. As they gradually demonstrate the competencies necessary to manage complex clinical problems across a variety of clients and medical environments, they become independent practitioners. In summary, Behavior Analysts undergo a rigorous course of training and education and have an “internship” period in which they begin by working under the direct supervision of an experienced Behavior Analyst. “[1]

“The use of carefully trained and well-supervised Behavioral Technicians* [*unlicensed professional and/or students training to become licensed professional] is a common practice in ABA treatment.  The use of Behavioral Technicians enables health plans and insurers ensure that they maintain adequate provider networks and deliver medically necessary treatment in a way that manages costs.   The use of Behavioral Technicians produces more cost-effective levels of service for the dura­tion of treatment because it allows the Behavior Analyst to manage more cases/hours of direct treatment.  The use of the tiered service delivery model permits sufficient expertise to be delivered to each case at the level needed to reach treatment goals. This is critical as the level of supervision required may need to shift rapidly in response to rapid client progress or demonstrated need.   Tiered service delivery models can help ensure that treatment is delivered to families in hard to access rural and urban areas as well as families who have complex needs.”[2]

VAP and AS have been assured that the language of 18VAC85-150-130 will not endanger the use of supervised unlicensed individuals or students training to become licensed professionals in the implementation of Behavior Treatment Plans.  

Finally, as we go forward with implementation of Virginia’s insurance mandate and then the subsequent filings for reimbursement from insurance providers, it will be important to monitor this section on the supervision of unlicensed personnel.  If for any reason it is used as a tool to deny reimbursement for behavior analysis to families, the Board of Medicine must act swiftly to clarify the intent of the regulations to follow the medical model of billing for the services performed under the larger umbrella of the licensed professional.

Respectfully submitted,

Teresa L. Champion,

President,

Virginia Autism Project

teechamp@gmail.com

Judith Ursitti,

Director, State Government Affairs

Autism Speaks

Judith.Ursitti@autismspeaks.org