As a board certified behavior analyst and licensed behavior analyst in Virginia, I feel the behavior analyst licensure regulations that have been in place are working well. It has been my experience that families in need of services have been able to receive them from well qualified professionals throughout the state. The field of behavior analysis is incredibly specialized, and requires delivery from clinicians who possess the high quality training and experience required within the current regulations. 

Please maintain the regulations as they have been in place. 

The current regulations for licensed behavior analysts in the state of Virginia represent the field well and have enabled the continued delivery of quality services by such licensed professionals.  It is recommended that the regulations remain as they are written.  The BACB's certification process is one to be highly respected and should continue to be the first requirement toward becoming state licensed.  An advisory board containing behavior analysts would certainly be the best way to oversee professionals licensed and practicing in our state.

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. 

I support the regulations governing the practice of Behavior Analysis as they are currently written.

I support the regulations governing the practice of Behavior Analysis as they are currently written.  As a parent to a son with autism, I have seen firsthand the distinct difference ABA therapy has made.  An artificial environment such as a doctor's office where it is quiet with little sensory input does NOT provide what is necessary to teach my son how to cope with his frustration and anxiety because he doesn't feel those stresses in a cozy office.  I know, we've tried several.  However, when you put him in his natural setting with other kids, changes in schedules, frustrating fine motor tasks; that is when you will see the behaviors that need therapy and coaching as well as the triggers.  That is when you can do the real work.  To have all of the noise, the kids sitting around watching as my son has a meltdown because his Nutri-grain bar broke in two pieces...that is real life and that's where these kids have to be treated and equipped.   It is imperative to have ABA therapy as part of my son's supports.  At the end of the day, the goal is to address the social/emotional deficiencies these children have so they can mature into adults.  Specifically, adults who can contribute and work in our communities and be self sufficient.  It is possible with ABA therapy.  The data is there.  ABA therapy and the ABA licensure was a huge step in the right direction for providing effective supports and training for our children.  The challenges the psychologists made in their public and written comments would equate to taking a step backward and that is simply not what anyone is interested in doing.   

I highly recommend that the present regulations  for  licensed behavior analyst in the state of Virginia remain as they are written.   It  represents the field well and made possible the delivery of  quality  services  by licensed professionals. The BACB certification as a requirement and and an advisory board containing behavior analysts  are also recommended to oversee  the licensure and practice in our state.

The emergency regulations have supported licensed BCBAs to practice in Virginia. The current regulations are working.  

Respectfully,

Jessica Philips

The regulations, as currently stipulated, appear to be effectively governing the practice of behavior analysis by behavior analysts. I support the current regulations. It does not appear necessary to change them.

Sincerely,

John Prickett

As a Board Certified Behavior Analyst and a Licensed Behavior Analyst in the Commonwealth of Virginia, I support the regulations governing the practice of Applied Behavior Analysis in Virginia as they are written.  The current regulations make it possible for behavior analysts to apply quality, specialized, and individualized Applied Behavior Analysis services to those who benefit from it in a timely and efficient manner. 

Behavior Analysts have rigorous requirements outlined by the Behavior Analysis Certification Board and this should remain the utmost requirement for Behavior Analysts providing services in Virginia.

Thank you for your consideration to maintain the current regulations governing the practice of Applied Behavior Analysis in Virginia.

I work with many families and organizations that are receiving quality support due to the current regulations in place governing the practice of behavior analysis.  I support the regulations governing the practice of behavior analysis as they are currently written.  They provide access to staff highly trained and educated in behavior analysis to clients who deserve quality services.

The current regulations governing the practice of behavior analysis in the Commonwealth are sufficient. These emergency regulations, which were informed by the Behavior Analyst Certification Board's Guidelines for Responsibile Conduct for Behavior Analysts, have enabled thousands children and adolescents diagnosed with ASD across the Commonwealth to overcome the challenges associated with Autism Spectrum Disorders. The proposed changes to these regulations will negatively impact the current service delivery model and may leave thousands of children without appropriate and effective treatment.

I support the legislation as written. 

As a Board Certified Behavior Analyst and a Licensed Behavior Analyst in the Commonwealth of Virginia, I support the regulations governing the practice of Applied Behavior Analysis in Virginia as they are currently written.  The current regulations represent the field of Applied Behavior Analysis well and have enabled the continued delivery of quality services by Licensed Behavior Analysts.

The Behavior Analysis Certification Board has a highly respected certification process and this should continue to be the first requirement toward becoming licensed in the Commonwealth.  An advisory board containing Licensed Behavior Analysts would be the best way to oversee the licensing and practice in the Commonwealth of Virginia.

Respectfully,

Kate Lewis

I support the regulations governing the practice of Behavior Analysis as currently written. The regulations provide families with access to high quality services. It is recommended that BACB certification be required and that an advisory board consisting of behavior analysts oversees licensing. 

I support the regulations governing the practice of Behavior Analysis as they are currently written. 

Kristina Zaccaria 

Board Certified Behavior Analyst 

The provisions that have been in place appear to be working.  People diagnosed with autism and their families are able to obtain services from professionals who are well versed in behavioral principles.  By requiring that the practicing behavior analysts continue to meet the qualifications set forth by the Behavior Analyst Certification Board and the current state requirements, you are ensuring that those providing services are qualified to do so.  I support continuing to follow the current regulations.

Applied Behavior Analysis is scientifcally proven to help those that have autism.  People that have autism have difficulty with communication and social skills, and also commonly have challenging behaviors, such repetive and restrictive behaviors, interests or activities.  Autism is increasing in our society and ABA is the single, scientific, results-based therapy that can help, and sucessfully improve the quality of life for the individual and their family in order to have a happy and productive life.  If we neglect autism, and do not make ABA easily available through healthcare coverage, we will have a new problem... adults untreated that are not able to join society, maintain a job, and be successful.  This will harm families in a multitude of ways and of course, be an income drain.  Overall it will harm society, since we will have to pay for the many products of providing NO treatment.  Autism is epidemic, please be forward thinking... we need to be proactive, all of us.

The current regulations governing the practive of Behavior Analysis in the state of Virginia are effective in ensuring that licensed professionals provide quality services.

It is recommend that the current regulations be kept as they are, with a modification including making BACB certification a requirement for licensure to protect individuals diagnosed with ASD and their families as they seek effective and ethical services from licensed professionals. BACB certification has standards that are comparable to regulations governing other professionals governed by the Board of Medicine. Furthermore, this certification should be verified by the BACB for all current licensed behavior analysts to further protect individuals with ASD and their families and ensure quality services.

I believe that an advisory board made up of LBA's that are currently certified by the BACB would be the most efficient way of ensuring that ethical and professional standards in Behavior Analysis services in Virginia are upheld.

Thank you for your consideration to maintain the current regulations governing the practice of Applied Behavior Analysis in Virginia

As a parent of a teen on the autism spectrum, I strongly support upholding the current regulations governing the practice of Applied Behavior Analysis (ABA) in Virginia.  The current regulations are important to maintain high quality, effective services to people and families living with autism. Since ABA is effective, it doesn't make sense to change the current professional standards outlined by the Behavior Analysis Certification Board.

I support the regulations governing the practice of Behavior Analysis as currently written. The regulations provide families with access to high quality services. It is recommended that BACB certification be required and that an advisory board consisting of behavior analysts oversees licensing. 

On behalf of the Faison Centers of Excellence and our team of three doctoral level, seven masters level, and two bachelors level behavior analysts, I write to express our support for the proposed regulations governing the practice of behavior analysis, as written. We commend the Board of Medicine for promulgating regulations that, over the last year, have led to many positive outcomes for recipients of behavior analytic services in the Commonwealth. 

Eli Newcomb, Licensed Behavior Analyst

I am a parent of 2 boys with autism. They have greatly benefitted from Behavior Analysis in the model of the current provisions. Other families should be able to have that same benefit.

I support the regulations of ABA as they are currently written. My six-year-old daughter was diagnosed with autism three years ago and it’s taken all that time for my private insurance to finally begin covering ABA treatment. However, she will age out in January when “early intervention” and the autism bill designating coverage by age expires. While I am grateful for the help, we will have benefitted from only one year of ABA coverage. I’ve gone through great lengths to personally fund ABA treatment as a single mom because it’s the only research-based evidence proven to work best during these critical years. And every day the clock is ticking. The truth is these kids require ABA a lot longer. Why would anyone want to limit access now? Let’s not take ten steps backwards when we have finally begun to get some traction on autism awareness and access to affordable ABA therapy. It’s opened doors of progress, particularly speech, for my daughter that would have otherwise been closed. I heard her name her colors for the first time at three-years-old when I hired an in-home ABA therapist to work with her in the next room. I stood in the kitchen crying tears of joy and disbelief when I heard that precious voice answer “yellow,” “green,” and “blue” when asked to name the color she saw. I swore she knew these things cognitively but it was ABA therapy that pulled this out of her for the world to see in her very own words. Parents are desperate for help to show the abilities of these beautiful children. Please don’t create another barrier to autism treatment. These kids will thrive with continued ABA support, and most importantly, increased access to ABA. If it's not broke please don't try to fix it.  

Respectfully,

Kelly Smith

 I support the regulations governing the practice of Behavior Analysis as they are currently written

The regulations governing Applied Behavior Analysis as they are currently written are working.  For the sake of children and families who benefit from ABA, please maintain the current regulations.

Thank you.

As a mother of a child with autism and a provider as well, I would like to urgently attest that the current requirements as outlined by the BACB, along with the current state licensure regulations ensure high quality and effective services to those facing the life long challenges of autism spectrum disorder.  Any lapse in the delivery of aba services could negatively impact the lives of individuals with asd and their families. 

I support the regulations governing the practice of Behavior Analysis as they are currently written

I support the current regulations governing the practice of behavior analysis in the Commonwealth of Virginia.  As the regulations stand, behavior analysts, like myself, are able to provide effective therapy to children diagnosed with autism.  The changes that have been proposed regarding these regulations threaten the delivery of these services to many in need.  Please maintain the current regulations governing the practice of Applied Behavior Analysis in Virginia.

I support the regulations governing the practice of Behavior Analysis as they are currently written.

The regulations regarding the practice of behavioral analysis should remain the same. The support needed to represent this population in need is under represented, as there are many individuals whom currently need assitance. Changing the regulations would ultimately effect the progress we have made thus far in contributing to this population, and would also endager many jobs of individuals who are seving this population, myself included. There is nothing within our current system that suggests we should make a change. Keep the regulations as they are.

Please maintain the regulations governing Applied Behavior Analysis as they are currently written.

Maintain the regulations governing Applied Behavior Analysis as they are currently written.

I support the regulations governing the practice of Behavior Analysis as they are currently written. I am a parent of a child who experiences autism.

I support the regulations governing the practice of behavior analysis as they are currently written.

I support the regulations governing the practice of Behavior Analysis as they are currently written.

I support the regulations governing the practice of Behavior Analysis as they are currently written. 

I support the regulations governing the practice of Behavior Analysis as they are currently written, thanks!

I am currently completing my M. Ed. and am being supervised by a Behavior Analyst to work directly with clients.  These clients have beneffited from the current regulations and continue to make progress today.  The supervision process has been beneficial for the families as well as myself.  The ability to collaborate and receive the support of a licensed Behavior Analyst has been influential in allowing me to continue my education while building practical experience.  A mother of one of my clients expressed that as compared to a year ago she can now breath easier in knowing that her son was making systematic progress.  

ABA is essential however, it should be required that all insurance providers cover it. Per all are not. Some employee sponcered insurances don't cover.  While employee's don't get to determine which provider their employers choose so all providers should cover the same option certainly pertaning to disablities.   Per if employers are going to except the cheapest propsal to save on cost, then employees who's children have Autism and other disablities will not be able to get this service through insurance and to pay out of pocket will cost thousands of dollars.  I covered my family for many years working for a large Insurance provider with a headquater in Richmond, VA however, when I was laid off due to out sourcing then swithched to my spouces employer sponsered insurance they did not cover.  While my husband works for a equally large corporation as a RN the insurance they provided has found a way to get around the law and or not provide coverage. 

Also, it should not be caped at age seven. Why?  Aferican American children are often diagnosed three years later then caucasian children by caping the age at seven black children are not benefiting from this legislation as they could becasue they may not be identified by age seven.  Also, a child that is eight, nine or ten, socially, emotionally, developmentally delayed and whose fuctional abilities are compromised will still benefit from services and can be taught just like a seven year old and often time can be developmentally younger then age. 

Food for thought !! Just some of my expeience as a mother of a black boy with aspergers not diagnosed until almost six. 

As a Board Certified Behavior Analyst and Licensed Behavior Analyst in the Commonwealth of Viriginia, I support the regulations for licensure as they are currently written.  The regulations, as they are currently written, have proven to be effective over the past year, at providing services to children on the autism spectrum and their families. 

I support the regulations governing the practice of Behavior Analysis as they are currently written.

The BCBA licensure regulations are working for behavior analysts in Virginia, and I support these regulations governing the practice of behavior analysis as they are currently written. 

On behalf of the many students, families and clients with autism the Virginia Institute of Autism serves and as a Virginia licensed behavior analyst, I am writing to express my support for keeping the regulations governing the practice of Behavior Analysis as they are currently written.

As a licensed Behavior Analyst in the state of Virginia, I strongly support the regulations governing the practice of Behavior Analysis as they are currently written.  Children with autism in this state have gained immense benefit as a direct result if the 2011 law regarding the provision of ABA services.  Additional benefit was provided by the 2012 law that led to the licensure of Behavior Analysts in the state of Virginia. 

Please continue to support those regulations so that children with autism in the state of Virginia can maintain access to ABA services.

As a licensed behavior analyst in the state of Virginia, I strongly support the regulations governing behavior analysis in the state of Virginia as they are currently written. As written, the laws provide necessary and impactful services for the families affected by autism across the state.

I support the Virginia regulations governing the practice of Behavior Analysis as they are currently written.