Public comment is being requested for Exceptional Rate for ID Individuals. This regulatory action actually refers to residence homes and is not for behavior analysts, however, the profession is described in the definitions, and we are incorrectly represented.
Please make comment similar to the following, or develop your own content.
Regarding the Exceptional Rate for ID Waiver Individuals, please accept the following public comment:
“Behavioral specialist” means a person who possesses any of the following credentials: (i) endorsement by the Partnership for People with Disabilities at Virginia Commonwealth University as a positive behavioral supports facilitator; (ii) board certification as a behavior analyst (BCBA) or board certification as an associate behavior analyst (BCABA); or (iii) licensure by the Commonwealth as either a psychologist, a licensed professional counselor (LPC), a licensed clinical social worker (LCSW), or a psychiatric clinical nurse specialist.
Number ii should read “licensure by the Commonwealth as either a behavior analyst (LBA) or assistant behavior analyst (LABA)” In order to practice behavior analysis in Virginia, on must be licensed according to §54.1-2957.16. Also, the a in BCaBA is lowercase and stands for “assistant.” When referring to a licensed person, the A is capitalized, but still refers to “assistant.”
Thank you for your consideration.