Written Public Comment Submission Detail

Public Comment Details

Meeting
Commission Meeting - February 2021

Agenda Item
1H: Strategic Plan Session

Name
Lauren DeNoia

Organization
--

Comments
CTC Members:
I'm writing to petition for your consideration of adopting a PPS credential and/or added authorization for PPS and Teachers in Behavior Analysis.
[also known as ABA: applied behavior analysis, and BCBA, board certified behavior analysts].
Please note the following 3 justifications:
1. During and AFTER pandemic related school closures (distance learning online) there is and will be an increasing need for students' behavioral/ social/ emotional healthcare and maintenance in order to remediate learning loss issues and promote receptive educational behaviors and mindsets.
Developing and closely monitoring the effectiveness of interventions [data based decision making] is an intricate skill that Behavior Analysts are educated to perform, whereas, this is *much less specifically* developed in the educational backgrounds of School Psychologists, School Social Workers, and School Counselors of whom did not specialize in behavior analysis. [This information was determined by comparing coursework requirements, as well as personal experience in a School Psychology Program and a separate and subsequent Applied Behavior Analysis program].
2. Adding a credential or authorization will also create jobs and generate funds for the CTC in fees collected from credential holders. These advantages will stimulate the CA economy overall, and have further reaching benefits.
3. According to the California Association for Applied Behavior Analysis:
"...adoption of SB 946 [licensing/credentialing holders of the BCBA] substantially increased the already high demand for ABA services and, as a result, precipitated the need to adopt uniform, objective, verifiable standards and procedures for **protecting consumers [or students] from risk of harm** caused by individuals who make unsubstantiated claims that they are qualified to practice ABA. **At present there are no such laws clearly requiring that individuals document and demonstrate training and competence in ABA in order to practice in this state [including public schools],** and no entity within California that has legal authority to directly regulate the practice of ABA. These were some of the contingencies that led CalABA to sponsor legislation that would license professional practitioners of behavior analysis in California."
https://calaba.org/news-and-events/2016/licensure-update-ab-1715-introduced
- There will always be a need for Behavior Analysts to perform work with students with IEPs (specifically conducting FBAs and writing behavior plans and interventions for students eligible under ED and AUT, among other eligibilities), however, there is now an unprecedented need for CLOSELY REGULATED behavior analytic services among the general and special education populations, if not only to decrease the over-identification of students in need of special education due to extenuating circumstances brought about with the pandemic.
** I do NOT believe that qualified professionals that are credentialed in other specialties should be precluded from performing behavioral analysts work (ie School Psychologist, etc). With a designated Behavior Analysis credential, CA schools will be able to improve upon the existing framework with a higher level of expertise.
[As a comparison: School Counselors, School Psychologists, and School Psychiatric Social Workers all provide counseling to students with different degrees of intensity]
Thank you for your consideration,
Ms. Lauren De Noia MA, BCBA
PPS School Psychologist
District Behavior Specialist

Back