Comment on DOD-2011-HA-0076-0001

The document is generally a good idea; however, it has acritical flaw. The document appears to want to increase the number of providers eligible to render behavior analytic services. Behavioral services have been effective for children with autism spectrum disorder; however, permitting unlicensed professionals to provide such services is a mistake. It is my belief that unlicensed, certified behavior analysts should be required to work under the supervision of a licensed psychologist. The regulation should be rewritten to reflect that.