To the attention of:

Michael Nicin , Senior Policy Advisor at Office of the Minister of Children and Youth Services

Michael Coteau, Minister of Children and Youth Services

Bruce McIntosh, President of the Ontario Autism Coalition and member of the OAP Implementation Committee

Dear Mr. Nicin:

Please re-instate/not remove the requirement for an RHP (clinical psychologist) overseer to the BCBA providing ABA therapy to children receiving DFO. The quality of the services received will suffer if this is not the case. The accountability and expertise provided by the RHP is essential and will ensure the DFO funds are spent to achieve the best possible outcome for children receiving DFO with the delivery of quality services.

I have significant concerns about the removal of the requirement of an RHP as clinician in charge overseer for BCBA's in this OAP.

I feel strongly that the expertise of a clinical psychologist (an RHP) is critical for not only accountability and quality in service delivery but also for breadth and depth of knowledge of child and human development, co-morbid disorders and other psychological issues that are beyond the scope of expertise possessed by a BCBA. I want the BCBA to have an overseer to turn to for guidance and problem solve as well as that third tier of accountability for ensuring that the programs implemented were all consistently clinically sound and appropriate. I know that that this clinical overseer will enhance the quality of therapy that my child will receive in the OAP.

The level of knowledge, expertise and experience is widely variable across the BCBA designation. It is the presence of the clinical psychologist (RHP) as the clinician in charge that contributes to and ensures the quality assurance and continuity. Having this overseer also ensures a clinical accountability from the BCBA to the clinical psychologist and safeguards quality service delivery and clinical guidelines being adhered to.

I have great concerns with removing the requirement of this clinician in charge being an RHP to oversee the service delivery. I am concerned that the removal of this contingency will affect the quality of the services provided to children as well as consistent clinically appropriate and competent ABA therapy.

I believe that newly board certified behaviour analysts especially require the oversight of an RHP with a BCBA designation right out of school. I believe it is ill-advised to remove this guidance, support and expertise that the RHP clinician in charge would provide.

A two-year masters program and 1500 hours of practicum and passing a board exam do not qualify an individual to have the clinical judgement and expertise of a clinical psychologist nor the clinical accountability of an RHP.

I worry that in the pursuit to gain more credibility and establish the BCBA designation further in the field of autism, we may have lost sight of what is important: the most effective and best possible service delivery of ABA therapy to improve the lives of children and their families with autism. I firmly believe that this will be accomplished with the BCBA’s as part of a team of professionals working together with an RHP overseer and centering the services provided around the child with autism and their families.


Regards,

Concerned Autism Families in Ontario (Canada)