Thank you for the opportunity to comment on EPSDT changes that concern behavior.  I am Megan Valentine, BCBA LBA and I am the Regional Director of ABA Therapy program in Northern Virginia.  There are three areas where I think changes should be made to the way EPSDT covers Applied Behavior Analysis (ABA):

1. ABA and Behavioral Therapy should be separate treatments and ABA should be solely guided by the DHP regulations governing behavior analysts.  Often behavioral therapy run by non-LBAs looks more like counseling or behavior modification and not the science of ABA.  It is confusing to lump the professions together, and the distinction is necessary.

2. ABA should not be limited by location, but the services should be provided in the location that is most appropriate to the needs of the individual.  This may be a clinic, the community, a social group, or the home, or other place that meets the needs of the individual.  ABA clinics should be required to obtain a license that is appropriate to their business, which is not available at this time.

3. ABA does not necessarily need to be provided individually, but may be appropriate for some individuals in a group setting.  The service should be available in a group setting or one-on-one with an individual as is dictated by the individual’s needs and outlined in the ISP. 

4. ABA therapy does not end at age 21. For most, if not all of our clients, need us more than ever after age 21. There is continued need to treat developmenatal delays that impact a persons ability to live a more independent and meaningful life well into their adult years. And with the wait list for access to Medicaid Waviers, many individuals do not get the help and support they need until they are well into their late teens or early 20s. We are losing an entire group of individuals that could benefit from ABA services due to the long DD wait list and then compounded by the age restriction of under 21. I urge you to please look into increasing the age to 22 and over to maximize the benefit of services to adults. 

I appreciate the hard work that has gone into revising these regulations and thank you, again, for the opportunity to comment. 

Megan Valentine, BCBA, LBA

Compass Counseling Services of NOVA

Regional Clinical Director