Hello, my name is Eli Newcomb and I am a behavior analyst who oversees the provision of a number of behavioral services. There are some 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-licensed individuals looks more like counseling or behavior modification and not the more specific discipline and practice of ABA. It is confusing to group multiple and different professions as one, and the distinction is necessary, as ABA has been a well-established discipline for nearly a half century. 

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. 

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