I have concerns with the proposed 20 hour weekly cap on ABA services, the requirement for an ASD diagnosis prior to authorization, and potential restrictions on telehealth initial assessments. While I understand the importance of appropriate oversight and ensuring services are medically necessary, these changes will create additional barriers for families who already struggle to access care.

A 20 hour cap does not account for each child's individual needs. Some children require more than 20 hours a week to address significant deficits and interfering behaviors compared to there typical aged peers. Treatment hours should be based on individualized medical necessity rather than a set limit. Although exceptions may be available, the process must be accessible and timely so that children are not denied the level of care their treatment plans support. Also what does the 20 hour a week cap entail? Is it 97153 or all units together a week? We need to know what it all entails. 

Requiring an ASD diagnosis before ABA authorization is also concerning given the lengthy waitlists many families face to see qualified diagnostic providers. Low income families may not have the resources to pay for private evaluations or travel long distances to obtain a diagnosis. These delays prevent children from accessing needed services during critical developmental periods.

Additionally, restricting telehealth initial assessments will further limit access, particularly in rural areas where BCBAs are scarce or unavailable. When clinically appropriate, telehealth allows families to connect with qualified providers who can assess their needs. Requiring in-person assessments in every circumstance will cause some families to miss out on needed services due to their location and due to how far they are able to travel to find services for their children.

The combined impact of these changes will affect low income families and children in rural communities. Families with financial resources may have more options to obtain private evaluations, travel for assessments, or seek additional services, while families relying on Medicaid may have very few alternatives. This creates a risk that access to care will depend more on a family's income and location than on a child's clinical needs.

I encourage DMAS to reconsider the 20 hour cap, the ASD diagnosis before authorizing ABA, and telehealth assessment options when clinically appropriate. As a BCBA, I believe it is essential that policies prioritize the client first and equitable access to medically necessary treatment. Children should receive services based on their individual needs, and families should not be placed at a disadvantage because of financial limitations, diagnostic waitlists, or a lack of providers in their communities.

Best,

Taylor Gale