1) Thank you for including telehealth in the proposed regulation, as it is a feasible, effective, and beneficial way to provide therapeutic behavior consultation services.

2) Please consider allowing units to be billed in 15 minute increments for more accurate accounting of services provided. 

3) Individuals who have the Building Independence (BI) Waiver do not currently have the option of receiving therapeutic behavior consultation or any other TC service and this should be an allowable service under the BI Waiver.  Individuals living alone or more independently are still in need and meet criteria for therapeutic consultation services.

4) Please consider listing a definition and/or specifics related to in-kind paperwork.  Is it accurate to include person-centered reports, contact notes, plan for supports, and disposition summaries as in-kind paperwork?  Also, since the proposed guidelines are specifically requiring graphs and other information in person-centered reviews, are they considered billable?