Thank you for the opportunity to make comments on these regulations. Below are some suggestions, questions and feedback regarding the Therapeutic Behavior Consultation services.

Currently TC services are allowed under the CL and FIS Waiver but it is suggested that Therapeutic Behavior consultation is also an allowable service under the Building Independence Waiver.  Individuals living more independently and who may have less overall support needs are still in need of Therapeutic Consultation services in order to increase independence and remain safe and productive members of the community. 

Service Units and Limits Section C.

C1 Service Units- we strongly suggest and plead with DMAS to allow for 15 min increments when billing for services- this will allow for more accurate billing.  If this is not changed then please provide more specific guidance on how to accurately bill for 15 min increments. 

C3- Please list the paperwork that is considered "in-kind".  There is some confusion about quarterly reports specifically.   These are required reports with required documentation, please clarify

C5b&5c- Can this be written more clear? i.e. Behavior Support Plans should be designed and developed within 6 months of the start of service and submitted in WaMS upon subsequent approvals.  But, are there exceptions to this 6 month period and what type of documentation and information will be required to renew if a plan has not be completed?

Also,  how will we account for ISP years that only have one month left? Do we request services for 30 days and then another 150 days, or will we be able to request the initial 6 months straight through the ISP year?  

E1a- Can this be removed as a requirement? TC providers can request this document but should not be required to have it on file since TC providers are not the ones who complete this assessment and do not have easy access to it.  Instead, it is suggested that the SIS is uploaded in WaMS upon completion. That way all providers and services have access to it at all times.  

E1c(1)iv- Functional Behavior Assessment- can this be referred to in the BSP, but instead be a separate document? Right now it reads as if it must be part of the BSP, but many complete/develop longer and more formal FBA's that would make a BSP too long if included in the plan.

E1c(1)xi- Change to "as indicated" or better define additional recommendations- linkages is one suggestion, but recommendations is very broad, there are behavioral recommendations, support recommendations, strategy recommendations, provider recommendations, service recommendations etc.  

E1c(1)xii- please define appropriate signatures- what signatures are required, just the individual/guardian and the consultant at minimum?

Thank you!