I chose to build my career around providing ABA services specifically in a home environment, where many of the most socially significant skills are present and often most challenging, where I can help support families through their hardest moments, and where I can see the greatest lasting changes for the families I serve. When I first read the proposed changes to our Medicaid regs in the state of Virginia, I was floored, because it truly seems like the goal is to eradicate the possibility of providing home-based treatment for our consumers/clients. Because of the way the draft regs are written, which look nice and lucrative if you are providing a clinic-based model, my fear is that more and more LBAs will choose to drift away from home-based work and move more toward clinic-based work only (or that companies' survival will be dependent on clinic-based work, thus eradicating home-based treatment altogether). As the draft regs have made clear, without an available supervisor/LBA/LMHP, services cannot occur, thus creating major limitations in the state of Virginia for the populations we serve.
I do see a few specific and major limitations that I would like to highlight:
Thank you for considering these comments for the future of home-based ABA in light of the proposed Medicaid regulation changes.