I feel that clarification is needed under Service Definition/Description for who is a Behavior Consultant. I think that it is pertinent that you list titles such as LBA/BCBA, PBSF, LCSW, LPC, etc.   

I feel that Nursing consultation should be added as a service option. It can often be beneficial to have a nursing consult to discuss unfamiliar or complicated diagnoses, medications, and medical concerns that may need to have additional medical follow up by specialists that may not have been previously considered by the overwhelmed and reducing number of medical doctors who provide services for the ID/ DD population. 

Under Service Documentation Requirements (pg. 153) For behavioral consultation, the annual review must include graphed or tabled data that is trended across the first three quarters; Behavior consultation is only approved for 180 days = 6 months therefore unless service authorizations are going to be approved for longer periods of time, I am not sure how we are going to be held accountable to trend data for 9 months with an approval of only 6 months. 

In the same section, A contemporaneously signed and data final disposition summary that is forward to the support coordinator within 30 days following the end of this service and that includes: Providers do not have access to WaMS after the end date of the service authorization. This makes it impossible to forward the final disposition 30 days after services are terminated. I would suggest to continue following the previous regulations and do 30 days prior or after.

Lastly, believe that All therapists should be listed under code 97139, instead of Occupation Therapy, Speech Therapy, and BCBA being listed at 97139 and LBA/BCBA, PBSF, LCSW, LPC, Psych, and Recreation Therapy listed under 97530. I think it would be only right that all Therapeutic Consultation services should reimbursed at the same rate of pay. BCBA's, LBA/BCBA, PBSF, LCSW, LPC 's all provide Behavior Consultation services. We are all held to the same standards and expectations, so it does not seem justified that BCBA's would fall under a different code (and a higher reimbursement rate) than those who are not BCBA's. Recreation Consultants also provide a very valuable service to the individuals and supporters we serve. The services they provide often work in conjunction with other therapeutic disciplines and they deserve to be classified and viewed with the same type of professional respect.