Thank you for sending these proposed changes out for public comments. I am a BCBA in the area of applied behavior analysis and would like to provide comments on how these proposed changes will directly impact some of my current clients.

I want to start by first commenting about the new diagnosis criteria for Autism Spectrum Disorder (F84.0) that is now required for services. The manual now states, "A comprehensive diagnostic evaluation conducted in-person confirming the diagnosis of ASD by a LMHP acting within their scope of practice that includes an evidenced based diagnostic tool such as one of the following: i. Autism Diagnostic Review (ADI-R) ii. Autism Diagnostic Observation Schedule (ADOS) iii. Childhood Autism Rating Scale (CARS). Documentation shall include the name, credential and Type 1 NPI of the evaluator " The points of concern for this statement includes 1) that the assessment needs to be completed in person, 2) that the paperwork requires the NPI number listed, and 3) it lists specific diagnostic tests. 1) The wait lists for an autism diagnosis can be multiple years long depending on the area or if there is not a diagnosing provider in a particular area. Some families seek a diagnosis from a telehealth provider to remediate these barriers. The current wording in the document would prevent those families from receiving services, even if the client has a diagnosis. 2) some diagnosing providers do not provide their NPI number on the diagnostic paperwork. The ABA provider can search the diagnosing provider's NPI number to add to the ISP as an alternative to it being required on the diagnostic paperwork. 3) The specific diagnostic evaluations listed are a great starting off point, however it is not an exhaustive list of evidence based diagnostic assessments. The document should clarify the list provided includes examples and are not the only three accepted evidence based assessments. 

These changes to the wording need to be completed or some families who have children with a diagnosis will have to seek a second diagnosis because their current diagnosis does not meet the listed criteria. That will increase waitlists and potentially cause families to have to travel significant distances if they are in a rural area.

Due to the change in diagnostic criteria required for ABA services, I recommend the initial and continued stay Medicaid form be edited to have boxes to easily provide information about the client's diagnosis or information about the waitlists the client is on. 

I want to continue by commenting on the schedule requirements listed on page 32 for authorizations over 20 hours. I am seeking clarification on if this is 20 cumulative hours or 20 hours of 97153 services. 

In conclusion, I recommend the comments be reviewed after the document is closed for commenting, changes be made to the manual/initial and continued stay forms, then the updates be posted on the DMAS website with an effective date 60-90 in advance. This will give families time to contact their diagnosing providers to get updated paperwork or potentially get on another waitlist. Implementing these changes so quickly without providing adequate notification times will cause undo stress to the families currently receiving services and diagnosing providers, both of which are already overwhelmed without having to scramble to make these changes. I hope you take this comment into consideration and make changes accordingly.