Recommendations to therapeutic consultaiton services:

1.  Reclassify Positive Behavior Support Facilitators and Certified Recreational Therapist to billing code 97139.

2. Remove telephone calls form non-billable activity.

3. Permit video chat and conferencing - this will help provide services to the rural area or underserved populations and even in urban areas where travel time is a barrier between services.

4. Allow Certified Occuaptional Therapy Assistants, COTA's who are certified by the Commonwealth, to work under the supervision of Occupational therapsit. COTA could be billed at 97530 and OT's will use code 97139.

5. Therapeutic consultation should be allowed under all Wavier programs, inclduing ICFID.

6. Make all documentationa billable activity.

7.  All therapeutic consultantants should recieve a 5% raise to be comaprable to the commercial industry.

8. Standarization of documentation, either in written forms or EMR.

9. Expand therapy services to incldue psychiatry and nurse pracitioner for medication managment.

10. Allow Positive Behavior Support Facilitators, PBSF to have a Positive Behavior Support Assistant, PBSA mirroring the BCBA protocol.