Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
Waivered Services [12 VAC 30 ‑ 120]
Action Three Waivers (ID, DD, DS) Redesign
Stage Final
Comment Period Ends 3/31/2021
Previous Comment     Next Comment     Back to List of Comments
3/28/21  5:18 pm
Commenter: Meneika Chandler

Rates for Therapeutic Consultation for LPCs and LCSWs

Peaceable Life Therapeutic Services, Inc. would like to advocate that LPCs and LCSWs who are endorsed to provide Positive Behavioral Supports are able to bill at the highest rate along with “Therapist and BCBAs” as follows: 

97139 Therapeutic Consultation, Therapists/Behavior Analysts/Rehab. Engineers

LPCs and LCSWs who provide Therapeutic Consultation for behavior supports are restricted to billing under 97530 as "other professionals" because we are not considered as qualified to provide Therapeutic Behavioral Consultation as a BA. 

Licensed Professional Counselors are masters level licensed professionals, completing 4000 supervised clinical hours with 200 direct supervision hours under an LPC.  Likewise, LCSWs are masters level licensed professionals, completing 3000 supervised clinical hours with 100 direct supervision hours under an LCSW. In addition to clinical experience, LPC or LCSW with endorsement as a PBSF holds specialized training in evidenced based behavioral support.

Our state struggles to provide quality mental health support to individuals with Developmental Disabilities that also have comorbid conditions related to mental health. In addition to being able to provide interventions for behavioral needs and address behavioral emergencies, PBSFs who are LPCs and LCSWs are uniquely able to integrate resources and strategies related to diagnosed mental health disorders which are contributing to the behavioral needs of the individual as well as evidence based behavioral strategies for behavioral support. 

LPCs and LCSWs holding endorsement as a PBSF offer a specialized level of professional qualification to meet highly complex behavioral and mental health comorbid needs and should be able to bill accordingly.


CommentID: 97450