236 comments
Under Critical Features and Service Components:
Under Medical Necessity Criteria
Lastly, It is noted the Behavior change plan can substitute as the ISP. That may be functional if Medicaid is willing to wait 30 days for an ISP to be attached to a comprehensive needs assessment as the behavior change plan may not be completed until a provider is at most, 3 - 4 sessions in. To further explain, behavior change plans are completed prior to the start of the behavior change phase. Once that phase nears completion or is completed, a generalization phase plan is a completed, then generalization phase starts. The behavior change plan is no longer a focus, the generalization plan becomes the focus.
ARTS manual Chapter 4 pg 35
Service Units and Limitations ? See ARTS Reimbursement Structure for billing codes and units for outpatient services: is available online: http://www.dmas.virginia.gov/Content_pgs/bh-home.aspx.
This does not appear to be a working link.
In APP 6, page 6, It states "ISP must be reviewed as necessary at a minimum of every 30 calendar days or more frequently depending on the youth's needs." Please clarify as an individual must be at least 18 years of age to qualify.
In the service auth section for Mobile Crisis it indicates that the service is initially registered for up to 32 units and if additional time is required an authorization is submitted that is no greater than 72 hours long. This reads as though the 72 hours is in addition to the first 32units of the registration. Please clarify whether mobile crisis can be for a total of 72 hours from the time of initiation of services or for 72 hours in addition to however long it took to use the 8 hours from the initial registration, as well as the length of stay for the initial registration.
H2012-ABA treatment planning, performed by a psychologist, BCBA-D, or BCBA, which includes the development and revision of treatment plan and goals, data analysis, and real-time, direct communication with the participant's other service providers is essential to ensure the following: effects of independent variables (treatment) are assessed after each session is completed to assess ongoing progress, teaching components are monitored closely through comprehensive data analysis, and adjustments can be made frequently to the behavior support plan. It is vital that each LHMP be given a set amount of treatment planning hours per month for each beneficiary to ensure progress is made.
Upon reviewing the units that will allotted per client, it seems as though there is a major reduction in the amount of time allowed. 28 hours a week is not enough time for counselors to effectively assist clients. This will only increase clients going in and out of services. It seems that they will be more inclined to enter crisis 4x a month versus 2x a month if given a continued stay. I think based on the current nature of things and the new issues clients are facing now that this should be reconsidered for a higher number. The current limit on units now (56 hours) is already a stretch given limited appointment availability with psychotherapists, physicians, and even walk ins. Many if not all practitioners offices have limited appointments that are sometimes 1 week out. Clients need assistance navigating this as well as time to get these things accomplished. I also want to point out that crisis clients are not always in the best head space and can prove to be challenging. They often require redirecting, which can take upwards of an hour which places constraints on getting things accomplished in a week with reduced hours.
Request for code to be added for treatment planning and data/progress analysis outside of assessment period that is not concurrent with face to face implementation or programming
Request for code to be added for creation of resources for communication and treatment
I am writing as an individual concerned with billing limitations placed on Board Certified Assistant Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework and fieldwork hours are not geared towards just providing direct services, they cover: proper supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis, assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas, employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients could be negatively impacted as a result of this change, with hundreds of other clients potentially impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA therapy services for children with autism and developmental delays is a significant risk with this change.
For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf
It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS funding under the Therapeutic Consultation service, which is similar in scope/practice (info here):
https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/
As a current Board Certified Assistant Behavior Analysts/Licensed Assistant Behavior Analyst (BCaBA/LaBA), I am writing to express my concerns with billing limitations placed on BCaBA/LaBA’s in the draft iteration of the DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework and fieldwork hours are not geared towards just providing direct services, they cover: proper supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis, assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas, employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients could be negatively impacted as a result of this change, with hundreds of other clients potentially impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA therapy services for children with autism and developmental delays is a significant risk with this change.
For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf
It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS funding under the Therapeutic Consultation service, which is similar in scope/practice (info here): https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/
I am writing as BCBA/LBA who is concerned with billing limitations placed on Board Certified Assistant Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework and fieldwork hours are not geared towards just providing direct services, they cover: proper supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis, assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas, employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients could be negatively impacted as a result of this change, with hundreds of other clients potentially impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA therapy services for children with autism and developmental delays is a significant risk with this change.
For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf
It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS funding under the Therapeutic Consultation service, which is similar in scope/practice (info here):
https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/
I am writing as an individual concerned with billing limitations placed on Board Certified Assistant
Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the
DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with
their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia
Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are
qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain
assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed
Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and
require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework
and fieldwork hours are not geared towards just providing direct services, they cover: proper
supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis,
assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training
here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas,
employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients
could be negatively impacted as a result of this change, with hundreds of other clients potentially
impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA
therapy services for children with autism and developmental delays is a significant risk with this change.
For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is
notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of
training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf
It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS
funding under the Therapeutic Consultation service, which is similar in scope/practice (info here):
https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/
I am writing as an individual concerned with billing limitations placed on Board Certified Assistant Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are
qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework and fieldwork hours are not geared towards just providing direct services, they cover: proper supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis, assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas, employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients
could be negatively impacted as a result of this change, with hundreds of other clients potentially impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA
therapy services for children with autism and developmental delays is a significant risk with this change.
For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf
It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS funding under the Therapeutic Consultation service, which is similar in scope/practice (info here):
https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/
I am writing as an individual concerned with billing limitations placed on Board Certified Assistant Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework and fieldwork hours are not geared towards just providing direct services, they cover: proper supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis, assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas, employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients could be negatively impacted as a result of this change, with hundreds of other clients potentially impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA therapy services for children with autism and developmental delays is a significant risk with this change.
For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf
It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS funding under the Therapeutic Consultation service, which is similar in scope/practice (info here):
https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/
I am writing as an individual concerned with billing limitations placed on Board Certified Assistant
Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the
DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with
their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia
Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are
qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain
assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed
Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and
require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework
and fieldwork hours are not geared towards just providing direct services, they cover: proper
supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis,
assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training
here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas,
employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients
could be negatively impacted as a result of this change, with hundreds of other clients potentially
impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA
therapy services for children with autism and developmental delays is a significant risk with this change.
For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is
notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of
training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf
It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS
funding under the Therapeutic Consultation service, which is similar in scope/practice (info here):
https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/
I am writing as an individual concerned with billing limitations placed on Board Certified Assistant Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed Behavior Analyst. BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework and fieldwork hours are not geared towards just providing direct services, they cover: proper supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis, assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas, employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients could be negatively impacted as a result of this change, with hundreds of other clients potentially impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA therapy services for children with autism and developmental delays is a significant risk with this change. For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of training/expertise: https://www.abainternational.org/media/152236/codeconversiontable.pdf It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS funding under the Therapeutic Consultation service, which is similar in scope/practice (info here): https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/
I am writing as an individual concerned with billing limitations placed on Board Certified Assistant Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework and fieldwork hours are not geared towards just providing direct services, they cover: proper supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis, assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas, employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients could be negatively impacted as a result of this change, with hundreds of other clients potentially impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA therapy services for children with autism and developmental delays is a significant risk with this change.
For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf
It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS funding under the Therapeutic Consultation service, which is similar in scope/practice (info here): https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/
I am writing as an individual concerned with billing limitations placed on Board Certified Assistant
Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the
DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with
their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia
Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are
qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain
assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed
Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and
require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework
and fieldwork hours are not geared towards just providing direct services, they cover: proper
supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis,
assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training
here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas,
employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients
could be negatively impacted as a result of this change, with hundreds of other clients potentially
impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA
therapy services for children with autism and developmental delays is a significant risk with this change.
For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is
notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of
training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf
It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS
funding under the Therapeutic Consultation service, which is similar in scope/practice (info here):
https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/
I am writing as an individual concerned with billing limitations placed on Board Certified Assistant Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework and fieldwork hours are not geared towards just providing direct services, they cover: proper supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis, assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas, employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients could be negatively impacted as a result of this change, with hundreds of other clients potentially impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA therapy services for children with autism and developmental delays is a significant risk with this change.
For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf
It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS funding under the Therapeutic Consultation service, which is similar in scope/practice (info here): https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/
I am writing as an individual concerned with billing limitations placed on Board Certified Assistant Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework and fieldwork hours are not geared towards just providing direct services, they cover: proper supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis, assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas, employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients could be negatively impacted as a result of this change, with hundreds of other clients potentially impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA therapy services for children with autism and developmental delays is a significant risk with this change.
For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf
I am writing as a current BCaBA, LaBA concerned with billing limitations placed on Board Certified Assistant Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the DMAS ABA therapy manual. I have been working with my client's and families for several years completing the services under the supervision of a BCBA/LBA that are now being removed from the DMAS updates. Please enable BCaBA/LaBA’s to use the billable codes that are in line with their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework and fieldwork hours are not geared towards just providing direct services, they cover: proper supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis, assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas, employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients could be negatively impacted as a result of this change, with hundreds of other clients potentially impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA therapy services for children with autism and developmental delays is a significant risk with this change.
For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf
It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS funding under the Therapeutic Consultation service, which is similar in scope/practice (info here):
https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/
I am writing as an individual concerned with billing limitations placed on Board Certified Assistant Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework and fieldwork hours are not geared towards just providing direct services, they cover: proper supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis, assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas, employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients could be negatively impacted as a result of this change, with hundreds of other clients potentially impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA therapy services for children with autism and developmental delays is a significant risk with this change.
I am writing as an individual concerned with billing limitations placed on Board Certified Assistant Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework and fieldwork hours are not geared towards just providing direct services, they cover: proper supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis, assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas, employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients could be negatively impacted as a result of this change, with hundreds of other clients potentially impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA therapy services for children with autism and developmental delays is a significant risk with this change.
For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf
It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS funding under the Therapeutic Consultation service, which is similar in scope/practice (info here): https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/
For any client who qualifies for ABA, it is always a goal to have a client ultimately have access to the least restrictive environment. With behaviors that can change based on their environment, school is a factor in the child's success across different settings. In my experience, several families report their children having behaviors within school that are not present within the home from counties in which their is no ABA program provided by the school system and are interested in ABA services being provided in the school. The draft states under services that will not be covered by medicaid as "Services provided by a local education agency. ABA may only be provided in the school setting when the purpose is for observation and collaboration related to behavior and skill acquisition (not direct therapy) and services have been authorized by the school, parent and provider and included in the ISP." I request that further definitions of direct therapy vs. observation and collaboration specifically within schools be added. Teacher training would be essential in helping the child succeed across environments and people, and training is most successful when modeling interventions with clients is included. However, I am concerned that modeling these interventions could be interpreted as "direct services". Speaking with the teachers about the treatment plan and observing the child without working directly with the child may not be effective in supporting the child's school team and ensuring that implementation is accurate with the teacher. It would be most effective if interventions were able to be observed by the teacher as the client receives ABA therapy from the provider within the school setting.
I am writing as an individual concerned with billing limitations placed on Board Certified Assistant Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework and fieldwork hours are not geared towards just providing direct services, they cover: proper supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis, assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas, employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients could be negatively impacted as a result of this change, with hundreds of other clients potentially impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA therapy services for children with autism and developmental delays is a significant risk with this change.
For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf
It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS funding under the Therapeutic Consultation service, which is similar in scope/practice (info here): https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/
I am writing as an individual concerned with billing limitations placed on Board Certified Assistant Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework and fieldwork hours are not geared towards just providing direct services, they cover: proper supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis, assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas, employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients could be negatively impacted as a result of this change, with hundreds of other clients potentially impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA therapy services for children with autism and developmental delays is a significant risk with this change.
For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf
It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS funding under the Therapeutic Consultation service, which is similar in scope/practice (info here): https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/
Why can’t BCaBA/LaBAs bill anymore? They’re licensed and go through extensive training.
The goal of Community Stabilization services is to continue to stabilize the individual within their community and support the individual and/or support system during the period between either 1) an initial Mobile Crisis Response and entry in to an established follow-up service at the appropriate level of care or 2) transitional step-down from a higher level of care if the next level of care service is identified but not immediately available for access.
"Community Stabilization services are permitted through a registration process for 7 calendar days/224 units. Submission of registrations must be within 1 business day of admission. "
"submitted no earlier than 24 hours before the requested start date of the continued stay. "
Does this include weekends? So if the continued stay authorization needs to be submitted on Sunday, is it not okay to submit it on the Friday before to prevent the lapse.
Just clarification here: So if the services is provided only by an individual like a QMHP, it is considered an individual response and billed at that rate, however if there is designation of a TEAM response, Ie a QMHP and Licensed person and only the QMHP person responds is it not billable or does it bill at the individual QMHP rate )
Can there be some specific guidance our outline of what the LOCUS assessment consist off and what the Crisis Education Prevention Plan needs to include? Or will there be formatted documents given to agencies.
The draft states that the assessment for community stabilization will be the LOCUS.
Currently the CNA is completed and can be used to recommend and initiate other services. Will the LOCUS be able to be utilized in that manner.
Can you clarify if the consumer needs to have experienced a behavioral health crisis within 72 hours or if they need to have had contact with Mobile Crisis Response services within 72 hours.
Individuals must meet all of the following criteria:
1. The individual has experienced a recent behavioral health crisis (within 72 hours of admission) or the individual is transitioning from a higher level of care and requires short-term support with identifying and/or engaging in the services necessary to maintain safety and stability in the community;
Also the draft states that an intervention with Emergency Services for pre-admission screening to acute hospitalization is considered a mobile crisis response.
In those cases do the calls/referral to community stabilization need to come from the regional call center, or can the local emergency services make the referral to the community crisis stabilization program and it meet the requirement for admission to the crisis stabilization program.
I am writing as an individual concerned with billing limitations placed on Board Certified Assistant Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework and fieldwork hours are not geared towards just providing direct services, they cover: proper supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis, assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas, employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients could be negatively impacted as a result of this change, with hundreds of other clients potentially impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA therapy services for children with autism and developmental delays is a significant risk with this change.
For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf
It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS funding under the Therapeutic Consultation service, which is similar in scope/practice (info here): https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/
I am writing as an individual concerned with billing limitations placed on Board Certified Assistant Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework and fieldwork hours are not geared towards just providing direct services, they cover: proper supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis, assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas, employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients could be negatively impacted as a result of this change, with hundreds of other clients potentially impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA therapy services for children with autism and developmental delays is a significant risk with this change.
For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf
It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS funding under the Therapeutic Consultation service, which is similar in scope/practice (info here): https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/
I am writing as an individual concerned with billing limitations placed on Board Certified Assistant
Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the
DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with
their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia
Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are
qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain
assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed
Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and
require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework
and fieldwork hours are not geared towards just providing direct services, they cover: proper
supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis,
assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training
here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas,
employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients
could be negatively impacted as a result of this change, with hundreds of other clients potentially
impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA
therapy services for children with autism and developmental delays is a significant risk with this change.
For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is
notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of
training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf
It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS
funding under the Therapeutic Consultation service, which is similar in scope/practice
Thank you for your time,
Kate Shillingford
I am writing as an individual pursuing BCBA concerned with billing limitations placed on Board Certified Assistant Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed Behavior Analyst. BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and require 1300 supervised fieldwork hours prior to taking their board certification exam.
These coursework and fieldwork hours are not geared towards just providing direct services, they cover: proper supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis, assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training
here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas, employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients could be negatively impacted as a result of this change, with hundreds of other clients potentially impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA therapy services for children with autism and developmental delays is a significant risk with this change.
For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is
notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of
training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf
It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS
funding under the Therapeutic Consultation service, which is similar in scope/practice (info here):
https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/
I am writing as an individual concerned with billing limitations placed on Board Certified Assistant Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework and fieldwork hours are not geared towards just providing direct services, they cover: proper supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis, assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas, employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients could be negatively impacted as a result of this change, with hundreds of other clients potentially impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA therapy services for children with autism and developmental delays is a significant risk with this change. For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS funding under the Therapeutic Consultation service, which is similar in scope/practice (info here): https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/
Under the BACB, BCaBAs are allowed to complete the same tasks and job roles as a BCBA under the supervision of a BCBA. Therefore, it should follow that billing abilities and limitations should be similar if not the same. Having this limitation will greatly affect companies and the way they duties are performed.
I am writing as an individual concerned with billing limitations placed on Board Certified Assistant Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework and fieldwork hours are not geared towards just providing direct services, they cover: proper supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis, assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas, employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients could be negatively impacted as a result of this change, with hundreds of other clients potentially impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA therapy services for children with autism and developmental delays is a significant risk with this change.
For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf
It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS funding under the Therapeutic Consultation service, which is similar in scope/practice (info here): https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/
I am writing as a BCBA, LVA concerned with billing limitations placed on Board Certified Assistant Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework and fieldwork hours are not geared towards just providing direct services, they cover: proper supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis, assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas, employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients could be negatively impacted as a result of this change, with hundreds of other clients potentially impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA therapy services for children with autism and developmental delays is a significant risk with this change.
For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf
It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS funding under the Therapeutic Consultation service, which is similar in scope/practice (info here): https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/
I am writing as an individual concerned with billing limitations placed on Board Certified Assistant Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework and fieldwork hours are not geared towards just providing direct services, they cover: proper supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis, assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas, employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients could be negatively impacted as a result of this change, with hundreds of other clients potentially impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA therapy services for children with autism and developmental delays is a significant risk with this change.
For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf
It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS funding under the Therapeutic Consultation service, which is similar in scope/practice (info here): https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/
I am writing as an individual concerned with billing limitations placed on Board Certified Assistant Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework and fieldwork hours are not geared towards just providing direct services, they cover: proper supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis, assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas, employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients could be negatively impacted as a result of this change, with hundreds of other clients potentially impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA therapy services for children with autism and developmental delays is a significant risk with this change.
For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf
It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS funding under the Therapeutic Consultation service, which is similar in scope/practice (info here): https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/
I am writing as an individual concerned with billing limitations placed on Board Certified Assistant Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework and fieldwork hours are not geared towards just providing direct services, they cover: proper supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis, assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas, employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients could be negatively impacted as a result of this change, with hundreds of other clients potentially impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA therapy services for children with autism and developmental delays is a significant risk with this change.
For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf
It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS funding under the Therapeutic Consultation service, which is similar in scope/practice (info here): https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/
I am writing as an individual concerned with billing limitations placed on Board Certified Assistant Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework and fieldwork hours are not geared towards just providing direct services, they cover: proper supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis, assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas, employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients could be negatively impacted as a result of this change, with hundreds of other clients potentially impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA therapy services for children with autism and developmental delays is a significant risk with this change.
For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf
It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS funding under the Therapeutic Consultation service, which is similar in scope/practice (info here): https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/
In addition, I am currently practicing as a Clinical Supervisor since January of 2021. I have completed my coursework to become a BCaBA and I have a BS in Social Psychology. I am licensed in the Commonwealth of Virginia to practica as a BCaBA and certified as a BCaBA by the BACB. If this change goes into affect, the decision would reduce my job back to a Behavior Specialist and I have worked hard to reach my position as a Clinical Supervisor. I implore you to change these limitations and allow BCaBA's to continue to practice. Thank you for your time.
I am writing as an individual completing ABA coursework who is concerned with billing limitations placed on Board Certified Assistant Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework and fieldwork hours are not geared towards just providing direct services, they cover: proper supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis, assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas, employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients could be negatively impacted as a result of this change, with hundreds of other clients potentially impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA therapy services for children with autism and developmental delays is a significant risk with this change.
For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf
It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS funding under the Therapeutic Consultation service, which is similar in scope/practice
It appears that the Dept is attempting to define specific services within the universe of what is being provided and narrow them into framework toward what end? ABA is defined under regs of the Board of medicine and the BACB organization. It should be left as such and not conflated into a mix including LMHPs/LMHP-Rs who have no scope of experience providing specifically classic ABA therapy. That is singularly the domain of LBAs and those under. If the Dept is seeking to better define Behavioral Therapy Services and support then they should concentrate on that and remove out ABA tx as a singular separate service as it is.
MST and FFT are long-standing treatment modalities that already exist in terms of those coordinating needed care for children and their guardian families and FFT with focused intervention on the relationships of people in a home as it impacts children.
Shortline: this document is confusing/diffuse and is conflating quite a bit of regs/coding/tx approaches without a clear purpose objective by mixing language, staff qualifications etc
It appears that the Dept is attempting to define specific services within the universe of what is being provided and narrow them into framework toward what end? ABA is defined under regs of the Board of medicine and the BACB organization. It should be left as such and not conflated into a mix including LMHPs/LMHP-Rs who have no scope of experience providing specifically classic ABA therapy. That is singularly the domain of LBAs and those under. If the Dept is seeking to better define Behavioral Therapy Services and support then they should concentrate on that and remove out ABA tx as a singular separate service as it is.
MST and FFT are long-standing treatment modalities that already exist in terms of those coordinating needed care for children and their guardian families and FFT with focused intervention on the relationships of people in a home as it impacts children.
Shortline: this document is confusing/diffuse and is conflating quite a bit of regs/coding/tx approaches without a clear purpose objective by mixing language, staff qualifications etc
It appears that the Dept is attempting to define specific services within the universe of what is being provided and narrow them into framework toward what end? ABA is defined under regs of the Board of medicine and the BACB organization. It should be left as such and not conflated into a mix including LMHPs/LMHP-Rs who have no scope of experience providing specifically classic ABA therapy. That is singularly the domain of LBAs and those under. If the Dept is seeking to better define Behavioral Therapy Services and support then they should concentrate on that and remove out ABA tx as a singular separate service as it is.
MST and FFT are long-standing treatment modalities that already exist in terms of those coordinating needed care for children and their guardian families and FFT with focused intervention on the relationships of people in a home as it impacts children.
Shortline: this document is confusing/diffuse and is conflating quite a bit of regs/coding/tx approaches without a clear purpose objective by mixing language, staff qualifications etc
30 day treatment plan revisions are typically in effect/done for high intensity Emergent crisis type care. Again what is the purpose objective here?
I am writing as an individual concerned with billing limitations placed on Board Certified Assistant
Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the
DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with
their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia
Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are
qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain
assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed
Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and
require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework
and fieldwork hours are not geared towards just providing direct services, they cover: proper
supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis,
assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training
here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf
Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas,
employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients
could be negatively impacted as a result of this change, with hundreds of other clients potentially
impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA
therapy services for children with autism and developmental delays is a significant risk with this change.
For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is
notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of
training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf
It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS
funding under the Therapeutic Consultation service, which is similar in scope/practice (info here):
https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/
BCaBAs - the restrictions placed on the codes that BCaBAs can bill for will reduce the amount of services families needing help will be able to find, and does not follow what the Virginia Board of Medicine has licensed them to do. It does not account for their education, supervision, training and Behavior Analyst Board Certification.
Supervision- the requirement to supervise unlicensed staff on a weekly basis puts home and community services at risk, especially if only BCBAs can bill for this activity.
Care Coordination - written as "referrals to medical services." While we welcome collaboration with other disciplines it is not in our scope to make referrals. What is being asked for here is not clear.
Family Involvement - "Direct family involvement in the treatment program is required at a minimum of weekly." This frequency will also be a barrier to families without more guidelines on what the weekly involvement needs to be.
Indirect Activities - Ongoing assessment, data and program review, program development, treatment planning are not accounted for under these codes.
School - service limitation "ABA may only be provided in the school setting when the purpose is for observation and collaboration related to behavior and skill acquisition (not direct therapy)" does not clearly delineate what short term services we can offer to help prevent placement in a more restrictive educational environment.
Thank you