We, the Public Policy Committee of the Virginia Association for Behavior Analysis, have the following comments on the Telehealth Services Supplement.

We are very concerned that ABA codes are not included in the reimbursement tables.  ABA providers have been using telehealth for a variety of services and excluding them prevents clients from accessing services for whom this modality is appropriate and necessary given their circumstances and clinical disposition.

Specifically, although we do initial assessments in person, there are often times that we must observe and assess from a remote location. For example, if a behavior does not occur regularly, or if the behavior analyst’s physical presence produces an “observer effect.”.  Additionally, remote supervision can be more effective in some circumstances, as it allows supervisors to be unobtrusive. It also more readily allows professionals with highly specialized expertise in a particular specialty area who do not live in the geographic region to provide consultation.  Another example is when a youth is medically fragile and is not cleared by a doctor to participate in in-person therapy.  Finally, parent training is often more effective remotely as schedules can be better accommodated.

We respectfully request that the following codes be added to Table 3: 97151, 97153, 97155, and 97156.

We thank you for the opportunity to comment and welcome your continued partnership.