There are several concerns that immediately stand out while reviewing the draft manual in terms of ABA services (beginning pg. 33 of appendix D).  This manual proposes several activities that are stated as "required", however, under the proposed CPT codes, the BCBA/LBA would not be compensated for those required activities such as care coordination, supervision, observation, etc. Care coordination (pg. 35) is an important component of ABA programming, however, care coordination can take large amounts of time when a client is enrolled in several different services.  Clinical supervision is also listed as a required activity (pg. 36), however there are no codes listed specific for supervision. The adaptive behavior treatment with protocol modification code (97155) is not the same as supervision. Supervision can and should be conducted with and without the client present. There are components discussed during supervision meetings that are not appropriate for the client to be present for such as reviewing trends in the client's skill acquisition or addressing problem behaviors. These topics of conversation should not occur with a client present, unless the client is present to be actively involved in his or her own treatment planning.  Another required activity includes “monthly observations of the individual” (pg. 34), which is, again, not a billable activity under the proposed CPT codes. These expectations are time consuming and unrealistic for LBAs or LaBAs who wish to provide quality services to families, while at the same time, still need to earn a living.  Adding or continuing these expectations while removing the possibilities of reimbursement for completing these requirements will directly impact the stability of the practitioners, which, in turn, would negatively impact your consumers who are in need of these necessary services. Reimbursement rates should be increased and/or modifiers added to billing codes to provide an opportunity for service providers to receive reimbursement for the activities that are considered “required” in the manual.  

Another area of concern is regarding the requirement of referrals to medical services (pg. 35). Referring to medical services would not constitute as within the scope of LBAs.  LBAs can and should provide resources to families based on the individual needs of the family (e.g. providing lists of dentists in the area, developmental doctors in the area, etc.). However, requiring LBAs to specifically refer families to medical services such as neurological or psychiatric programs is an unreasonable expectation and puts the LBA at risk of making suggestions that are out of that individual’s scope of practice.

Finally, please do not discredit the education, training and abilities of the BCaBAs by removing the various activities that those individuals are in fact trained and educated to perform.  The BCaBA practices under the oversight and direction of a BCBA and he or she should be able to participate in the practices that they are specifically and carefully trained and supervised for.