I am writing as an individual concerned with ??illing limitations placed on ??oard Certified Assistant ??ehavior Analysts/Licensed Assistant ??ehavior Analysts (??Ca??A/La??A) in the draft iteration of the DMAS A??A therapy manual. Please ena??le ??Ca??A/La??A’s to use the ??illable codes that are in line with their training, possibly at lower rates or with different modifiers than ??C??A’s. According to Virginia Licensure Laws and ??AC?? guidelines for the practice of Applied ??ehavior Analysis, ??Ca??A/La??A’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 ??ehavior Analyst. ??Ca??A’s receive 225 hours of specific A??A coursework following (or as part of) their college and require 1300 supervised fieldwork hours prior to taking their ??oard certification exam. These coursework and fieldwork hours are not geared towards just providing direct services, they cover: proper supervision/training of staff, writing programming/??ehavior plans, ethical practice of ??ehavior analysis, assessment, and data analysis. Please see the latest task list covering the extent of ??Ca??A/La??A training here: https://www.??ac??.com/wp-content/uploads/2020/05/170113-??C??A-??Ca??A-task-list-5th-ed-.pdf Paragon Autism Services, a provider of A??A services in the Fredericks??urg and Wood??ridge areas, employs ??Ca??A/La??A’s for all ??ut one of their Clinical Supervisor positions. Over 60 of their clients could ??e negatively impacted as a result of this change, with hundreds of other clients potentially impacted at other employers of ??Ca??A/La??A’s throughout the state. Removing access to necessary A??A therapy services for children with autism and developmental delays is a significant risk with this change.

For additional supporting reference, please see the A??AI’s code ??reakdown in the link ??elow, where it is notable that ??Ca??A’s/La??A’s are a??le to ??ill for relevant A??A codes according to their level of training/expertise: https://www.a??ainternational.org/media/152236/codeconversiontable.pdf

It is also notable that ??Ca??A/La??A’s are still currently allowed to provide A??A through Virginia DMAS funding under the Therapeutic Consultation service, which is similar in scope/practice (info here): https://www.virginiaa??a.org/??ecome-a-therapeutic-consultation-provider/