To whom it may concern,

After reviewing the new regulations, it appears that individuals with a BCaBA credential will be unable to bill for supervision tasks that they are currently able to bill for.   I have been a practicing BCaBA since 2017 and, under the close supervision of a BCBA, have been able to provide supervision for many RBTs that have provided service to many children.  If this policy changes, I would no longer be able to supervise clients or staff in a billable capacity. 

I fear that this will cause many clients that are currently being managed by a BCaBA to lose their much needed services.  

As an example if an agency is Providing services to 30 clients of which 18 are being supervised by a BCBA, and 12 are being supervised by a BCaBA, and the BCaBA is no longer able to bill supervision for the 12 clients, the BCBA would either be responsible for then providing supervision for all 30 clients, or some of the clients would likely lose services, as a caseload of 30 clients exceeds the ethical limits of most Behavior analysts with regards to being able to provide quality services to the individuals they serve. 

I would hope that there will be some ability for individuals that currently hold their BCaBA to continue to provide billable supervision services going forward.  

Thank You.