Many of the changes within the new ABA manual are most welcome and will help to improve our services throughout the state.

1. Please add BCaBAs/LaBAs as supervisors. They have worked hard for their credentials and need to continue to be recognized at the level in which they are able to provide services. Not allowing the BCaBA/LaBA to provide supervisory type services will hinder the number of cases in which companies may be able to see and will leave clients without services especially within more rural areas.
2. Please consider adding an H code, or some other code, that will allow for billing for treatment planning, data analysis, and case coordination/management services. Since these activities are required, they need to be compensated. It is not feasible to do these activities within a protocol modification session with the client within the clinic, home, or community environment. In addition, it is vital that LBAs be able to meet with RBTs and BCaBAs on client cases, without having the client present, as it allows the staff to talk more freely about what is happening and to allow for troubleshooting when needed.
3. Parent involvement is listed as occurring weekly. What should that look like? While this addition in welcome, there are many instances where parents may not be available weekly (ex. single parent working 3 jobs to financially sustain the family). What, if any, consequences may the client suffer as a result? 
4. 97153 is listed as only being able to be administered by a Behavior Technician, however, there may be instances when it would be more appropriate for the LBA to provide those services. There should be a rate that would be appropriate for the LBA to provide this service.
5. For rates, please consider making the rates competitive. It is extremely difficult to stay competitive in today's job market. Reducing any of the rates from the current levels, may leave clients without services especially in the more rural parts of the state where it is already difficult to find and train staff. Reducing rates, which in turn may lead to reduced wages, will make the access to services even more difficult for clients.