I am writing as an individual concerned with billing limitations placed on Board Certified Assistant Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the DMAS ABA therapy manual.

Please enable BCaBA/LaBA’s to use the billable codes that are in line with their training (97151, 97155, and 97156).

According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are qualified to provide supervision upon completion of the supervision CEU, a bachelors program, supervised fieldwork, and ABA course sequence. 

I believe that no longer allowing BCaBA to bill for assessment, supervision, and parent meetings is a step back for the state of Virginia. States all over the country and providing licensure, and including this highly needed poistion within their policies. 

In addition to regressing the field and impacting the jobs of many individuals in the state of Virgnia, this would impact the service delivery model of ABA for the state. The demand for ABA servcies is incredibly high in the Northern Virginia area, removal of this licensure would only increase the wait times families endure  seeking services. 

There are 

Thank you for your time, 

KayLynn Newton