I am writing as an individual is extremely concerned about the proposed billing limitations for BCaBA's. BCaBA's have strict requirements that they must meet in order to qualify for this certification (see https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf for more information). BCaBA's not only complete additional coursework but also complete a minimum of 1300 supervised hours as well as work under the supervision of a BCBA. BCaBA's are working within their scope of practice: According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’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 Behavior Analyst. 

This proposed change will seriously impact clients currently benefiting from services provided by BCaBA's and will limit a field that is already strained on competent providers for all the clients who need and deserve the services provided to them. 

Please reconsider the current proposals to maintain quality and quantity service delivery to families in need and keep the BCaBAs able to work as per their certified skills