There is no mention of codes for billing for when the client is not present within the new drafts. This greatly impacts organizations who target populations that need after school and evening support along with populations that lives in more rural areas of Virginia where services are already limited. The regulations state that "Supervision shall include a review of progress notes and data and dialogue with supervised staff about the youth’s progress and effectiveness of the ISP."

The current billing code as proposed by these drafts and the regulations definition of supervision, will both decrease the quality of service provided to our families and could have potential harmful effects, like putting client safety in jeopardy, to the clients that we serve. This will also greatly impact both the quality of supervision provided to clinicians and the quality of treatment planning conduced by LBAs/LaBAs since either party will be unable to give their undivided attention to the above topics the regulations state need to be covered within a supervision. 

Request for the supervision code to be updated to include both direct and indirect time spent with the clinician and client. 

Request for code to be added for treatment planning and data/progress analysis outside of assessment period that is not concurrent with face to face implementation or programming.

Request for code to be added for creation of resources for communication and treatment. 

 

Within the current draft of the regulations, care coordination is a required part of services; however, there is no code currently that accounts for the direct or indirect time that an LBA/LaBA spends providing care coordination.

Request for code be added for care coordination and case consultation.

 

I appreciate this opportunity to voice my concerns and truly hope they will be taken into consideration.