In reviewing the comments posted to date, I concur with the submission below and am re-posting to underscore that agreement.

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, possibly at lower rates or with different modifiers than BCBA’s. 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. 

BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework and fieldwork hours are not geared towards just providing direct services, they cover: proper supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis, assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf 

For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of training/expertise: https://www.abainternational.org/media/152236/codeconversiontable.pdf  

It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS funding under the Therapeutic Consultation service, which is similar in scope/practice (info here): https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/