In reviewing the proposed changes to the billing codes for ABA services, several concerns for the feasibility of continuing quality in-home ABA services, especially for those in rural communities, arose for me and many of my colleagues. These include limited opportunities for supervision, treatment planning, care coordination, and the creation of resources in support of clients’ treatment goals. I’m also greatly concerned about the incredibly short timeline in which providers will be asked to make these significant changes should what is currently being proposed become a definitive set of standards as of 12/1/2021, especially during the midst of a global pandemic. As Covid-19 cases continue to remain at significant levels, especially in rural populations with a small percentage of people who are vaccinated, it will be difficult to navigate these changes and require home-based supervisors to increase time working in clients’ homes, which increases the risk of spreading the virus to clients, families, and staff.
I appreciate your serious consideration of these comments and hope that they provide an understanding of the significant impact these changes will likely have on the well-being of clients, the livelihood of technicians, and the quality of in-home ABA services.