Please add clarification under Service Definition/Description for who is a Behavior Consultant. I suggest you list the titles, such as LBA/BCBA, PBSF, LCSW, LPC, etc.  Are BCaBA's behavior consultants, if so then please add them to the list. In the same section - please define physical therapy disciplines - is this only licensed physical therapist or does this include PTA, COTA, or who?

Please change pronouns to he/she/they.

Under Service Documentation Requirements (pg. 153) For behavioral consultation, the annual review must include graphed or tabled data that is trended across the first three quarters; Behavior consultation is only approved for 180 days = 6 months. I am not sure how we are to trend data for 9 months with an approval of 6 months. 

In the same section, A contemporaneously signed and data final disposition summary that is forward to the support coordinator within 30 days following the end of this service and that includes: Providers do not have access to WaMS to enter final disposition after the end date of service. This makes it impossible to forward the final disposition 30 days after services are termed. I suggest we follow the previous regulations and do 30 days prior or after.

All therapists should be listed under code 97139. 

Nursing consultation should be added as a service option.