We, the Public Policy Committee of the Virginia Association for Behavior Analysis, have the following comments on the Draft Development Disabilities Waivers Chapters II, IV, and Appendix D.  We thank you for the opportunity and partnership.  Many of our members are providers of Therapeutic Consultation as Licensed Behavior Analysts and Licensed Assistant Behavior Analysts.

On page 37 of Appendix D, the unit of service is listed as 1 hour.  However, a 15 minute-unit would be more efficient and less open to waste.  Frequently, providers of therapeutic consultation provide services over or under the hour mark and then must adjust for billing purposes.  Often this results in the provider not being paid for services provided under 30 minutes or the provider being paid for services not provided but rounded up to the next hour.  15-minute units are common for many of the providers who deliver these services.

Currently, Therapeutic Consultation services are only provided to those with the Family and Individual Supports Waiver or Community Living Waiver.  These services would be very beneficial for individuals with the Building Independence Waiver as well, especially in helping them to remain on that waiver and not need more intensive care.

We thank you for the opportunity to comment and welcome your continued partnership.