As a dedicated advocate for expanding access to vital services, I strongly support removing the requirement that initial assessments for individuals with autism requiring ABA (Applied Behavior Analysis) therapy must be completed in person, as outlined in the Mental Health Services Manual, Appendix D. This revision ensures timely, equitable access to care, aligns with evidence-based practices, and reflects evolving standards in behavioral health service delivery. Below are several key reasons why this update is essential:
• Improved Accessibility to ABA Services: Individuals with autism, especially those in rural or underserved areas, often face significant challenges in accessing in-person services. Removing the in-person initial assessment requirement bridges this gap, enabling timely access to critical therapy services without forcing families to endure delays or logistical hardships.
• Evidence-Based Support from CASP and BACB: The Council of Autism Service Providers (CASP) and the Behavior Analyst Certification Board (BACB), both respected authorities in the ABA field, provide strong support for the use of telehealth. CASP’s Practice Parameters for Telehealth Implementation of Applied Behavior Analysis and BACB’s ethical guidelines emphasize that telehealth-based assessments can deliver the same high level of effectiveness as in-person services when conducted appropriately by credentialed providers.
• Consistency with CMS Guidance on Telehealth: The Centers for Medicare & Medicaid Services (CMS) has long acknowledged the importance of telehealth in reducing service delivery barriers. CMS extended approval for ABA-related CPT codes (97151-97158, 0362T, 0373T) for telehealth delivery into 2025, further solidifying telehealth’s role in increasing accessibility without compromising care quality.
• Widespread Industry Consensus: Telehealth has gained widespread support across healthcare bodies such as the Autism Society and the American Psychological Association (APA). These organizations recognize the importance of modernizing healthcare delivery methods to better meet the needs of individuals requiring behavioral therapies, supporting policies that remove outdated limitations like in-person-only requirements.
• Faster Initiation of Treatment: In-person requirements often lead to delays, which can impede progress for individuals requiring ABA therapy. Allowing for remote initial assessments ensures a prompt start to services, aligning with treatment goals and optimizing therapeutic outcomes.
• Resource Optimization for Providers and Clients: Requiring in-person initial assessments not only imposes logistical and financial burdens on clients but also monopolizes limited resources for providers. Removing this requirement allows providers to extend their reach, especially in areas with limited behavioral health professionals.
• Maintaining High Standards of Care: Telehealth assessments comply with rigorous professional and ethical standards, including privacy and security, and ensure quality in alignment with CASP, BACB, and CMS guidelines. The technology-enabled modality ensures that individuals with autism receive comprehensive evaluations tailored to their needs.
• Alignment with State and Nationwide Health Priorities: The revision of Appendix D of the Mental Health Services Manual reflects the evolving standards of care and helps further the state’s broader goals of improving healthcare access, leveraging technology, and driving better patient outcomes.
In conclusion, removing the in-person initial assessment requirement from the Mental Health Services Manual, Appendix D, is an essential step to modernize ABA services, incorporate consensus-driven standards, and enhance accessibility for individuals with autism. This change aligns with the authoritative guidance of CASP, BACB, CMS, and other leading organizations, ensuring evidence-based practices and equitable care delivery.