To the Department of Medical Assistance Services:

Genesis Autism Center is a clinic-based ABA provider in Hampton serving young children and their families, many of whom rely on Medicaid. We share DMAS’s commitment to quality and accountability. However, we are concerned that the proposed Appendix D, as written, will delay or deny medically necessary care to the children who need it most and can least afford to wait.

1. The diagnosis requirement narrows eligibility for children who currently qualify. Current Appendix D criteria allow ABA for youth with a qualifying DSM diagnosis and documented functional impairment. Requiring an ASD diagnosis removes a pathway for children with other conditions who benefit from ABA today. These children will now depend on case-by-case EPSDT review, which adds delay and uncertainty for families already in crisis.

2. Diagnostic wait times will become treatment wait times. Families across Virginia already wait 6-12 months for a comprehensive autism evaluation. Requiring an in-person evaluation with specific tools and evaluator credentials before authorization, and limiting provisional diagnoses to children 5 and under, means older children cannot begin treatment until an evaluation is complete. Early intervention matters most during the very months these children will spend waiting.

3. Medicaid families face the greatest barriers. Families with limited transportation, inflexible work hours, or no access to nearby evaluators will be hit hardest by in-person requirements and documentation that must be “obtained directly from the evaluating entity.” Commercially insured families do not face these hurdles. This widens an existing gap in access.

4. Administrative burden reduces clinical capacity. New schedule requirements, weekly summary notes, and expanded re-authorization packets shift BCBA time from children to paperwork. In a field with a well-documented workforce shortage, every hour spent on administration is an hour of care not delivered.

5. The 31-day lapse rule penalizes families for hardship. Requiring a full new assessment after a hospitalization, illness, or family emergency delays the return to care at the moment a child is most vulnerable.

6. The timeline leaves no room to protect continuity of care. An October 22 effective date, one day after comments close, gives providers no time to adjust and risks authorization disruptions for children currently in treatment.

We respectfully request that DMAS:

• Retain the current diagnostic pathway, or allow a provisional diagnosis for all ages while an evaluation is pending.
• Accept validated telehealth evaluations and family-provided waitlist documentation.
• Allow an assessment addendum, rather than a new assessment, after documented hardship lapses.
• Delay implementation at least 90 days and honor all active authorizations through their end dates.

Every month of delay is a month of lost progress for a child. We urge DMAS to adopt standards that strengthen accountability without closing the door on the families who depend on Medicaid most.

Respectfully,

Cameron S. Ashworth, M.A.
Co-founder, Genesis Autism Center and COO of Genesis Counseling Center              Hampton Roads, Virginia