As a Board Certified Behavior Analyst (BCBA) and Licensed Behavior Analyst (LBA) practicing in Virginia, I am writing to express concern regarding the proposed changes to Medicaid-funded Applied Behavior Analysis (ABA) services, particularly the proposed 20-hour utilization threshold and in-person diagnostic requirements.

ABA treatment should be individualized based on each recipient’s assessed needs, functional impairments, treatment response, progress data, and medical necessity. A standardized utilization threshold should not restrict access to clinically appropriate services for individuals who require more intensive treatment. Treatment hours should be determined through comprehensive assessment, ongoing data analysis, and the clinical judgment of qualified professionals in collaboration with families and other members of the treatment team.

I am also concerned that rigid in-person diagnostic requirements may create unnecessary barriers for families who face transportation challenges, geographic limitations, scheduling difficulties, financial constraints, or limited access to qualified diagnostic providers. These requirements could delay assessments and treatment initiation, particularly for families already navigating significant barriers to care.

I respectfully encourage DMAS to ensure that the final policy preserves individualized treatment planning, allows clinically justified exceptions to utilization thresholds, and considers appropriate flexibility in diagnostic requirements when clinically and legally permissible. Any policy changes should be evaluated for their potential effects on timely access to care, continuity of services, patient outcomes, and the ability of families to obtain medically necessary treatment.

As clinicians, our responsibility is to provide ethical, evidence-based care that meets the needs of each individual. Medicaid policy should support that goal rather than impose restrictions that may interfere with medically necessary treatment. Thank you for considering the perspectives of Virginia clinicians, the individuals we serve, and their families.

Justin Scroggins, BCBA, LBA