Our full comments will be emailed due to the character limit imposed by Town Hall.

The Virginia Association of Community-Based Providers (VACBP) submits these comments through its ABA Council. We recognize that the 20-hour limit and ASD requirement come from Item 291.WW.2 of the 2026 Appropriation Act; we ask DMAS to implement them clearly and protect continuity of care. A full letter has been sent to DMAS.

1. Eligibility (p. 24): Explain the clinical basis for ASD-only eligibility and what service DMAS recommends for youth with ADHD, ODD, conduct disorder, or Down syndrome/ID who benefit from ABA. State in the criteria that these youth may be approved via EPSDT.

2. Diagnosing professionals: Specify which license types may render ASD and provisional diagnoses, and distinguish administering a screening tool from making a diagnosis. Accept ASD diagnoses under all applicable F84 codes. Define "age 5 or under" as through the day before the 6th birthday.

3. Evaluations (pp. 28-29): Confirm prior evaluations using ADOS/CARS satisfy the requirement and current clients need not be re-evaluated. Evaluator waitlists are about one year; provide a grace period.

4. Provisional pathway (pp. 28-31): Name the ICD-10 code for provisional diagnoses. Define acceptable waitlist evidence (including family attestation or a DMAS form) since many families are waitlisted with no date. Define when the 12-month clock starts. No recoupment if a later evaluation does not confirm ASD; provide a transition period.

5. EPSDT and 20 hours (pp. 28, 31-32): EPSDT review should be automatic before any denial. Publish uniform elements, forms, and timeframes for all MCOs and FFS; continue services while review is pending. Accept schedules by session block, not unit by unit, and allow adjustments. Require reviewers with ABA expertise. List which codes count toward 20 hours, excluding assessment and family training. Use utilization data from all MCOs.

6. Assessment codes (p. 28): Direct MCOs that 97151, 97152, and 0362T need no prior authorization.

7. Implementation: Allow at least [90] days after the final manual is published. Apply new requirements to current youth only at their next continued stay. Provide training and FAQs before the effective date and coordinate MCOs for consistency.

8. Corrections: "Autism Diagnostic Review" should read "Autism Diagnostic Interview-Revised"; "evidenced based" should read "evidence-based"; use consistent age phrasing.