We respectfully request that DMAS revise the draft manual section governing Autism Spectrum Disorder (ASD) diagnostic documentation for ABA services. Our primary concern is that the proposed requirements would force ABA providers to retroactively evaluate and potentially question valid, established diagnoses based on assessment instruments, formatting, or telehealth delivery. Once a qualified LMHP acting within their scope of practice establishes a diagnosis, that diagnosis should be accepted for accessing ABA services.

Key Concerns:

• Retrospective Evaluation of Diagnoses: Requiring ABA providers to audit the original clinician’s diagnostic methodology, formatting, or tools creates an improper administrative burden, strays outside the scope of ABA treatment planning, and departs from how established diagnoses are treated throughout medicine.

• Invalidation of Existing & Telehealth Diagnoses: Diagnostic practices vary across settings, timeframes, and geographic locations. Individuals diagnosed in the past or out-of-state should not be penalized. Crucially, Virginia Medicaid currently reimburses diagnostic evaluations conducted via telehealth. Disqualifying diagnoses obtained through a Medicaid-covered service delivery method is contradictory and leaves families without a clear path forward.

• Duplicative Costs and Barriers to Care: Autism diagnostic slots in Virginia are already extremely limited, with long waitlists at participating hospital systems. Forcing individuals to 

• Undergoing Repeat Evaluations: This creates unnecessary, duplicative costs for the Medicaid program, places administrative strain on MCOs and providers, and causes harmful delays in access to care.

If DMAS seeks to enforce specific diagnostic standards, those rules should apply prospectively to evaluators at the time of assessment, not retroactively to members seeking treatment.

We recommend that DMAS revise this section to require ABA providers to document the existence of a qualifying ASD diagnosis and the credentials of the professional establishing or attesting to that diagnosis, rather than independently verifying the original diagnostic methodology.

Proposed Language:

a. A diagnostic evaluation confirming the diagnosis of Autism Spectrum Disorder (ASD) by an LMHP acting within their scope of practice. ABA providers shall document the name and credential of the evaluator; or the name and credential of the primary care provider attesting to the Autism Spectrum Disorder diagnosis.

b. For youth 36 months of age or younger, documentation of a provisional diagnosis of Autism Spectrum Disorder may be utilized for the approval of ABA services. A provisional diagnosis may be provided by an LMHP acting within their scope of practice. ABA providers shall document the name and credential of the LMHP providing the provisional diagnosis.