Expand the Supervision Regulations

To include both LMHP/LMHP-Es (with ABA experience/expertise) and LBA/BCBAs. Our agency has benefitted greatly from contracting an LBA to train our staff and oversee program development in addition to our licensed supervisor. Yet this LBA is not permitted to supervise in our EPSDT program because we are licensed under the Intensive In-Home license despite her eight years of experience working directly with this population. This setup is not congruent with “knowledge to practice.” By requiring additional training for all supervisors in the program, and credentialing behavior analysts to provide supervision and assessments, we believe that it would raise the standard of supervision provided to clinicians working in the program and enhance the quality of services provided to families.

Increase the Standard of Training

Behavioral therapy can best be provided by counselors with specific training and demonstrated competency regarding the practice of Applied Behavior Analysis. The ABA Outpatient track more consistently prepares staff to meet the needs of the population serviced through behavioral therapy by requiring 40 hours of specialized training. This same standard of training should be expected of staff working in programs provided under Intensive In-Home track as well. The same clients are being serviced under these two programs, but staff qualifications vary drastically. It is essential to the children and families that we work with to bring regulations more in accordance with one another so that the same quality of service is being provided by all agencies.

Clarification of Covered Services

As the regulations read now, some things appear to be mentioned twice under “Covered Services” (for instance, clinical supervision). We feel that it leaves room for interpretation by the provider in some instances. As a provider, we would like to be sure that we are billing responsibly and feel that can be achieved more effectively with further clarification in this section.