Hello,

Thank you for allowing the opportunity for comments so that community providers may help improve the quality and access of services for individuals in our commonwealth. To better assist individuals and families in building skills to support behavior and skill deficits in at-risk eligible populations, I would like to highlight the following:

While ABA therapy is a behavioral therapy, all behavioral therapy is not ABA. Individuals and organizations searching for appropriate services may confuse these, and since the standard of practice differs between ABA and behavior therapies, the distinction between the two fields is necessary to ensure the correct application of services.

ABA includes generalization in treatment, meaning that when done correctly, it is a "real life" intervention. This occurs across settings, and should not be limited to just the home setting. Social skills and behavioral strategies taught in the home should also be able to be practiced out in the community with others, in the natural environment. Sometimes a controlled setting such as a center is most helpful, to establish skills first. Limiting the locations available for services limits progress for the individual.

ABA is always individualized, but with clinical oversight by an LBA, there are many times when group treatment could be beneficial as well. Individuals that require peers to practice skills are not able to routinely get access to each other with the current regulations in place as written.

"Sessions for family support" may be considered vague, and as EPSDT mandates parent training (a "support" for families), this sometimes occurs without the client present to allow the parent to practice strategies in the treatment plan before implementation by the family.

Many individuals eligible for EPSDT services may benefit from an interdisciplinary approach, such as those who have a developmental diagnosis and co-morbid PTSD or other trauma, or a co-morbid mental illness. This population currently has to choose whether he/she gets treatment for skill deficits, or the co-morbid disorder, which often goes back and forth, making it unlikely that the individual will ever demonstrate enough progress to be eligible for discharge. Making both services available could help shorten the length of treatment for these individuals significantly.

Many individuals who would benefit from ABA services are not eligible due to age. Please consider extending coverage past age 22 years old to assist those who have fewer service options available to him/her.

Thank you for taking time to consider my comments. 

Sincerely, 

Hannah Robicheau, M. Ed., BCBA VA-LBA