Thank you for the opportunity to comment on EPSDT changes that concern behavior therapy.  I am Julie Barndt, BCBA, LBA and provide behavior analytic services for children and adolescents with autism. My practice accepts all payor types including Medicaid.  There are three areas where I think changes should be made to the way EPSDT covers Applied Behavior Analysis (ABA):

1. ABA and Behavioral Therapy are not the same treatments and  properly separated. ABA should be solely guided by the DHP regulations governing behavior analysts.  Often behavioral therapy run by non-LBAs looks more like counseling or behavior modification and not the science of ABA.  It is confusing to lump the professions together, and the distinction is necessary.

2. ABA should not be limited by location, but the services should be provided in the location that is most appropriate to the needs of the individual.  This may be a clinic, the community, a social group, or the home, or other place that meets the needs of the individual.  ABA clinics should be required to obtain a license that is appropriate to their business, which is not available at this time. Due to significance of social deficits that are part of an autism diagnoses, it is essential to treat social deficits in the context of behavior analytic therapy which can only be done in situations in which social interactions with peers is likely. Often times parents are not able to provide social opportunities for their child in their home.

3. ABA does not necessarily need to be provided individually, but may be appropriate for some individuals in a group setting.  The service should be available in a group setting or one-on-one with an individual as is dictated by the individual’s needs and outlined in the ISP. It is important that children with all levels of need are able to access behavior analytic therapy that is helpful to them and this includes individuals who may only need assistance in social interactions and don’t necessarily require the intensity of a 1:1 intervention. 

Overall, necessary changes should be made so that an appropriate person-centered approach can be utilized as deemed necessary by the licensed clinical professional.

I appreciate the hard work that has gone into revising these regulations and thank you, again, for the opportunity to comment.