My name is Byron Wine and I am VP of Operations at the Faison Center in Richmond. The Faison Center consists of a school, adult day program, residential program, and behavioral health clinic that serves approximately 250 individuals per day. I would recommend a few changes to the way EPSDT covers Applied Behavior Analysis (ABA).

ABA and Behavioral Therapy are not interchangeable terms and ABA should be guided by the DHP regulations governing behavior analysts. Behavior therapy is a nebulous term used by several different licensed and unlicensed professionals. To a lay audience though these terms sound alike and can lead to confusion.

ABA often takes place where the client is having difficulties. As such, ABA should not be limited by location, but the services should be provided in the location that is determined most appropriate by the behavior analyst. 

ABA may be delivered individually or to groups of clients. The behavior analysts should be able to decide, from a comprehensive assessment of the presenting problem, if one-to-one or group therapy is most appropriate.

Thank you, Byron Wine