Thank you for your dedication to revising the regulations. I am a licensed behavior analyst at The Faison Center where we provide services to individuals across the lifespan. I would like to comment on the EPSDT changes that concern how the EPSDT is covering Applied Behavior Analysis services.

First, ABA and Behavioral Therapy are two separate treatments. ABA is guided by the Virginia Department of Health Professions regulations governing behavior analysts. Behavioral Therapy and ABA are distinct and should not be lumped together. Second, the provision of ABA should not be limited by location. Services should be person-centered and therefore occur in the setting most appropriate to the needs of the individual. These locations may include a clinic, center, community, home, social group or any other place where the behavior of interest may occur. Last, ABA is provided in 1:1 and group settings. As above, a person-centered approach requires that the services be provided according to the needs of the individual. Therefore, if a group setting may be the most appropriate, then it should be permitted. 

Thank you again for your efforts in revising these regulations and for your attention to this comment.