In Home Services: Due to the amount of time with travel and scheduling to provide quality in home care there is concern related to how the current draft is established for supervision to only be provided when the client is present. Per the draft there is concern regarding quality of care being at risk for supervision. For a LBA delegating in home services to an unlicensed behavior technician, within the current regulations it is allowed to provide supervision with and without the client, but there is no mention for codes for billing for when the client is not present within the new drafts. This will put an additional strain on LBAs wanting to target the population that needs after school and evening support targeting generalization and maintenance to the home setting  along with providing quality services to populations that cannot afford transportation.

 

Request for code be added for care coordination and case consultation: care coordination is needed to maintain a full cohesive treatment team to include other modes of therapy, medication management, etc. especially for in home services.