I am writing as an individual concerned with billing limitations placed on Board Certified Assistant
Behavior Analysts/Licensed Assistant Behavior Analysts (BCaBA/LaBA) in the draft iteration of the
DMAS ABA therapy manual. Please enable BCaBA/LaBA’s to use the billable codes that are in line with
their training, possibly at lower rates or with different modifiers than BCBA’s. According to Virginia
Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBA’s are
qualified to provide supervision (CPT code 97155), parent training (CPT code 97156) and conduct certain
assessments/analyze data (CPT code 97151), among others duties, under the supervision of a Licensed
Behavior Analyst.
BCaBA’s receive 225 hours of specific ABA coursework following (or as part of) their college and
require 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework
and fieldwork hours are not geared towards just providing direct services, they cover: proper
supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis,
assessment, and data analysis. Please see the latest task list covering the extent of BCaBA/LaBA training
here: https://www.bacb.com/wp-content/uploads/2020/05/170113-BCBA-BCaBA-task-list-5th-ed-.pdf

Paragon Autism Services, a provider of ABA services in the Fredericksburg and Woodbridge areas,
employs BCaBA/LaBA’s for all but one of their Clinical Supervisor positions. Over 60 of their clients
could be negatively impacted as a result of this change, with hundreds of other clients potentially
impacted at other employers of BCaBA/LaBA’s throughout the state. Removing access to necessary ABA
therapy services for children with autism and developmental delays is a significant risk with this change.

For additional supporting reference, please see the ABAI’s code breakdown in the link below, where it is
notable that BCaBA’s/LaBA’s are able to bill for relevant ABA codes according to their level of
training/expertise:
https://www.abainternational.org/media/152236/codeconversiontable.pdf

It is also notable that BCaBA/LaBA’s are still currently allowed to provide ABA through Virginia DMAS
funding under the Therapeutic Consultation service, which is similar in scope/practice (info here):
https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/