For any client who qualifies for ABA, it is always a goal to have a client ultimately have access to the least restrictive environment. With behaviors that can change based on their environment, school is a factor in the child's success across different settings. In my experience, several families report their children having behaviors within school that are not present within the home from counties in which their is no ABA program provided by the school system and are interested in ABA services being provided in the school. The draft states under services that will not be covered by medicaid as "Services provided by a local education agency. ABA may only be provided in the school setting when the purpose is for observation and collaboration related to behavior and skill acquisition (not direct therapy) and services have been authorized by the school, parent and provider and included in the ISP." I request that further definitions of direct therapy vs. observation and collaboration specifically within schools be added. Teacher training would be essential in helping the child succeed across environments and people, and training is most successful when modeling interventions with clients is included. However, I am concerned that modeling these interventions could be interpreted as "direct services". Speaking with the teachers about the treatment plan and observing the child without working directly with the child may not be effective in supporting the child's school team and ensuring that implementation is accurate with the teacher. It would be most effective if interventions were able to be observed by the teacher as the client receives ABA therapy from the provider within the school setting.