It appears that the Dept is attempting to define specific services within the universe of what is being provided and narrow them into framework toward what end? ABA is defined under regs of the Board of medicine and the BACB organization.  It should be left as such and not conflated into a mix including LMHPs/LMHP-Rs who have no scope of experience providing specifically classic ABA therapy. That is singularly the domain of LBAs and those under. If the Dept is seeking to better define Behavioral Therapy Services and support then they should concentrate on that and remove out ABA tx as a singular separate service as it is.

MST and FFT are long-standing treatment modalities that already exist in terms of those coordinating needed care for children and their guardian families and FFT with focused intervention on the relationships of people in a home as it impacts children. 

Shortline: this document is confusing/diffuse and is conflating quite a bit of regs/coding/tx approaches without a clear purpose objective by mixing language, staff qualifications etc