BCaBA/LaBAs:
As a BCBA/LBA, I am concerned with the 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. According to Virginia Licensure Laws and BACB guidelines for the practice of Applied Behavior Analysis, BCaBA/LaBAs 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. Therefore, BCaBA/LaBAs should be able to use billable codes that are in line with their training, possibly at lower rates or with different modifiers than BCBAs.
BCaBAs receive 225 hours of specific ABA coursework and are required to obtain 1300 supervised fieldwork hours prior to taking their board certification exam. These coursework and fieldwork hours are not geared towards just providing direct services, in fact, there is a requirement to obtain specific fieldwork hours that focus on the following; proper supervision/training of staff, writing programming/behavior plans, ethical practice of behavior analysis, assessment, and data analysis. Please see the latest task list provided by the BACB 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/LaBAs 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/LaBAs throughout the state. Removing access to necessary ABA therapy services for qualifying individuals 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/LaBAs 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/LaBAs are still currently allowed to provide ABA through Virginia DMAS funding under the Therapeutic Consultation service, which is similar in scope/practice:
https://www.virginiaaba.org/become-a-therapeutic-consultation-provider/
Indirect Activities:
Frequent comprehensive data analysis, ongoing re-assessment, program and behavior plan development, and consultative supervision are essential components to ensure clients' progress with skill acquisition and behavior reduction. These activities are not represented under these codes.