To whom it may concern,

When reading on the recent changes, and the current objectives, one is often presented with Project Bravo.  A project that is currently purporting to do the following:

Project BRAVO (Behavioral Health Redesign for Access, Value and Outcomes) consists of the implementation of fully integrated behavioral health services that provide a full continuum of care to Medicaid members. This comprehensive system will focus on access to services that are: high quality, evidence-based, trauma informed and cost effective.

I would like to draw your attention that within this objective, the focus is on access to services that are: high quality, evidence-based, trauma informed and cost effective.  Yet the service changes articulated in Appendix D, primarily as it relates Applied Behavioral Analysis effectively seem to limit this access to consumers.  I say this because when dictating services, the following billing designations are limited to LBA/LMHPs: 97151, 97155, 97156, 97157, 97158.  While it is concerning that LMHPs will also be able to utilize this code to deliver ABA services, as modalities and ethical code differs – you are leaving out a whole other designation (LABA) that is licensed to do much of the same within their scope of practice (as dictated by the BACB) under the purview of an LBA.  Not enabling these codes to also be able to be billed by LABA will essentially limit the reach of ABA services in general, as this entire process will have to be handled by the BCBA.  It is well established that there are not enough LBA’s to meet the demand of the consumer, as waitlists within the number of companies established in the Commonwealth of Virginia is staggering.  And it is here that BCaBA’s serve to bridge this gap and allow increased access to care for the consumer. 

So, we are left with the following question – is your aim to limit access to care, and further promote clinic-based settings vs. in home services and greater access by allowing BCaBA’s under the purview of a BCBA to carry out the duties to which they are licensed to do?  How is it that you are purporting to increase the quality of services yet framing it to introduce more barriers than solutions. 

Further, the fact that treatment planning for these services has essentially been phased out is also of great concern.  I say these because within the field of Applied Behavioral Analysis, programs are individualized to the consumer.  It is not a one shoe fits all solution, and due to this a lot of renditions, creations, and tailoring of materials utilized within programs are key to ensuring successful treatment. 

If your concern is stemming from fraud or rather, “double billing” instances - than I implore you that it is more important to further scrutinize and specify what would qualify for this type of service and what would not.  As in our field, you should operationally define it.  Include examples, and non-examples, and ensure that if two people were to evaluate the same thing that they would be able to yield similar decisions regarding it. 

Moving forward with the changes that you have put forth thus far, I assure you, would do more harm than good for our consumers.  I can only hope that you will take these concerns to heart, and truly consider the future of the consumers you claiming to support. 

Sincerely –

Robert