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.