As a Virginia BCBA working directly with children and families who rely on ABA services, I am asking DMAS to protect individualized clinical decision-making in the proposed ABA Provider Manual changes.

A child's treatment needs cannot be appropriately determined by a predetermined number of hours. Two children with the same diagnosis can have very different clinical presentations, barriers, safety concerns, skill deficits, and treatment needs. Treatment recommendations should therefore remain based on individualized assessment, objective clinical data, medical necessity, and professional clinical judgment.

I am deeply concerned about the proposed 20-hour threshold because of how it may ultimately be applied by MCOs. A number intended as a review threshold can easily become a practical ceiling for treatment, placing clinicians in the position of defending why a child requires care beyond an administratively established number rather than focusing on what the clinical evidence demonstrates that child needs.

I respectfully request that DMAS remove predetermined ABA hour caps and utilization thresholds and maintain a system in which treatment intensity is determined through individualized medical-necessity review.

I also urge DMAS to preserve telehealth diagnostic evaluations when clinically appropriate. Access to qualified diagnostic providers is already challenging for many Virginia families, and policy changes should expand appropriate access to care rather than unintentionally create additional barriers.

Virginia's children deserve a system that provides appropriate oversight while preserving individualized, medically necessary treatment.