I am writing as the mother of a three-year-old son diagnosed with Level 3 Autism Spectrum Disorder who is nonverbal and requires substantial support in his daily life. I am deeply concerned about the proposed changes to Virginia’s Applied Behavior Analysis (ABA) services, particularly the 20-hour weekly baseline, mandatory weekly caregiver participation requirements, and the proposed 31-day break-in-care discharge policy.

I strongly urge DMAS to reconsider these proposals and fully evaluate the potentially devastating consequences for children with significant developmental disabilities and the families responsible for their care.

1. Service Intensity: Why Individualized ABA Therapy Hours Are Essential

My son has Level 3 autism, the most significant support classification within the autism spectrum. His challenges are not minor developmental delays that can simply be addressed through occasional intervention. His disability affects his ability to communicate, develop independence, navigate his environment, and acquire essential daily living skills.

For children like my son, ABA therapy is not an extracurricular activity, a convenience, or a luxury. When medically necessary and appropriately individualized, it is a critical intervention that supports communication, functional development, safety, and quality of life.

The proposed 20-hour weekly baseline is particularly concerning because it risks placing an administrative threshold ahead of individualized clinical judgment.

A child’s medical necessity should determine the intensity of treatment, not a predetermined number of hours established for administrative purposes.

Although the proposal reportedly allows exceptions through EPSDT review, requiring families and providers to navigate additional approval processes may create unnecessary delays and interruptions in care.

Children with significant disabilities should not have to overcome additional administrative barriers to receive services their qualified treatment professionals have already determined are medically necessary.

I strongly urge DMAS to preserve individualized treatment planning and ensure that children with substantial support needs are not disadvantaged by arbitrary service thresholds.

2. Potential Impacts: Caregiver Requirements and the 31-Day Discharge Policy

I recognize the importance of caregiver participation in a child’s therapeutic progress. As a mother, I understand that consistency between the home and therapy environment can be beneficial.

However, there is a significant difference between encouraging meaningful parental involvement and imposing inflexible requirements that could jeopardize a child’s access to treatment.

Parents of children with significant disabilities already carry extraordinary responsibilities. We manage medical appointments, educational planning, therapy schedules, behavioral challenges, communication barriers, employment obligations, and the needs of other family members.

For families raising multiple children, maintaining employment, or navigating medical emergencies, rigid weekly participation requirements can become punitive rather than supportive.

A parent’s inability to attend a particular weekly session should never be interpreted as a lack of commitment to their child.

Caregiver participation should be collaborative, flexible, and responsive to each family’s circumstances. Parents should be supported in participating meaningfully, not placed in situations where unavoidable conflicts threaten their child’s treatment.

I am even more concerned about the proposed 31-day break-in-care discharge policy.

The possibility that a child could be automatically discharged after a prolonged interruption in services, even when caused by illness, hospitalization, or a family emergency, is deeply troubling.

Children with profound developmental needs do not suddenly stop needing support because their family experiences an unexpected crisis.

Imagine a child who has spent months building trust with a therapist, learning to communicate basic needs, and developing essential daily living skills. A medical emergency interrupts treatment, and that child is subsequently required to restart the assessment and authorization process.

This is not continuity of care. It creates the possibility of unnecessary treatment gaps, disrupted therapeutic relationships, and regression in previously acquired skills.

Children should never be penalized for circumstances beyond their control, and families should never be forced to choose between managing a crisis and preserving their child’s access to medically necessary care.

I urge DMAS to eliminate automatic discharge provisions and instead establish reasonable, individualized procedures for maintaining or resuming services after unavoidable interruptions.

3. Progress and Results: The Importance of Early Intervention

As the mother of a nonverbal child with Level 3 autism, I understand how meaningful even the smallest developmental milestone can be.

For some families, progress may mean a child learning to request water, communicate discomfort, follow a safety instruction, tolerate a transition, or participate in a daily routine with greater independence.

These accomplishments may appear small to someone unfamiliar with severe developmental disabilities. For our children, however, they can represent extraordinary progress.

Early childhood is a critical period for developmental learning. Children with substantial support needs deserve timely access to appropriate interventions that help them develop functional communication, adaptive skills, and greater independence.

When medically necessary treatment is delayed, reduced, or interrupted, the consequences extend far beyond missed appointments. Families may experience increased caregiving demands, difficulty maintaining employment, and greater concern about their child’s long-term development and safety.

I refuse to accept a system in which children with the greatest needs face additional obstacles simply because their treatment requires more resources.

My son deserves the same opportunity to develop, learn, communicate, and experience a meaningful quality of life as any other child in Virginia. His disability should not diminish that opportunity.