I appreciate DMAS’s efforts to establish a pathway for young children to access ABA services while awaiting a comprehensive diagnostic evaluation. However, I am concerned about how the proposed diagnostic requirements and timelines will affect young children and families who are unable to obtain a comprehensive autism evaluation within the required timeframe. In my clinical work with children and families in Virginia, I frequently encounter young children who demonstrate significant developmental, communication, behavioral, and adaptive needs consistent with autism spectrum disorder but have not yet been able to obtain a comprehensive diagnostic evaluation. This is often not due to a lack of caregiver effort. Access to qualified diagnostic providers is limited, waitlists can be lengthy, and these barriers can be even greater for families living in rural or underserved areas.

A child’s access to medically necessary early intervention should not depend on whether a qualified diagnostic provider happens to be available within a specific timeframe. I  encourage DMAS to maintain the provisional diagnosis pathway while providing greater flexibility when a family can demonstrate that they are actively pursuing a comprehensive diagnostic evaluation. I also encourage DMAS to consider whether the proposed pathway should be available to children beyond the youngest age groups when documented barriers to diagnostic evaluation exist. Geographic location and provider shortages can affect children of any age, particularly those in rural communities. The intent should be to ensure that comprehensive diagnostic evaluations are ultimately completed without creating a situation in which children lose access to medically necessary treatment because the diagnostic system does not have sufficient capacity to evaluate them in time.