I am writing to show support for the addition of billable codes for care coordination, treatment planning/modification, and consultative supervision of staff in the ABA therapy manual. We encourage DMAS to look to states such as Maryland, which added billing provisions for external supervision and treatment planning each month alongside implementation of other common ABA CPT codes:
https://health.maryland.gov/
Care coordination is listed as a required activity in the new manual draft (pg. 35) and is an essential ABA service component to ensure consistency and generalization of skills across individuals/environments. Without a billable code, care coordination cannot be expected to occur as regularly as is necessary, especially for those with multiple other service providers or those in rural locations.
Likewise, as part of the required 30-calendar ISP review documentation and to ensure prompt, safe and effective ABA treatment - treatment planning/modification is also essential. However, without a billable code, suitable time each month will likely not be taken for proper analysis of the data and individualized program modifications based on that data, and program quality will likely suffer.
Finally, clinical/consult supervision of unlicensed staff is listed as a required weekly activity (pg. 36), however there are no codes designated for this apart from program modification while the individual is present and actively receiving therapy. Please consider adding codes for these essential services to the new ABA therapy manual to help ensure widespread access to quality ABA services.