As a BCBA/LBA in Virginia who provides home-based services, the proposed changes in the Medicaid regulations gives me worry and concern about the feasibility and quality of home-based ABA services going forwards. Bigger picture, from the way that the drafted regulations are currently written, home-based services will be much more-costly to provide than clinic-based services, which will in turn lead to companies choosing to provide clinic-based services over home-based services and may lead LBAs to move away from providing home-based services, despite the continued need. This will have a significant and direct impact on clients and their families, for whom ABA services are considered medically necessary. Individuals without access to transportation (especially those who live in more rural or remote locations and those with a lower socioeconomic status) will have increased barriers to accessing services. Additionally, this will impact client’s ability to learn and practice socially significant behaviors in their own environment, and parent’s/caregiver’s ability to participate as readily in services and parent-training. While I support and understand a need for change in the current Medicaid regulations, I worry that the proposed changes will unintentionally hurt those who are most in-need and work against creating lasting behavior change through a decrease in quality and feasibility of home-based services.
Changes in what LBAs are able to bill for and language allowing clinic-based services will lead companies/LBAs to provide services in the clinic, as it will allow for more billable activity (more lucrative) with increased convenience. In turn, this will impact:
Thank you for your considerations of these comments towards the proposed regulation changes.