As an LBA supervising the provision of ABA services to rural Virginia families, I have concerns about the changes to billable activities in the draft Manual.  I believe the changes to the billing codes will have the unintended, but disastrous, effect of reducing the financial feasibility of providing in-home ABA.  My office primarily serves clients who are unable to access clinic or center-based services.  These clients are only a sampling of the Virginia families who are at-risk of the loss of ABA services that allow individuals to gain skills, and ultimately to remain in their homes.  I would like to specifically address the elimination of billing codes for: remote supervision of non-licensed individuals, and treatment planning

1. Supervision of non-licensed individuals is a required weekly activity.  If this is required to occur in the presence of the client, it would result in a significant decrease in time available to engage in clinically necessary work including treatment planning, data and assessment review, data compilation, and care coordination.  The inclusion of a billing code to allow for remote supervision ensures the home-based LBA has sufficient time to provide individualized, effective services for clients and families.
2. Treatment planning and data review are critical to ensuring effective, individualized services across settings.  For LBAs supervising in-home programs, the ability to treatment plan remotely allows for increased engagement with caregivers, non-licensed staff, and clients while in the home.  I am concerned about the practical changes to these home visits without a billing code for these activities.  I anticipate that LBAs would spend more of their time behind a computer making adjustments to programs and ISPs while in the presence of clients and families.

Thank you for the opportunity to comment on these changes and for listening to the thoughts and concerns of practitioners who will be impacted by them.