While I appreciate the need for the transition to CPT codes, there are several requirements in this manual that are unique to Virginia Medicaid and should be addressed:
Service collaboration is required, but not covered by any current CPT codes. This should be billable by a separate code so clients can continue to received high-quality collaborative services.
LBAs and LABAs should still be allowed to bill a small percentage of indirect services - especially for agencies such as ours that provides services in rural areas that are prohibitive for clinicians to reach daily, but treatment plans and protocols need to be updated frequently.
The requirement of clinical supervisor of unlicensed staff to occur weekly is a hold-over from the original transition from IIH to behavior therapy. This should be removed in favor of the RBT requirement of 5% supervision per month. If not, this should be better defined (is it supervision per client? per staff? how long? - in IIH the requirement is to meet QMHP/QMHP-T standards, which do not apply in ABA)
Lastly, please reconsider the exclusion of LABAs from billing supervisor codes. Waitlists in Virginia are long enough without removal of part of our supervising force (181 licensed LABAs in Va). The BACB describes the ability of LABAs to supervise unlicensed staff. ABA is designed to be a tier model with BCBAs, BCaBAs, and RBTs. With required supervision, it is well within the scope of their practice to complete assessments and protocol modification.
