“An initial assessment for ABA consistent with the components required in the Comprehensive Needs Assessment (see Chapter IV for requirements), documenting the individual's diagnosis/es and describing how service needs match the level of care criteria must be completed at the start of services.”

“Include a functional assessment using validated tools completed by the LBA or LMHP acting within the scope of practice.”

Board Certified Behavior Analysts (BCBAs) are specifically trained in administering assessments and gathering data needed to inform treatment.  The requirement to complete an initial assessment with the 15 components of the comprehensive needs assessment requires additional information that is not needed for effective treatment. In addition, some of the components that are required are not applicable to individuals with autism. BCBAs should be allowed to determine the assessment(s) and data they need in order to develop a treatment plan that is well thought out and of high quality. Please consider updating this to remove the requirement for the initial assessment to include these 15 components.  

In addition, not all clients will need a functional assessment if they do not have goals targeting behavior reduction.  Please consider updating this requirement to indicate that this requirement is only appropriate for clients with behavior reduction goals.