After reviewing the proposed regulations, I have 2 great concerns regarding external supervision and treatment planning. As a BCBA/LBA, who provides in-home services I am worried the limitations which are being set on treatment planning will have a negative impact on the service I am currently able to provide. I spend a great deal of time working with clients, their families, and my clinicians. When I am face to face with them, I am actively engaged and hands on. I am worried with these new regulations this may shift dramatically, as I will need to work on their treatment plans with them present. I would hate to see the day I have to engage with these clients and families from behind a computer. Additionally, when working in the home, there are many variables which arise throughout sessions. Removing external supervision will create even more of a hardship when I attempt to train and prepare my supervisees in the presence of the client. In addition to this hardship, there is information which may need to be discussed in the absence of the client, so that the therapeutic relationship is not damaged.
I urge DMAS to look to states such as Maryland which have added billing provisions for external supervision and treatment planning each month alongside other common ABA CPT codes.