After reviewing the changes in the new manual, several concerns arise.  First, BCBAs will no longer be able to bill for office supervisions with unlicensed staff.  With the requirements of a minimum of only a high school diploma required for behavior technicians, many of these staff need additional training/support outside of direct sessions.  Providing office supervisions provides supervisors the opportunity to give corrective feedback as well as role-playing various strategies without having to do it during direct ABA sessions when the client's parents are present.  

Another concern is for supervisors to no longer be able to bill for treatment planning.  Treatment planning is an essential part of effective services.  It does not seem realistic for a supervisor to review/update client's treatment plan during a live supervision with the client and client's parents present.  These changes will ultimately hinder the ability of the supervisor to provide adequate time and attention to these client's clinical assessments and treatment plans.  

As for the BCaBAs no longer being able to supervise cases under a BCBA, these changes do not make any sense.  BCaBA's are supervised by a BCBA for a reason.  They have the additional knowledge and field experience making them qualified to assist in training Behavior Technicians/Registered Behavior Technicians.