Thank you for the opportunity to comment on the upcoming Medicaid program changes for Mental Health Providers. Overall we are in agreement with the need to align the codes for Applied Behavioral Analysis with those that commercial payers use, however we believe that there are a few aspects of these changes that should be further clarified or reconsidered.

Please consider adding supervision of technicians, care coordination, and ISP development as billable activities. They are all required in the ISP and are fundamental aspects of providing quality ABA services. The current code set does not allow for these activities to be billable. While the rates have not yet been released, if they are designed to be financially cross walks of the previous codes, they will not be sufficient to cover the time involved to be considered  bundled services. 

Please add specific language for how time should be billed, ei a "rounding rule". In previous years Virginia Medicaid did not allow for any rounding, while most commercial payers use the CMS eight minute rule. For consistency, we support that DMAS adopt the CMS standard as well.

Please consider an adjustment to the requirement of weekly supervision of behavior technicians. This wording leaves little to no room for vacations or illnesses of either the technician nor the supervising LBA.  In this pandemic, support for flexible scheduling and time off is especially important for health and safety. Further clarification on whether this weekly requirement is per technician or per client would also be beneficial. 

We appreciate what a massive undertaking redesigning Virginia's Mental Health Services are, and hope to continue to partner with DMAS to provide help and support to our community's most vulnerable populations.