Thank you for making these important changes to the manual and for including behavior analysts in the process.  The Virginia Association for Behavior Analysis Public Policy Committee has the following comments regarding Appendix D:

• Care Coordination is specifically required by DMAS, but not by any other organization.  Therefore, when the rate study is conducted, it is unlikely that Care Coordination will be taken into account as an in-kind service.  Thus, we request that an additional code be assigned to Care Coordination to be paid separately.
• Licensed Assistant Behavior Analysts (LABAs) should be included in all places that LBAs are included and should have their own modifiers.  LABAs can perform all of the same activities as LBAs as long as they are within scope of competence.  The only difference between tasks performed by an LABA and an LBA is that there must be ongoing supervision.
• Replace the term behavior modification as it is typically associated with an absence of functional assessment and does not reflect our profession any longer.  The term appears on pages 34, 41, 42, and 44.  In all cases, the word “modification” can simply be removed leaving just the word “behavior.”

• Rates (both technician and LBA/LABA) should include provisions for supervision without the client present.  In addition, for code 97151, services should be covered for both face-to-face and non-face-to-face situations.
• On pages 36 and 44, there are requirements that a document needs to be signed when supervision happens.  These documents are not generally signed the day of, but rather within a week or when the notes are reviewed.  Request understanding of why the exact day is necessary.

• For group treatment, the service is limited to 3 for both families and individuals.  ABACodes.com FAQ notes that it should be between 2 and 8 individuals for group therapy.  For parent training, it does not specify, but the example lists 5.  Request increasing the maximum to 8.
• On page 37, the manual lists school setting under the services that shall not be covered.  We understand the limitation with reference to public schools but suggest that the word “public” is added as some private schools provide ABA.
• The Virginia Association for Behavior Analysis also supports the comments made by the Association for Professional Behavior Analysts (APBA) via Dr. Gina Green.

With respect to the Telehealth Services supplement, we request that patient’s home be added to the examples of originating site for clarification.  ABA services are often provided in the home and therefore would be the appropriate place to receive the services.