The most concerning issue regarding these proposed billing changes is that Medicaid has put policy ahead of client and family needs once again. I understand the need to standardize and adhere to billing codes that match CMS billing guidelines. However, I don't know how Medicaid and other state regulators think the solution should be reducing the overall amount of covered services.

Unfortunately, by completely altering the regulations and reducing the reimbursement for this program, you end up with poorly trained staff members. Which in turn, creates another problem where providers are unable to meet the needs of the client/family because they won't be able to bill for things like creating communication tools and other resources and interventions.

If you ask families who receive this service, most would tell you that it's life-altering (in the best way). Families who once struggled with long lists of alternative needs such as assistance with communication, safety concerns, reducing maladaptive behaviors, etc., were able to be helped and successfully trained in ABA principles. The success of clients and families and ASD/Developmental Delays is directly attributed to the amount of time, effort, training, and general care that our community-based providers have invested in treatment planning, creating resources, tools, and alternative modalities to treatment. By removing certain covered services, you are removing the ability for providers to help families. Essentially, you're going to pay for what you get.

As a potential solution, Medicaid should consider adding in an alternative H-code to allow some of the items they have conveniently left off of the "allowable" list to ensure that Medicaid providers can provide the same excellent level of care they have been providing all of these years. There are some very reputable ABA providers spanning across the state, and they are conducting sound, ethical, and life-changing ABA to children and families affected by Autism and other developmental delays. Creating an alternative billing code is not only an investment in the providers; you're investing in the client and families' lives as well.

Lastly, nearly all states with a Medicaid ABA program (comparable to Virginia) include regulations that services should be conducted in the client's home for generalization across all settings, not just in a clinic. Therefore, Medicaid should allow the provider (and the MCO) to determine the clinically appropriate treatment setting.