After reviewing the proposed regulations, I have several concerns that I feel need to be addressed in order to meet the needs of all individuals in need. There are still rural areas of Virginia that are greatly lacking services, evidenced by long waiting lists and no additional providers.
One of the areas that I feel that will only hurt the field of ABA is the inability for BCaBAs to provide supervision. These individuals have the knowledge, skills and training in order to complete all tasks under the close supervision of a BCBA; while lessening the potential burnout on said BCBA. This immediate change in the way services have been completed will only further hinder children in our state from receiving this much needed service.
It is worth mentioning that the removal of the ability to complete data analysis, treatment planning and supervision of technicians combined with the removal of BCaBAs ability to do anything, would completely disrupt many home-based programs. I remember not too long ago when it was recommended to avoid clinic/center-based services in favor of the home-based; and now, it seems that the opposite is occurring. There are rural areas that are hours away from an ABA center-based program and the removal of the option of home based will be catastrophic to their care. Other states have adapted codes to ensure provisions are made to allow for these services to be covered, and Virginia should consider the same.
Service collaboration and coordination is a requirement; however, is not covered under any CPT code. A benefit of ABA services is the generalization to other settings and caregivers; thus reducing the more intensive ABA service. Removing this ability will hinder the individual’s access to high quality services—and often can create cookie cutter treatment.
In order to remain in line with the standards of BACB and their requirements regarding supervision, I would ask that it be reviewed for 5% monthly supervision for RBTs, as is written into their supervision guidelines. There are often times that conversations need to occur with a staff in regards to behaviors that the child does not need to hear, which is not allowed under these proposed regulations.
As far as proposed changes to reimbursement rates, it is currently a market where staff are hard to find and will often leave companies for even a small increase in compensation. I would request that any changes being made to technician rates be made after some period of recovery from the current employment crisis in the United States.
Over the past few years, our children have been required to be flexible in their schooling and social interactions due to COVID-19 restrictions and virtual learning. After reviewing these proposed changes, I feel that it would further disengage our most severely impacted clients and not provide them the highest quality of individualized and ethical services available. While in the moment this may seem like the best decision for financial reasons, the overall effect of increased treatment spanning years longer than necessary will deplete any immediate benefit.