These proposed changes will greatly inhibit ABA programs from implementing effective services. ABA services are medically necessary and therefore require frequent treatment planning and supervision to ensure adequate treatment. Making these activities non-billable will greatly restrict providers from doing so. Restricting BCaBAs from the supervision codes will also prevent programs from being able to continue to serve as many clients as they do now. Again, these services are medically necessary and this will lead to an already underserved population being further disadvantaged. It also completely devalues the qualifications of current BCaBAs. Furthermore, BCBAs, BCaBAs, RBTs, and BTs will not be able to support themselves if they can only bill for in person services and will be unable to continue working in this field. Everyone working in this field and those receiving ABA services will only be hurt by these changes. The only group that benefits will be the insurance company. Our client's deserve the best quality services possible and we deserve to be reimbursed for the services we provide.