I would like to start by stating that after processing these changes, I cannot figure out how this could possibly have a positive impact on the clients it is meant to serve.  We work with some of the most vulnerable population, which, by the way has already fallen through the cracks in so many other systems.  If these new regulations and billing codes go into effect as planned, all it will do is further inhibit the progress that this population deserves to achieve.  

The following are my primary concerns with the proposed changes:

1. The restrictions on BCaBAs has absolutely no obvious justification.  BCaBAs are essential in providing BCBAs with the additional support in getting the clients' needs met (supervisions, assessments, treatment planning, parent training etc). The quality of services will surely decrease without the assistance from the BCaBAs.  In addition, they are far over-qualified to be restricted to conducting direct sessions.  If this were suggested in ANY other field, everyone would be equally confused and off-put by the suggestion.  (ie. would anyone suggest no longer allowing a physicians assistant to perform their well-trained duties, and restricting them to internship job duties?) 
2. Adding restrictions to billing (such as classifying treatment planning, case coordination, and office supervisions as non-billable activities) will again only hinder a population of people that deserves the best quality services.  
   1. Treatment planning, case coordination, and office supervisions are vital to the quality of the direct services provided.  They are all of equal importance.
   2. Without proper treatment planning, adequate live supervisions cannot take place.  
   3. Without office supervisions, interventions will have to be trained and maintained in vivo with a client and family will be present competing for attention.  
   4. Without case coordination, various services providers may be working on completely different and competing goals, further inhibiting the client's ability to make progress.  
   5. Furthermore, to even suggest that these things will continue to be required but not billable, is completely naive.  Companies across the board have billable hour requirements that are expected to be met.  So either people will not be able to support themselves for lack of billable hours, or people will be overworked and burnt out trying to achieve their billable hour requirements while continuing to complete activities that are required for quality services.