I am a Board Certified Behavior Analyst and LBA in Virginia. I have been practicing for almost four years. I have practiced in the home, clinic, and day care settings. I have also provided services In-person and via telehealth. I am writing to express concerns for the proposed updates in Appendix D.

First I want to express concerns regarding the 20 hour limit for services (page 28). It is  my clinical belief that the number of therapeutic hours be individualized to the child, and not based on a limit imposed by an external body. Treatment plans prepared by myself and my fellow BCBAs are done so after careful consideration, evaluation, and with respect to CASP guidelines. These hours consider the client and family’s ability to participate, their risks, deficits, strengths, and their support systems. At this time, I have multiple children on my caseload that require 15-25 hours of only direct (97153) services and this does not include the hours spent treatment planning, parent training, and supervising the direct care staff. If a limit is to be imposed; it is requested that this not be inclusive of parent training and supervision hours as these take away from the amount of direct therapy a child receives.

Should a child need additional hours, it is understandable that further review would be required and warranted to ensure appropriate use (Page 31). It is requested that this review should be completed by medical professional who is abundantly familiar such as a fellow BCBA/LBA with the field of ABA and in a timely manner so as not to further delay service delivery. I appreciate that many insurance carriers allow for peer to peer discussions to further justify the need for additional hours and this should continue to be the standard. It is my experience that these peer to peer reviews can at times be scheduled multiple weeks later which is time spent that a child could be making progress to reach functional independence.

Through my company, we service many children in rural areas in which there is not an in-person provider for more than 40+ miles. I have recently serviced a child who lives more than 30 miles outside of the closest major city (Roanoke) which is still fairly rural. These services are often paid through Medicaid and families are  unable to accommodate for extended drive times. In-person assessments should continue to be the priority, but when not possible due to limitations of availability, distance, or other barriers a virtual assessment should be accepted.

Early intervention is proven to be most beneficial to children diagnosed with Autism. These comments are intended to consider the need for additional documentation requirements to ensure ethical service delivery while also prioritizing the needs of the individuals that we serve thus improving quality of life, functional independence, and reduction of community/caregiver burden.

Thank you for your time and consideration of these comments.

Sarah Richter M.S. BCBA, LBA