BCaBAs - the restrictions placed on the codes that BCaBAs can bill for will reduce the amount of services families needing help will be able to find, and does not follow what the Virginia Board of Medicine has licensed them to do. It does not account for their education, supervision, training and Behavior Analyst Board Certification.

Supervision- the requirement to supervise unlicensed staff on a weekly basis puts home and community services at risk, especially if only BCBAs can bill for this activity.

Care Coordination - written as "referrals to medical services." While we welcome collaboration with other disciplines it is not in our scope to make referrals. What is being asked for here is not clear.

Family Involvement - "Direct family involvement in the treatment program is required at a minimum of weekly." This frequency will also be a barrier to families without more guidelines on what the weekly involvement needs to be.

Indirect Activities - Ongoing assessment, data and program review, program development, treatment planning are not accounted for under these codes.

School - service limitation "ABA may only be provided in the school setting when the purpose is for observation and collaboration related to behavior and skill acquisition (not direct therapy)" does not clearly delineate what short term services we can offer to help prevent placement in a more restrictive educational environment.

Thank you