Regarding the Exceptional Rate for ID Waiver Individuals, please accept the following public comment:

"Behavioral specialist" means a person who possesses any of the following credentials: (i) endorsement by the Partnership for People with Disabilities at Virginia Commonwealth University as a positive behavioral supports facilitator; (ii) board certification as a behavior analyst (BCBA) or board certification as an associate behavior analyst (BCABA); or (iii) licensure by the Commonwealth as either a psychologist, a licensed professional counselor (LPC), a licensed clinical social worker (LCSW), or a psychiatric clinical nurse specialist.

Number ii should read “licensure by the Commonwealth as either a behavior analyst (LBA) or assistant behavior analyst (LABA)”

In order to practice behavior analysis in Virginia, one must be licensed according to § 54.1-2957.16.  Also, the a in BCaBA is lowercase and stands for “assistant.”  When referring to a licensed person, the A is capitalized, but still refers to “assistant.”

Thank you for your consideration.

Regarding the Exceptional Rate for ID Waiver Individuals, "Behavioral specialist" means a person who possesses any of the following credentials: (i) endorsement by the Partnership for People with Disabilities at Virginia Commonwealth University as a positive behavioral supports facilitator; (ii) board certification as a behavior analyst (BCBA) or board certification as an associate behavior analyst (BCABA); or (iii) licensure by the Commonwealth as either a psychologist, a licensed professional counselor (LPC), a licensed clinical social worker (LCSW), or a psychiatric clinical nurse specialist.

Number ii should read "licensure by the Commonwealth as either a behavior analyst (LBA) or assistant behavior analyst (LABA)"  In order to practice behavior analysis in Virginia, on must be licensed according to §54.1-2957.16.  Also, the a in BCaBA is lowercase and stands for "assistant."  When referring to a licensed person, the A is capitalized, but still refers to "assistant."

Thank you.

ype over this text and enter your comments here. You are limited to approximately 3000 words.

Regarding the Exceptional Rate for ID Waiver Individuals, please accept the following public comment:

“Behavioral specialist” means a person who possesses any of the following credentials: (i) endorsement by the Partnership for People with Disabilities at Virginia Commonwealth University as a positive behavioral supports facilitator; (ii) board certification as a behavior analyst (BCBA) or board certification as an associate behavior analyst (BCABA); or (iii) licensure by the Commonwealth as either a psychologist, a licensed professional counselor (LPC), a licensed clinical social worker (LCSW), or a psychiatric clinical nurse specialist.

Number ii should read “licensure by the Commonwealth as either a behavior analyst (LBA) or assistant behavior analyst (LABA)”  In order to practice behavior analysis in Virginia, on must be licensed according to §54.1-2957.16.  Also, the a in BCaBA is lowercase and stands for “assistant.”  When referring to a licensed person, the A is capitalized, but still refers to “assistant.”

Thank you for your consideration.

Nikia Dower, MS, CCC-SLP/L, BCBA, LBA

The original estimate which generated the budget of $7.4M for this program was that approximately 250 individuals would need and qualify for this exceptional rate to be successful in a community residential setting. The rates were approved for use on November 1, 2014; in the first 11 months there were only 56 provider applications of which 37 were approved and only 41 individuals had been approved for funding.

Given the delay from the authorized implementation of July 1, 2013 until the actual implementation of November 1, 2014  (16 months), one would have expected a far larger number of applications based on pent up demand.  The modest response indicates to us several things:

• The conditions imposed on the providers (12VAC30-120-1012) are excessive and costly to the point of making the added funding far less attractive
• The conditions imposed on the providers subject the providers to increased risk of being found non-compliant with some aspect of the requirements if audited
• Providers have been successfully supporting individuals who meet all of the qualifying conditions in the community, but can not demonstrate compliance with the conditions described in 12VAC30-120-1012 B.2. because of the structure of the existing funding system.

We recognize that the “exceptional rate” will extend only through the individual’s conversion (either in July 2016 or January 2017) to the revised rate structure; we felt obligated, however, to make these few points as there seems an inclination to make similar “rules” about individuals on SIS Levels 6 or 7 and the providers who support them.  We hope that is not the case!

Number ii should read “licensure by the Commonwealth as either a behavior analyst (LBA) or assistant behavior analyst (LABA)”  In order to practice behavior analysis in Virginia, on must be licensed according to §54.1-2957.16.  Also, the a in BCaBA is lowercase and stands for “assistant.”  

Regarding the Exceptional Rate for ID Waiver Individuals, please accept the following public comment:

“Behavioral specialist” means a person who possesses any of the following credentials: (i) endorsement by the Partnership for People with Disabilities at Virginia Commonwealth University as a positive behavioral supports facilitator; (ii) board certification as a behavior analyst (BCBA) or board certification as an associate behavior analyst (BCABA); or (iii) licensure by the Commonwealth as either a psychologist, a licensed professional counselor (LPC), a licensed clinical social worker (LCSW), or a psychiatric clinical nurse specialist.

Number ii should read “licensure by the Commonwealth as either a behavior analyst (LBA) or assistant behavior analyst (LABA)”  In order to practice behavior analysis in Virginia, on must be licensed according to §54.1-2957.16.  Also, the a in BCaBA is lowercase and stands for “assistant.”  When referring to a licensed person, the A is capitalized, but still refers to “assistant.”

Thank you for your consideration.

this text and enter your comments here. You are limited to approximately 3000 words.