I’ve been a BCBA for four and a half years, and in that time I’ve practiced in nearly every setting ABA offers. I started in family homes, moved into a role split between a clinic and homes, and now provide services entirely through telehealth. Today I also train and mentor the BCBAs who work with Virginia children, most of whom rely on Medicaid. Each of those settings has taught me the same thing: progress depends on giving a child the amount of support their assessment calls for, and giving it without long gaps. I’m writing because parts of the proposed Appendix D would make that harder.

My biggest concern is the 20-hour weekly line on page 28. When my team builds a treatment plan, the hours aren’t a guess. They come from what we observe and measure. Some children do well with fewer than 20. Others, especially those whose behavior makes them unsafe at home or keeps them out of school, need more to make meaningful progress. Federal guidance from CMS this year makes clear that children covered by EPSDT shouldn’t face hard limits on care. I’d ask DMAS to write the rule so that going above 20 hours starts a closer look rather than a likely denial. I’d also ask that the count include only time spent directly treating the child. Coaching parents and supervising staff are some of the most valuable work we do, and they shouldn’t be what pushes a family over the threshold.

That closer look also needs a clear owner and a clock. The section on page 31 promises a review but doesn’t say who conducts it or how long it can take. Every week a child waits at reduced hours is a week of lost ground. Please have these requests decided by someone with ABA expertise, within about a week, and let the child keep their current services until a decision comes back.

My telehealth work makes me especially worried about requiring every diagnostic evaluation to happen in person For a toddler, a long wait for a diagnosis means a long wait for treatment, during the years it helps most. I’m not asking DMAS to drop in-person evaluations. I’m asking for a fallback when a family truly can’t get one in a sensible timeframe or distance, and for DMAS to honor valid evaluations a child has already received.

Oversight and good care aren’t in conflict. With a few adjustments to these sections, DMAS can keep the checks it’s looking for while making sure Virginia children get the right amount of help at the right time. Thank you for reading.

Brandon Eason, MS, BCBA, LBA