As an ABA in home counselor that went on to pursue my BCBA in order to best develop programming and interventions, I have been disheartened by EPSDT’s withdrawal of approval for BCBA provided assessment and supervision.  In order to provide quality services to the children of Virginia I make the following points:

BCBA’s are well equipped to provide oversight to quality treatment services.  They are well trained in behavior techniques, building communication, data collection and interpretation, task analysis to build independent living skills, discrete trial, and many other techniques.

BCBA’s will not have an incentive to work for Medicaid funded agencies according to the current limitations.  Other states offer more opportunities and higher reimbursement rates.

As a behavior counselor and BCBA, I have benefited greatly from supervision and insight offered from a LMHP or LMHP-E, so I would strongly suggest not limiting supervision to BCBA’s alone.

We feel that behavioral therapy can best be provided by counselors with specific training and demonstrated competency regarding the practice of Applied Behavior Analysis.

Other considerations that affect programming:

The three month turnover rate for extension requests adds a significant burden to direct care staff

Quality Assessment is key to program development. We would like the option to provide a total of 7-10 hours for administration and interpretation of the VB-MAPP to children with emerging language development.