Grafton would like to see regulations that are consistent with the Behavior Analyst Certification Board’s guidelines and standards.  The Behavior Analyst Certification Board articulates sound, clear direction on all aspects of ABA treatment, including assessments, expected duration of services, a recommended tiered service delivery model, case load sizes, and discharge/transition activities.

We support the position that a Board Certified Behavior Analyst (BCBA) or Board Certified Assistant Behavior Analyst (BCaBA) under the supervision of a BCBA is ultimately be responsible for a client’s ABA treatment, whether providing the service directly or through the supervision of a trained Behavior Specialist.  The requirements for these positions and supervision expectations are defined by the Behavior Analyst Certification Board.

We believe more time should be permitted and compensated, as needed, for assessment (up to 10 hours).

Re-authorization periods should be longer than 3 months; we recommend 6-month periods.

A differential rate of payment is needed between BCBAs (a higher rate) and Behavior Specialists.