Thank you for the opportunity to commment on the proposed changes.  I am a PhD-level Board Certified Behavior Analyst and Director of Clinical Services for our Agency.  I am proud that we provide center-based, in-home, and community-based Applied Behavior Analysis services.  

A few notes on ways in which changes to the way EPSDT covers ABA are suggested for your review: 

1. ABA and  Behavioral therapy are NOT the same.  Thus, they should be seperate treatments and ABA should be guided by the DHP regulations, which governs behavior analysts.  The certification overseen by the DHP ensures that the national requirements by the Behavior Analyst Certification Board function as a minimum standard and protects the practioner and consumer.  It is inappropritae to lump professions together both because of the obvious differences in certification requirementsand and it would cause confusion to the consumer, as well.

2. The location of services should be determined by the professional, i.e., the BCaBA/BCBA/BCBA-D.  For some individuals, that might be in the home, the community, a center or a combination thereof.  However, an important consideration is the licensure of center-based services, which is not currently available. 

3.  Similarly, ABA can be provided individually or in small groups, and that determination should be made, also, by the professional.  

Revising regulations is a tedious process.  Thank you for taking the time to review my comments.  

Katie Topham, PhD, BCBA-D, LBA