The opportunity to comment on the EPSDT Behavior Therapy townhall is greatly appreciated.

Please consider the following:

- Limiting ABA to the home severely limits the efficacy of the service. Services should be provided in the location that is most appropriate to the needs of the individual. This may be a clinic, community, social group, or other place that meets the needs of the individual.
- ABA clinics should be required to obtain a license that is appropriate to their business, which is not available at this time.

- ABA does not necessarily need to be provided individually, but may be appropriate for some individuals in a group setting.  The service should be available in a group setting or one-on-one with an individual as is dictated by the individual’s needs and outlined in the ISP.

- ABA and Behavioral Therapy should be separate treatments and ABA should be solely guided by the DHP regulations governing behavior analysts.  Often behavioral therapy run by non-LBAs looks more like counseling or behavior modification and not the science of ABA.  It is confusing to lump the professions together, and the distinction is necessary.

Clarification is needed regarding the following found in the proposal:

- The statement about a service specific provider intake being done face to face with the individual and guardian- obviously the individual should be part of the assessment, but conducting an interview alone with the guardian is also vital to the assessment process. This wording could be construed by Quality Assurance divisions as not allowing for this to occur.
- Completing an intake every 3 months- Quarterly reviews assess progress and the need to make changes to the treatment plan. This process includes a review of services and behaviors. What is the additional benefit of completing an entire intake instead?
- Section 8a references a “screening to identify physical, mental, or developmental conditions”. Is this referencing the DMAS 355 form? If not, clarification is needed.
- Section 8d states that family support and education are not allowable. Clarification as to the meaning of this language is needed as a major focus of the service is teaching and modeling for caregivers.

Section 11c references 2 areas of clarification:

i.“Documentation shall include activities provided, length of services provided, the individual’s reaction to that day’s activity . . . “- This last point regarding the individual’s reaction seems to move from the data driven model of ABA to a more subjective framework. An individual’s reaction is seen through the behaviors observed and data produced. The last point listed seems to open the door to statements such as “he enjoyed the activity, he became frustrated with the activity, etc.” which are not objective measures.

ii.“Documentation shall be prepared to clearly demonstrate efficacy using baseline and service-related data that shows clinical progress and generalization for the child and family members toward the therapy goals as defined in the service plan.”- Service plans are developed after a baseline is established. This wording does not provide for such time and staff obtaining baseline data in preparation of the plan would be documenting their efforts, but would not yet have a service plan to document against.