Virginia Regulatory Town Hall
Agency
Department of Medical Assistance Services
 
Board
Board of Medical Assistance Services
 
chapter
Amount, Duration, and Scope of Medical and Remedial Care and Services [12 VAC 30 ‑ 50]
Action EPSDT Behavioral Therapy Services
Stage Proposed
Comment Period Ended on 9/22/2017
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9/22/17  4:01 pm
Commenter: Donna Cattell-Gordon, LBA & Parent

EPSDT Behavioral Therapy Proposed Change H7
 

In regards to proposed regulation change H7 that specifies that "Clinical supervison shall occur at least weekly..." I am concerned that this change unintentionally usurps both the role of the Board of Medicine to set supervision standards and the judgement of the Licensed Behavior Analyst to set supervision requirements on a case by case basis.  In addition I am concerned that the unintended consequences of this rule change would be that fewer children would be served.  Why not just align the supervision rule with the current Board of Medicine standard?

CommentID: 62826