In general, we support and endorse the comments of vaACCSES and those of Virginia Association for Behavior Analysis, Public Policy Workgroup.

In specific to add, 

12VAC30-122-550 - Therapeutic Consultation Service. •

C.3- Strike “written preparation and telephone communication” •

D (1) Recommend adding Registered Behavior Technicians (RBT) to list of people that may provide direct support under the supervision of Board Certified Behavior Analyst. (RBT’s would not provide consultation, rather direct support).

12VAC30-122-310 - Community coaching service.

• A- After barriers add “or to support an individual’s participation when there is an ongoing barrier to participation” See definition.

• C.3- Strike “This service shall not be provided within a group setting.” This sentence is not necessary and has the potential the individual from learning how to interact and communicate with others in a community engagement setting – the entire purpose of the service. Requiring the service to be one-on-one is sufficient. 

12VAC30-122-40. Waiver services; when not authorized.

• B. Clarify that transition services can be provided to individuals who are inpatients at the listed facilities when they are preparing for discharge. The subsection states that waiver services shall not be furnished to individuals who are inpatients of a hospital, nursing facilities, ICF/IID, or inpatient rehabilitation facility. It goes on to state that waiver services shall not be provided until the individual has exited the institution and has been enrolled in the waiver. However, some of the costs covered by transition services would have to be incurred prior to the individual exiting the institution, in order for the individual to have an alternative place to live. Such expenses include security deposits, set-up fees, or deposits for utilities, etc.