Virginia Regulatory Town Hall
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Department of Medical Assistance Services
 
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Board of Medical Assistance Services
 
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9/19/19  8:21 pm
Commenter: Christy Evanko, VABA

Include Licensed Behavior Analysts
 

We, the members of the Virginia Association for Behavior Analysis (VABA) Public Policy Committee propose the following additions to the manual:

In Chapter II of the Local Education Agency Provider Manual, page 8 (also Chapter IV, page 1,2; Chapter V, page 10) include “Applied Behavior Analysis” as a covered service.  Behavior Analysts are often key team members in public schools and can help with behavior assessments and intervention plans, skill-building, and both individual student and group-focused work.  There is extensive research on behavior analysis in schools.  For a fact sheet, go to https://www.bacb.com/wp-content/uploads/Behavior-Analysis-in-Education-Fact-Sheet_190520.pdf.  Note that the legislature voted in 2019 to include Licensed Behavior Analysts in the budget language using at-risk funds.

In Chapter II, on page 9, Licensed Behavior Analysts and Licensed Assistant Behavior Analysts should be included in the list of possible ORP providers.

In Chapter II, on page 10, Licensed Behavior Analysts and Licensed Assistant Behavior Analysts should be included as supervisors for “Assistance to increase adaptive behavioral functioning”

In Chapter II, on pages 10 -12, Applied Behavior Analysis (ABA) as provided or supervised by a Licensed Behavior Analyst (LBA) or Licensed Assistant Behavior Analyst (LABA) should be added.

In Chapter IV, on pages 6-11, Applied Behavior Analysis should be included as a service that is added into the IEP based on a functional behavior assessment and a written behavior plan. 

In Chapter IV, on page 13, Licensed Behavior Analysts should be added to those who can develop a written behavior modification plan (in addition to licensed psychological provider).

In Chapter V, on pages 23-31, the following codes should be added:

  • 97151 – Behavior identification assessment
  • 97153 – Adaptive behavior treatment by protocol
  • 97155 – Adaptive behavior treatment with protocol modification (supervision)

In Chapter VI, ABA services should be included in the service-specific documentation requirements starting on page 4.

Even though it is permissible in the code of Virginia for school employees to provide services that look like the practice of behavior analysis within the scope of their duties, it is important to include Licensed Behavior Analysts in the list of DMAS approved providers for students.  LBAs have had the extensive training necessary to perform functional assessments and analysis and to write evidence-based behavior plans.

CommentID: 76280