1. The unit for Therapeutic Consultation for Behavior should be 15 minutes in order to allow flexibility for providers and clients and to account for the various activities. 

2. Consultation via phone and video conferencing should be allowed as billable charges in order to allow for remote participation, training, and fading of consultative services. 

3. For Therapeutic Consultation, page 16 of the Provider Participation Requirements includes the statement: “11. Therapeutic Consultation – in addition to any license, certification, or endorsement, must also possess at least one year of documented work experience in developmental disabilities services, performing functional analysis of behavior, developing behavior support strategies, developing written behavior support plans, and training caregivers in the implementation of behavior support interventions.”

First, this is listed an additional line item after all of the other provider requirements (including OT, SLP, Psych, Therapeutic Recreation, etc...) and not specifically tied to Behavior Consultation. Professions other than Licensed Behavior Analysts won't have experience with the functional analysis of behavior, developing behavior support plans etc..... so if this is included (although it is unnecessary and could be omitted), it should be as an addition to only the Behavior Consultation Provider Participation Requirements section. 

Second, it is rare that a professional providng therapeutic consultation for behavior would actually conduct a functional analysis of behavior. This includes manipulating variables in a controlled setting and the needed factors aren't typically available in home and community based settings. A functional behavior assessment includes interviews, observations, scales, record reviews, etc.... as outlined in the activiites for therapeutic consultation, but there is a distinct difference between a functional behavior assessment and a functional analysis. The reference to functional analysis should be removed from this statement as many licensed behavior analysts may not have experience with a functional analysis of behavior, and that is not necessary in order to provide therapeutic consultaiton for behavior. Additionally, a Positive Behavior Support Facilitator would never have experience in the functional analysis of behavior, so they would be excluded from eligibility to provide therapeutic consultation for behavior, even though they are previously listed as an eligible provider.