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April 11, 2022

Agency for Health Care Administration
Bureau of Medicaid Policy
2727 Mahan Drive, Mail Stop #20
Tallahassee, FL 32308


Re: 59G-4.125, Behavior Analysis Services Coverage Policy

The Florida Association for Behavior Analysis would like to thank the Agency for Health Care Administration for working with FABA and providers of behavior analysis to make this transition to CPT codes as smooth as possible and to make certain that effective and ethical behavior analysis services are available to all Florida Citizens.

There are improvements in the proposed policy. One notable improvement is the emphasis
on parent involvement and the allowance for up to two hours per week of telehealth to allow for increased connection at times that are convenient to the recipient. However, as FABA and many others have discussed in prior meetings and in the workshop on 4/8/22, there are significant concerns with a number of aspects of the draft policy:

2.2 - Requires that the referral includes a comprehensive diagnostic evaluation (CDE) that recommends behavior analysis services. This is problematic in that some families are not able to find a provider to conduct a CDE in a timely fashion. FABA recommends that this be modified so that if a CDE has not yet been done but the recipient has a physician’s recommendation for behavior analysis, they would be eligible for services if a CDE was scheduled.

If is also the case that not every professional completing a CDE will recommend ABA. Perhaps ABA was not needed at the time the CDE was initially done, but was later deemed necessary out of concerns for safety, communication, or ability to perform major life activities. The CDE may have been completed in a state that did not have ABA services. FABA recommends that if the CDE did not recommend behavior analysis services but shows that the individual meets criteria for functional impairment, another physician, licensed profession or BCBA-D assess and make a recommendation the individual receive behavior analysis services.

4.2.1 – Requires two specific tools – The Vineland and BASC be administered with each prior service authorization request. These two tools are not sensitive to measuring improvements in recipient behavior, thus the benefit for their repeated use is unclear. The cost of purchasing the tests, obtaining training to administer and administering on a repeated basis are significant. FABA recommends that the pool of allowable assessments be expanded to include other tools such as the ABLLS, AFLS, PEAK, VB-MAPP and Essentials for Living. The professional conducting the assessment should select the tools most appropriate for the individual being assessed.

4.2.2 - The first paragraph indicates that the parent or guardian must participate in treatment. FABA supports the idea that parents participate in treatment, however, there are concerns over what “participate” means. There are also concerns about how this applies to situations when the recipient is over 18, lives in a group home, or has other primary caretakers. FABA recommends that the first paragraph of this section, and subsequent sections that address parents and guardians also include caretakers. Caregivers could be defined as person or personnel that must participate in treatment (e.g., grandparent, home staff, teacher, etc.). Consideration could also be given to providing specific activities that can demonstrate participation (assist with implementation, review data, etc.).

4.2.2 – The listing of procedures does not include all procedures on the fee schedule (e.g., T codes, supervision code. FABA recommends that all procedures on the fee schedule be defined in the policy.
4.2.2. - FABA continues to be concerned about the lack of modifiers when medically necessary treatment is implemented by BCBA, BCBA-D, BCaBA or FL-CBA.
4.2.3 - Supervision - FABA members have raised concerns about the requirement to bill a non-reimbursable code for supervision. For many providers, this will add additional administrative costs in generating and approving notes, entering into billing systems, etc. If supervision occurs in the middle of an RBT’s session, they will have to write 3 notes instead of one.
4.2.4 - Discharge – This section implies that individual would no longer be eligible to receive services if any of the items were true. For items three, four and five, this is problematic since the absence of maladaptive behavior should not be the only criteria for discharge. FABA recommends combining items 3-6 into one item such as “Data indicates the frequency and severity of maladaptive behaviors(s) or level of functional impairment no longer poses a barrier to recipient’s ability to function in their environment”
5.2. – Exclusion – FABA is concerned about the number of new exclusions added to this section. These exclusions will eliminate recipients from getting medically necessary services in environments where the behaviors occur, in situations that will allow the person to integrate into their communities and will interfere with ability to choose the most appropriate educational environment for their child. An unintended consequence of these exclusions will increase the delivery of services in clinics only, perhaps with only the those needing acquisition skills, leaving those bigger stronger, more violent recipients without any providers. Limiting provision of services in some setting will have an adverse affect on some families ability to work.

Concerns with specific exclusions:

  • What is the definition of an Autism Specialty School? Why is the ASD diagnosis singled out?
  • Recreational, leisure or educational camp? Although an RBT should not be used merely to provide 1-1 care in these settings, if these services are deemed medically necessary to treat severe or intense behaviors, or teach skills related to the recipients functional impairment, why is it excluded?
  • Extracurricular activities – In some areas, this may be the best situation to train social skills rather than in contrived social situations.
  • Caregiver of Childcare settings – This can be a valuable area to train skills and address challenging behaviors in integrated setting.

FABA recommends that the exclusions section be re-evaluated and concerns about the environments that services be provided be addressed through the prior authorization process. Perhaps some general guidance could be written into the policy.

6.2.2 This list is similar, but not identical to the Model Coverage Policy provided by the ABA
Coding Coalition. FABA recommends a number of items be modified:

  • The third item requires a “Thorough Medical History…”. This seems excessive and goes beyond the scope of practice of behavior analysts. This should be modified to “Brief background information including available relevant medical history”
  • The Supervision Plan requires the name of the person who is providing supervision. This should be modified to clarify that this is the plan for providing clinical oversight on this plan. Requiring the name of the actual person is problematic as it implies that the plan will need to be updated if there is turnover or coverage issues at the agency.

6.2.4. – FABA members have raised concerns about the practicality of session notes signed. It may not be clinically appropriate to get each note signed. Some electronic medical record systems allow for signatures, but the system do not show all the clinical items listed. It does not appear that this is a requirement for other Medicaid services. In lieu of requiring that each session note be signed, perhaps the parent, guardian or caretaker could sign a verification log that indicates the date, time in, time out, name and credentials of the provider. If the goal is to ensure parent/guardian/caregiver inclusion, the above verification log, along with parent training records, and signatures on assessments would appear to meet that objective.


FABA looks forward to working with AHCA to improve this policy. Please let us know if you
have any additional concerns.


Eric Prutsman – [email protected]
Tiki Fiol - [email protected]
Mary Riordan - [email protected]
 

April 6, 2022

Agency for Health Care Administration
Bureau of Medicaid Policy
2727 Mahan Drive, Mail Stop #23
Tallahassee, FL 32308

Re: 59G-4.002, Provider Reimbursement Schedules and Billing Codes

The Florida Association for Behavior Analysis would like to thank the Agency for Health Care Administration for working with FABA and providers of behavior analysis to make this transition to CPT codes as smooth as possible and to make certain that effective and ethical behavior analysis services are available to all Florida Citizens.

In the weeks since the proposed Behavior Analysis Fee Schedule was released, FABA has received feedback from many providers who are genuinely concerned with continuing to serve individuals with serious behavioral needs in our state. Of the many issues raised, the two primary concerns were:

  1. The rate table does not provide a modifier for procedure code 97153 when the treatment protocol is implemented by a BCBA, BCaBA or FL-CBA. Thus, when ongoing implementation of the treatment plan requires the skills of a more qualified practitioner, they must bill at the RBT rate (a 36% rate cut for BCBAs). AHCA should recognize that although the RBTs provides a valuable service, their training is limited and may not be appropriate for individuals with all types of challenging behaviors. There are a number of other situations that may require treatment to be provided by a BCBA-D, BCBA, BCaBA or FL-CBA rather than an RBT. These may include those individuals who require more sophisticated treatment which goes beyond the training and scope of practice of the RBT, the limited number of hours needed for each code making it most appropriate for one practitioner to provide all services, situations when more intensive services are being faded as well as a variety of workforce issues that impact the availability of RBT’s. FABA understands that AHCA wants to encourage the Pyramidal model when this is appropriate, but as stated above this is simply not appropriate for all recipients. The prior authorization process can be used to limit the use of BCBA and BCaBA services when RBT level providers would be more appropriate. The proposed implementation date for the new codes is July 1, 2022. FABA recommends that a more gradual transition to the new codes is needed to allow providers who do not currently have RBT level staff to attempt to hire them. Alternatively, this would give families a chance to find providers who use the pyramidal model. FABA recommends that modifier codes be added to procedure 97153 so that appropriate rates can be billed when treatment is implemented by a BCBA, BCBA-D or BCaBA. Our providers have informed us if modifiers are not added to 97153, many children with serious challenging behavior will lose services from their current providers.
  2. The current rate table suggests that concurrent billing 97155 with 97153 and 97154 is not allowed. It was clearly the intent of the AMA that these are distinct services and concurrent billing should be allowed. Medicaid plans in many states, and many insurance providers do allow such concurrent billing. Many of these other providers also provide a significantly higher rate. Maintaining a robust provider network for Medicaid recipients will require somewhat competitive compensation rates and allowances. FABA recommends that the proposed fee schedule be modified to allow the Lead Analyst and RBT or BCaBA to bill at the same time, when clinical direction is being provided.

Other concerns raised include:

  • It may be desirable for AHCA to add a location modifier so that an analysis could be conducted of environments in which services were being provided.
  • Although FABA understands that the intent of the current rate proposal was not to increase rates, there is concern that the Medicaid rates are lower than neighboring states and other insurance providers in Florida.
  • Some providers will incur additional costs associated with use of the 97153 XP code. It might help if AHCA explains the purpose of the code and clearly defined its intended use since it is not in the proposed policy.

Eric Prutsman – [email protected]
Tiki Fiol - [email protected]
Mary Riordan - [email protected]
 
FABA 2023 - General Information

43rd Meeting of the Florida Association for Behavior Analysis
September 27-30, 2023

 

 

 

FAQ’s

How do I receive CEUs?  After the conference, we will process and "release" all CEUs. When that happens, if you are seeking MH/PSY CEUs, you will be able to log into BehaviorLive, go to CEU History and view that certificate. Once you pay the fee for those CEUs (in CEU History), you will be able to download your certificates. We will send follow-up instructions when this is ready.

Is there a waitlist for in-person registrations?  In-person registrations are closed at this time.  No additional in-person registrations or waitlist requests will be accepted.  On-site registrations are not available this year.  You must be previously registered for in-person attendance in order to attend in person.

How do I access the member discount?  If you are planning to purchase tickets using a member discount, you must 1) have an active membership before registering and 2) be logged into that account. If you are unsure of your membership status or have multiple accounts (work email, personal email), please contact us at [email protected] prior to attempting to register. We cannot retroactively apply membership discounts after the ticket has been purchased. Discounts will end after September 15, 2023.

When is FABA? As in previous years, FABA will open with workshops on Wednesday, September 27, 2023 and break-out sessions occurring on Thursday, September 28th, Friday, September 29th, and Saturday, September 30th.  Break out session presenters should plan to be available September 28-30, 2023 but we encourage you to join us for pre-conference workshops on the 27th.

How do I submit a presentation proposal to FABA? The Call for Papers has closed for FABA 2023.
 
When is the deadline to submit a presentation? All types of presentations (including posters) to be considered for FABA were due to be submitted by June 2, 2023, at 11:59 PM.
 
When should I expect an acceptance notification? Email notifications will be communicated beginning immediately and no later than July 1, 2023.  Correspondence will be sent to the email address(es) provided in the submission. 

How do I collect CEUs?  FABA will be using BehaviorLive for CEU certificate tracking and delivery this year.  In-person attendees should download the BehaviorLive app from the Apple AppStore or Google Play Store before attending the conference.  If you are attending online, please log in and follow the on-screen instructions.  Find out more here:  https://support.behaviorlive.com/hc/en-us/articles/360052296874-Attendee-Quick-Reference-Guide

Can we still register now and pay later?  Some organizations require an invoice to be submitted prior to payment.  If your organization requires this step, please contact us at [email protected] to set up your registration.  This must be requested via email no later than August 1, 2023, and payment must be completed by August 31, 2023.  No pay-later requests will be able to be processed after August 1.

When will workshops and pre-conference event tickets begin to be sold?  You may add workshop tickets to your conference registration here:  https://behaviorlive.com/faba/workshops

Do FABA members receive a discount for the hotel room block this year?  FABA members are eligible for a conference rate at the Hyatt Regency Grand Cypress Resort.  Click here to book through the conference room block with special, member pricing.

How do I request a refund?  Refund requests must be submitted by August 31. Cancelations will not be honored after this date, but you may still switch your in-person registration to virtual registration up until the day before the conference.

 

Conference Details:

Highlights

Tuesday, September 26

5:30 pm - 7:00 pm - FABA Store and Packet Pick Up

Wednesday, September 27

8:00 am - 6:00 pm - FABA Store and Packet Pick Up

9:00 am - 12:00 pm - Workshops

12:00 pm - 3:00 pm - Exhibitor Check-in and Set Up

1:00 pm - 5:00 pm - Workshops

6:30 pm - 9:30 pm - Welcome Reception

Thursday, September 28

7:00 am - 5:00 pm - FABA Store and Packet Pick Up

8:00 am - 5:20 pm - Sessions

5:30 pm - 6:30 pm - Presidential Poster Session

Friday, September 29

7:00 am - 5:00 pm - FABA Store and Packet Pick Up

8:00 am - 5:20 pm - Sessions

8:00 pm - 11:00 pm - Ignites @ Nite & Friday Night Social

Saturday, September 30

7:00 am - 11:00 am - FABA Store and Packet Pick Up

8:00 am - 11:50 am - Sessions

 

Host Hotel

Hyatt Regency Grand Cypress
One Grand Cypress Blvd, Orlando, FL, 32836, US

 

Events and Dates

September 27-30, 2023, with pre-conference workshops on Wednesday, September 27.

Conference Registration Fees

In-person tickets are only available via advance registration.  These have sold out in the last few years, so it is highly encouraged to purchase your tickets as soon as possible.  There is also a virtual, live-stream option hosted by our friends at BehaviorLive. 

Advance Registration will be available for the following packages through Friday, September 15:

Professional Member Advance Registration  $250
Student / Direct Care / Parent Member Advance Registration $145
Non-Members Advance Registration $360
Advance Workshop Ticket (each) (BA CEUs included for workshop) $95
Behavior Analysis CEU Package $100

 

 

Virtual Registration Only will be available after Friday, September 15:

All Virtual Registration (after 9/15) $360
Workshop Ticket (each) (BA CEUs included for workshop) $95
Behavior Analysis CEU Package $100

 

 *Pricing is automatically applied based on membership status at the time of registration. No additional discount code is necessary to receive pricing discounts. Please ensure that your membership is current at the time of registration. We are unable to refund the price difference after registration is complete. 

 

When to Arrive and Leave

The conference break out sessions officially begin on Thursday, September 28, 2023 at 8 AM, and conclude on Saturday, September 30 at 12:00 pm. FABA's Pre-Conference workshops will be held on Wednesday, September 27th and require an additional ticket purchase. 

Most attendees will want to arrive by Wednesday evening in order to attend the Welcome Reception and the Annual special session that has been held by the BACB the past six years as a method to deliver pertinent updates to the members of FABA.

If you would like to take advantage of the full conference event, departure travel should be planned for Sunday, October 1. We encourage all attendees to experience the full conference.

Registration Cap

This year, we will be capping registration at 1,800.   This number is determined by the Fire Marshal as the maximum number of people who can exit the conference area in the event of an emergency. Please avoid attempts to attend the social events only without registering for the event to limit overcrowding. Please also plan to wear or display the conference name badge to security should you be prompted to do so.

On-Site Registration

FABA does not offer on-site registration. This event is for preregistered attendees only.

Transportation

Below is information about the distance to several airports as the hotel does not offer a shuttle. 


International airports near Orlando, FL:

Domestic airports near Orlando, FL:

 

Parking

Both Valet parking ($45) and self-parking ($10-hotel guests/$30-drive-in guests) are available at the hotel, but these rates are subject to change. An additional overflow lot is located further away from the hotel with free parking subject to availability. FABA does not validate, reimburse, or offer additional discounts on parking rates.

Weather/Conference Attire

In September, the temperature is an average high of around 90 degrees, with an average low around 75 degrees. Meeting room temperatures tend to be cold. Please bring a light sweater or jacket to all meetings. 

Visas

Should you require an invitation letter for a Visa application for travel to the U.S. to attend the conference, please forward proof of your conference registration to [email protected] so that a letter can be issued to you.

Accessibility for Registrants with Disabilities

FABA is committed to providing an outstanding experience for all participants.  We strive for full access to the activities of these events based on an awareness of participants' needs and appropriate planning.  Accessibility accommodations relating to mobility, hearing, vision or other areas may be provided.

We ask that requests for reasonable accommodations requests be made as early as possible, and well in advance of the event, so we may best accommodate individual needs and requirements. Onsite requests will be accommodated to the best of our ability; however, available resources may be limited. You will see the opportunity to express your needs during the registration process as we are here to ensure a comfortable and accessible conference experience.

For questions or concerns about accessibility at this year’s conference, please contact [email protected]

Session Room Behavior

Extensive planning goes into scheduling sessions in appropriately sized rooms; however, the popularity of sessions is not always predictable, and overcrowding occasionally occurs. If a session room reaches capacity, attendees must follow the instructions provided by FABA staff, host hotel Regency staff, volunteers, or security staff. Attendees may be instructed not to stand against the walls or block the aisles or doors, or they may be denied entry if the room is too crowded. FABA is obligated to abide by the guidelines established by the Fire Marshal. If a room reaches full capacity and we do not have your cooperation, the Fire Marshal has the authority to delay or even terminate the session until any problem has been satisfactorily corrected. Please be courteous and respectful to staff and student volunteers when you are directed elsewhere.

Attendees are asked to be respectful of their fellow attendees and to be mindful of potential disruptions during sessions, such as eating food, use of phones or other mobile devices, or the presence of infants and children. Phones and other mobile devices should always be silenced. Attendees should not be photographing presentation slides unless explicit permission has been granted by the presenter(s); please respect the Recording Policy. Further, due to contractual obligations with both speakers, invited presenters, hotel management, and virtual presentation companies, no recording is allowed in sessions including during Ignites and social events without written approval of the Program Chair. Approval is contingent upon disclosing the purpose for the recording as well as adding a disclaimer that content is not endorsed by FABA.

Presentation Content and Feedback

Through the process of the Call for Papers, all submissions that included an abstract, title, learning objectives, data, and speaker qualifications are reviewed by over 35 independent reviewers from the field. These reviewers are volunteers from across the state that consist of practitioners and researchers as FABA aims to provide the highest quality, state-of-the-art research findings for attendees. However, FABA does not individually vet the specific content of each live presentation in advance of the event. Therefore, FABA is not responsible for the content a presenter may choose to deliver during a live or pre-recorded presentation nor can the FABA Program Committee guarantee that a presentation includes all relevant facts, data, or the most up-to-date research. FABA is not liable in the event that omissions or errors occur. However, FABA also affords attendees and members the opportunity to deliver feedback to each presenter through session ratings and feedback narratives immediately upon the conclusion of the session. FABA also provides the email address for each speaker at the conference printed in the conference Program to facilitate an attendee's direct communication with the presenter of concern. In line with the BACB's Ethics Code for Behavior Analysts, FABA encourages attendees to deliver immediate feedback directly to presenters should the need arise and, as always, please reach out to the Program Chair should you need additional clarifications or support.
 

https://forms.gle/coCEPbhxFBEEER426

 

 

FABA conference.JPG

Click here to apply for "MH/PSY" Continuing Education for LMHC, LCSW, LMFT, Psychology CEs at the FABA conference

 

 

We apologize for the confusion in this year's MH/PSY CEUs.   

If you were not able to access the complete list of approved talks, they are listed below:

Wednesday, 9/29/2021

  • Workshop02: A Practical Guide to Using the Supervision Handbook

  • Workshop03: Training Teams to Be Ethically Fit at Every Level: RBTs to BCBAs . . .

  • Workshop04: Assessment and Treatment of Children with Emotional & Behavioral Disorders

  • Workshop05: Bringing Solution Focused Language & Ideas When Working with Families with Autism

  • Workshop08: Multidisciplinary Collaboration: Strategies for Approachable & Accessible Communication with Educators

  • Workshop12: Training on the use of a Reinforcement-Based Treatment Package to address Picky Eating

  • Workshop11: Assessment Tools for Individuals with Autism Spectrum Disorders (ASD): Choosing . . .

  • Workshop13: Reviewing Supervisees' Behavior Programs for Dangerous & Challenging Behaviors

  • Workshop14: Using Adaptive Assessments Ethically in Behavior Analytic Practice

  • Workshop16: Engineering Schools and Clinics for Student and Client Success

Thursday, 9/30/2021​

  • #21 Machine Learning to Improve Practice and Research: A Series of Three Applications in Behavior Analysis

  • #25 The Application of Applied Behavior Analysis to the Juvenile Justice Field

  • #26 J-DEI and ABA: A Justice-Centered Approach to Expanding Applied Behavior Analysis in Public Health Option 3

  • #32 Toward an Applied Technology of Conditioned Reinforcement

  • #33 Assessment and Treatment of Behavior Disorders: The Next 40 Years?

  • #43 A Behavioral Coaching Toolbox of Essentials for Creating Sustainable Improvement in Schools

  • #46 Creating the right environment for success

Friday, 10/1/2021​

  • #53 Training Staff Working with Adults with Intellectual and Developmental Disabilities in Inpatient Settings Using the ECHO Model

  • #57 From Baselines to Phase Lines: The State of Behavior Analysis in Florida's Agency for Persons with Disabilities

  • #58 Ethical Issues in Using Standardized Decision-making to Inform Professional Practice Option 3

  • #61 Engineering Schools and Clinics for Student and Client Success

  • #63 Company-wide Implementation of a Parent Training Curriculum

  • #70 Special Paper Session: ABA in Education

  • #74 Informing ABA on Trauma-Informed Care: Crisis Evaluations, Ethical Implications, and Practice Applications

  • #75 Beyond the Task List: Preparing Your Supervisee for the Real World

  • #76 Using Behavioral Skills Training to Teach Sexual Assault Reporting Skills to University Students

  • #78 Private Events in Behavior Analysis: A Review of Studies Investigating Emotion

  • #79 Efficient Approaches for Disseminating Behavior-Analytic Procedures to Non-Behavioral Professionals

  • #80 Context is Key: Using the Contextual Variable Analysis and Planning Tool to Improve Treatment Outcomes

Saturday, 10/2/2021​

  • #85 Compassionate Care in Applied Behavior Analysis - How Our Past can Inform Our Future as Leaders in Compassionate Care

  • #87 From Business Opportunity to Behaviors: Selecting Meaningful Pinpoints for Your OBM Project

  • #89 Integrating Care for Children with Autism Spectrum Disorder: Promoting Collaboration between Behavior Analysts and Medical Personnel

  • #94 Can Behavior Analysts Behave Ethically?

  • #96 Advances in Understanding and Treatment of Automatically-Maintained Self-Injurious Behavior

 

Directions:

Step 1: Attend sessions at FABA2021, scan in and out of each session using CEU helper.

Step 2: Complete this form and pay for each of the MH/PSY/LMHC CEs you need credit for (CEs are offered through Adapt Behavioral Services) 

Step 3: Submit copies of your attendance certificates here:  https://forms.gle/coCEPbhxFBEEER426

 

 
 

Membership Renewal

 

The easiest way to renew your membership is to pay the membership renewal invoice. These invoices are automatically emailed to current members in December and come from the email address: [email protected]. (Please note: Everyone’s membership period is the same, regardless of when a member joins or renews. The membership period runs from January 1 – December 31.)

In the email, scroll about halfway down the screen and look for the blue link that says, “Click here to pay this invoice.”

If you cannot find the membership renewal email with the invoice OR your membership has lapsed, you can renew your membership by visiting the link below. It is IMPORTANT that you use your existing FABA username and password to log into the EXISTING USER section. If you have any problems at all, just reach out to us at [email protected]. Membership is nonrefundable.

Thanks for being a FABA member!


Renew My FABA Membership

 

 


By registering you agree to FABA’s Terms and Privacy Policy

 

 
 
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