Mr. Rick Calcote

Division of Behavioral Health

3601 C Street, Ste 878, Anchorage, AK 99503

(907) 269-3623 (fax)

hss.dbh.publiccomments@alaska.gov

 

Re:  PROPOSED CHANGES TO REGULATIONS: SERVICES FOR BEHAVIORAL HEALTH, MEDICAID COVERAGE & PAYMENT: AUTISM SERVICES.

7 AAC 70. BEHAVIORAL HEALTH SERVICES; 7 AAC 105. MEDICAID PROVIDER AND RECIPIENT PARTICIPATION; 7 AAC 110. MEDICAID COVERAGE; PROFESSIONAL SERVICES; 7AAC 135. MEDICAID COVERAGE: BEHAVIORAL; HEALTH SERVICES; 7 AAC 145. MEDICAID PAYMENT RATES; & 7 AAC 160. MEDICAID PROGRAM; GENERAL PROVISIONS.

Dear Mr. Calcote:

Thank you for the opportunity to comment on the Department of Health and Human Services proposed changes.  I am the [PARENT/GUARDIAN] of a child under age 21 who requires Intensive Active Treatment (IAT) in the form of Applied Behavior Analysis (ABA) services. Some significant changes that these services have made for my child include: [ADD IN PROGRESS YOU HAVE NOTED FOR YOUR CHILD(REN)]

 

The proposed changes to regulations will effectively prohibit any provider of ABA services in Alaska from accepting children covered by Medicaid, leaving some of Alaska’s most vulnerable and needful children without services. Specifically:

 

·        The changes do not include a reimbursement rate for the Masters/Doctoral level professional (BCBA/BCBA-D) who is responsible for ensuring fidelity and the successful programming for my child via supervision, assessment, and direct services with my child.

·        The proposed Medicaid rate is only 47% of the current rate paid for the same services to my provider, who has been providing IAT/ABA services to families in Alaska for 7 years.

·        Per the TRICARE Medicaid[1] study, the proposed AK Medicaid rates are well below the national average ($65.16/hr for behavior technicians and $94.72/hr for BCBAs).

·        Yet Fairbanks, AK has a cost of living rate that is 32% higher than the national average.

·        Proposed hourly AK Medicaid rates for BCBAs/BCBA-Ds should be developed and comparable to other professionals with similar educational requirements such as SLPs, OTs, and PTs. ($153.76, $181, $181 respectively[2])

 

If implemented, the proposed Medicaid rates will force my provider, Step-in Autism Services of Alaska, LLC, to close its doors.  If you have any questions, please feel free to contact [insert contact information].

 

Sincerely, 



[1] Maglione, M., Kadiyala, S., Kress, A., Hastings, J. L., & O’Hanlon, C. E. (2017). TRICARE Applied Behavior Analysis (ABA) Benefit: Comparison with Medicaid and Commercial Benefits. Rand Health Quarterly6(2), 10.

[2] State of Alaska (2017). Alaska Medicaid Fee Schedules and Covered Codes. Retrieved from http://manuals.medicaidalaska.com/medicaidalaska/providers/FeeSchedule.asp. (Codes referenced: SLP-97532, OT-97110, PT 97110)