The proposed changes to regulations regarding services for behavioral health, medicaid coverage and payment of autism services are open for public comment. Step-In Autism Services of Alaska has concerns about the proposal. The primary concern is that the proposed rate(s) would prohibit Step-In and other providers from offering services to Medicaid eligible individuals. Additionally, the proposal includes reimbursement rates for only a few of the services (assessment, behavior technician direct services, and parent training) offered for a quality ABA program.  The omitted services are follow-up assessments, Board Certified Behavior Analyst direct services, supervision of the behavior technicians by a Behavior Analyst, and others.

You may comment on the proposed regulation changes, including the potential costs to private persons of complying with the proposed changes, by submitting written comments to Rick Calcote at the Division of Behavioral Health, 3601 C Street, Suite 878, Anchorage, AK 99503. Additionally, the Department of Health & Social Services will accept comments by facsimile at (907) 269-3623 and by electronic mail at hss.dbh.publiccomments@alaska.gov . The comments must be received no later than 5 p.m. on October 10, 2017.  If you are interested in making comments, here is an example letter that you may feel free to use in your submission.

Parent Form Letter to ABA Proposal

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)