To supplement our primary ABA consulting offerings, we also help set up, operate, and advise trade associations and professional organizations supporting collective provider advocacy efforts. Additionally, we consult to other stakeholders with a shared interest in our mission and vision.
Advocacy Documents
Response to The Office of the Inspector General’s Healthcare Division (HCD)’s analysis of MassHealth’s Applied Behavior Analysis (ABA) Program
“The Massachusetts Office of Inspector General (OIG) recently issued a report of its analysis of applied behavior analysis (ABA) services for patients with autism that were funded by MassHeath (the state’s Medicaid program) between January 2022 and October 2023. Key findings were that some ABA providers (a) failed to meet the payer’s requirement for supervising service delivery; (b) submitted claims for “impossible” numbers of service hours; and (c) submitted claims for services delivered on holidays. The OIG’s analysis of selected claims data led them to conclude that as a result, MassHealth made large overpayments for ABA services (see Executive Summary, p. 6 of the report).”
“The analysis is flawed on several dimensions: MassHealth’s definition of “adequate supervision,” the OIG’s decision that it was inappropriate for ABA providers to deliver services on holidays, and the evidence on which the OIG’s conclusions were based.”
Linked below is the entirety of the letter that my colleagues from Partners Behavioral Health (Eileen Mendes, Gina Green) and I prepared, and that I recently sent to the Massachusetts OIG; individuals listed on the second page of the report were cc’d. We’ve also shared this with BABAT and the ABA CPT coding coalition.
We are sharing this information publicly in an effort to help ensure the accuracy of information being disseminated around this report, and to keep our community apprised of our actions on this matter.
Statement on Parent Training as a Condition of Insurance Authorization
Parent training is an important and valuable practice in ABA and supporting your child with autism. “We wholeheartedly support parental involvement and parent training, [but] predicating service authorizations on a required level of involvement or requiring reports of parental involvement can be highly discriminatory and [can pose] unnecessary restrictions on access to care for the autism population.”
A number of years ago some colleagues along with Eileen and Brandon founded MassCAP (Massachusetts Coalition for ABA Providers) to advocate for the interests and standards of ABA providers in MA. The organization has since merged with BABAT’s Professional Practice Committee as their interests aligned, but one of the earlier resources we generated was the attached document. I often get requests for this as it’s been reported to be a valuable resource in responding to insurers who try to limit access to ABA based parent or caregiver involvement.
I want to emphasize this paper is not at all in opposition to caregiver involvement. Clearly there is value in parent or caregiver training and participation. It is in response to Parent Training as a Condition of Insurance Authorization.