Arizona families who use Applied Behavior Analysis, or ABA, through Medicaid have another opportunity to weigh in on proposed changes to disability services.
And if that sounds familiar, it is.
Families may already be following the HCBS Needs Tool (HNT) and Extraordinary Care Review (ECR) rulemaking, which also has a public comment period underway. Keeping track of multiple AHCCCS proposals, deadlines and comment periods can be a lot, particularly for families already navigating services.
The important thing to know is that these are two separate rulemakings.
HNT/ECR addresses how needs for direct care and habilitation services are assessed for Arizona Long Term Care System (ALTCS) members. This new rulemaking specifically addresses Medicaid-funded ABA services.
The Arizona Health Care Cost Containment System (AHCCCS) opened a 30-day formal public comment period Sept. 17 on proposed ABA rules. Comments are due Oct. 17.
What’s being proposed?
The ABA rulemaking addresses several areas that could matter directly to families, including:
- Eligibility and referrals
- Covered services, limitations and exclusions
- Prior authorization and reauthorization
- ABA assessments and treatment plans
- Qualifications and supervision requirements for ABA providers
- Parent and caregiver participation
The rulemaking follows work AHCCCS began earlier this year to update its ABA policy. Proposed changes have included stronger provider supervision and background-check requirements, more detailed treatment-plan requirements and requirements involving caregiver participation.
AHCCCS has also proposed requiring additional documentation for ABA requests exceeding 25 hours per week, or more than 15 hours per week for students attending school full time.
Why families may want to take a look
Some provisions could affect how families access or continue ABA services, while others are intended to strengthen quality and safety.
Caregiver participation is one area families may want to review closely. Families’ circumstances vary, and work schedules, other caregiving responsibilities and other barriers can affect a caregiver’s ability to participate in treatment. AHCCCS materials recognize that barriers can occur and include provisions for documenting and addressing them.
Families also don’t have to analyze the entire rule or become policy experts to participate in the comment process. A comment can focus on one provision, ask for clarification or explain how a proposed requirement could work in real life.
Two rulemakings, two deadlines
For families following both issues, here’s the distinction:
HNT/ECR: Direct care and habilitation assessment and review. Public comments are due Oct. 12.
ABA: Medicaid-funded Applied Behavior Analysis services. Public comments are due Oct. 17.
Both may be important to some DDD families, but one is not part of the other, and commenting on one does not mean you have commented on the other.
Learn more and comment
Families can review the proposed ABA rule and instructions for submitting comments through AHCCCS.
AHCCCS: Proposed State Rules and ABA public comment information
