Letter to Legislators - Protect Healthcare: ABA Coverage

ABA therapy is the most effective, evidence-based treatment for children on the autism spectrum. Reductions in funding coverage harm children who rely on ABA therapy and violate the federal Mental Health Parity and Addiction Equity Act (MHPAEA) which prohibits time caps for ongoing conditions.

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Why Are Reductions in ABA Coverage So Devastating?

1) Time and consistency are critical in the successful delivery of ABA therapy. 

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The majority of children receiving ABA therapy rely on more than 30 hours a week. This is based on assessment of medical necessity by their healthcare provider. Providing less than this goes against the data-driven principles that guide all ABA decisions. 

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At best, clients with reduced hours will need to remain in ABA longer to achieve similar results (though building fundamental skills becomes harder with age). At worst, reduced time will halt progress or even cause progress to backslide.

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2) Limiting all children to an arbitrary number of years of coverage without evaluating their need is illogical and incredibly harmful. 

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All children learn at different paces. Just because a child is moving "slowly" through goals according to neurotypical standards does not mean ABA therapy has failed or that the child is not receiving a vital service. 

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An increase in behavioral issues when ABA is halted unexpectedly is well documented in both behavioral data and family testimony.

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A successful transition can only happen when children have mastered the necessary skills and can apply them across all environments.

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3) Redundant credentialing requirements lower the timeliness of care. They don't increase the quality of care.

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Excessive, bureaucratic requirements add months to the time a child will spend on waitlists. This delay in services will harm children and is in violation of EPSDT, which says children should have immediate access to medically necessary care.

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Furthermore, since this gap in average wait time is based on a family's financial source for their healthcare, this will amplify socio-economic disparities in access to medically necessary services.

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Medicaid Changes Disregard Data, Protocols, and Federal Requirements:

These time limits are being selected by individuals who are not BCBAs and are not qualified to recommend a reduction in hours for any client. They fly in the face of the data-driven practices that make ABA therapy effective.

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Medicaid's proposals are in direct violation of established policies: the Mental Health Parity and Addiction Equity Act (MHPAEA) and the CMS requirements for Early and Periodic Screening, Diagnostic and Treatment (EPSDT). CMS recognizes that a treatment does not need to "cure" a condition in order to be considered successful or medically necessary. 

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Furthermore, Medicaid made these announcements without following the standard protocol of soliciting input from families or providers. In violation of the rulemaking procedures set forth by ODM, there was no public comment period or public hearing for these proposed time caps and requirement increases. 

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Changes Ignore the Long-Term Economic Impact:

If these changes are enacted, it will cause negative ripple effects throughout our state for years to come. These children will not be able to be fully active, engaged participants in their community without the ABA therapy they need. 

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The proposed limits will increase costs for the state in the future, not decrease them. By not providing the appropriate treatment now, the state will pay more later for more complex and costly services.

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In Summary:

ABA is helping children to flourish by providing them with the skills and tools they need to navigate life. But learning to use tools takes time, often more than 3 years and 30 hours per week of services. I find it horrifying that a child with a disability (or disabilities) might lose access to this treatment because they are not progressing as quickly as the Medicaid budget would like. I find it appalling that Medicaid wants to enact rigid limits on a service that treats such an incredibly wide spectrum of symptoms. 

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I am appealing to you to help prevent these harmful and unjust Medicaid limits from being enacted. Thank you for your time and attention.