by James C. Sherlock
Parents, grandparents, and other caregivers of autistic children must understand who will actually be treating the child and monitor the services so that the rules of the insurer, which are important to the childโs outcome, are followed.
Many of the Board Certified Applied Behavioral Analysts (BCABA) licensed in Virginia live in other states. Some BCABAs who live in Virginia advertise their services statewide. That means neither will be providing in-person services to many of their clients.
An additional concern is that many billing errors and some fraud identified in state Medicaid programs for autism services stem from disregard for the required provider hierarchy in patient care, both in treatment and in billing.
Medicaid will be used as an example, but private health insurers generally follow the same hierarchy of services and payment rules.
In the case of Virginia Medicaid, to qualify for reimbursement, all service delivery must comply with:
- The licensed clinicianโs scope-of-practice guidelines; and
- The rules of the Virginia Medicaid Applied Behavior Analysis (ABA) program.
Caregivers’ concerns should mirror those of Virginia Medicaid
Virginia Medicaid sent a letter to all ABA service providers in December 2025. That letter pointed out specific issues that needed to be addressed. Those issues are as important to caregivers as they are to Medicaid and private health insurers. They include:
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