As summer turns to fall and Michiganders (sort of…) return to school, MiBAP continues to provide our members with advice and support on several different fronts. As a reminder, our COVID-19 Resource Page includes our position statement on ABA Services during the pandemic, along with several other resources and guidance. We continue to advocate on behalf of the ABA community on a wide range of issues:
Long before COVID-19, there has been ongoing confusion regarding the delivery of ABA services to students during traditional school hours. Although Section 18.10 of the Medicaid Manual discourages ABA services when the child would typically be in school, MDHHS has made it clear that ABA services can be scheduled during typical school hours, when medically necessary and when in support of and not overlapping with educational services. With the advent of COVID-19, this exception has become the rule, as thousands of autism-diagnosed and/or special education students are forced (or choose) to attend school from home – very often without the necessary technology or other supports available to them in a school setting. During these unprecedented times, it is crucial that families, schools, and medical professionals be empowered and given the flexibility to develop an Individual Plan of Service (IPOS) that best meets the combined educational and medical needs of the child. Failure or even delays in authorization of complementary and coordinated ABA services to this extremely vulnerable population will exacerbate the looming, COVID-induced mental health crisis, and likely be in violation of the Mental Health Parity & Addition Equity Act (MHPAEA). MiBAP strongly supports a parent’s right to request and receive non-overlapping ABA services for their child during times that have traditionally been considered “school hours,” as deemed medically necessary by the supervising medical professional, and in collaboration with caregiver(s), educators and the treatment team.
Q3 saw us active on several ABA policy fronts, beginning with another TRICARE Autism Cares Demonstration (ACD) report that again questioned the efficacy of ABA in the treatment of autism. MiBAP and several other organizations have responded to this report, to include submissions and testimony directly to the U.S. House and Senate Armed Services Committees. Over the summer, MiBAP has also weighed in on issues to include ABA during school hours (see above), crisis management and restraint legislation, ongoing ABA network stabilization funding, Direct Care Worker (DCW) premium pay extensions, and a Milliman actuarial study commissioned by MDHHS on the cost buildup for ABA billing rates. We are pleased to report that, despite significant budget shortfalls due to COVID, there have been no cuts to the Medicaid Autism Program budget or rates in the Michigan FY21 state budget, which began October 1.
In connecting with 100+ ABA providers across the state of Michigan this summer (see below), a few common themes resounded – first, that many providers continue to struggle operationally and financially as a result of the COVID-19 pandemic. Second, that while there are numerous resources available for clinical training, there are very few organizations or resources focused on teaching the business aspects of running an ABA company. With this in mind, MiBAP has announced the launch of an Educational Webinar Series, focused on the business of ABA. After polling our membership, planned classes include Clinical Operations (Balancing Quality & Profit), Finance 101, HR 101, Advocacy 101, ABA Staff Recruiting, and many more! Look for an announcement soon for our first webinar, scheduled for mid-November.
Over the summer, MiBAP conducted a communication and membership drive initiative to connect with every one of the 100+ ABA providers across the State of Michigan. In addition to learning quite a bit about what’s “top of mind” with Michigan ABA providers, we are also pleased to announce that several new members have joined the organization. Welcome! As of September 30, MiBAP now boasts 22 member organizations. These members collectively serve over two-thirds of all individuals receiving treatment for ASD through the Michigan Medicaid autism program. As part of this effort, we also issued a renewed call for participants on each of our committees – Access, Advocacy, Education, Membership, and Quality. We are thrilled to say that there are now 50+ individuals serving on one or more MiBAP committees. If you aren’t already on a committee, please join us! Contact our Executive Director, Mike Dow (firstname.lastname@example.org) for more information.
Below are quick updates from each of our committees, along with a few articles and papers you may find of interest. Stay safe!
Based on a survey conducted in 2019 and subsequent discussions, the Access Committee plans to spend time into 2021 focused on: (1) increased access to ABA through educational opportunities for the pediatric community; (2) working to establish some permanency to the telehealth expansion that occurred during the pandemic; and, (3) working to increase access to ABA in school settings. Given recent events, the implementation of these plans is expected to evolve over the next several months and may include virtual meetings and other on-line content. Additionally, the Access Committee voted on topics of importance for the MiBAP educational webinars and determined that we would sponsor a webinar/workshop on building relationships with school professionals. MiBAP members interested in participating in these efforts should contact the Access Committee Chair, Adam Bennett, through MiBAP.
Advocacy & Policy is a major focus of MIBAP. The Advocacy Committee has been established to support the MiBAP goal of Advocating for ABA services in environments where behavioral interventions can improve an individual or organization’s well-being and/or performance, to include the treatment of autism, traumatic brain injury, intellectual and developmental disabilities. In our first full year, MiBAP efforts in advocacy were substantial and proved to be effective. We had significant influence on autism legislation, including FY20 MDHHS Budget boilerplate Sections 959, 960, 924. Additionally, formal position papers and educational efforts were delivered on key issues, including non-credentialed supervision, background checks, telehealth, and ABA service delivery during school hours. Advocacy efforts are focused to impact both Medicaid and private payers. Our inaugural “Advocacy Day” in Lansing saw significant member participation and was well received by legislators and their staff.
The advocacy committee is currently developing their 2021 focus and action plan. With seven of the 22 MiBAP members participating in the committee, we are looking for broad involvement of the MiBAP membership in either the committee or in Advocacy Committee sponsored activities. To participate, please send an email to Jeff Brown, Chair of the MiBAP Advocacy Committee, email@example.com
In 2021, the Education Committee will be overseeing the logistics and schedule for MiBAP’s Educational Webinar Series, while also publishing this newsletter and contributing to other educational opportunities for our members, when they arise. Members interested in helping with these efforts should contact Mike Dow, MiBAP Executive Director (firstname.lastname@example.org).
The Quality Committee would like to thank Zach Duggar for his efforts in establishing and leading the committee during our first eighteen months. Zach and the rest of the committee now welcome Jon Timm, Executive Clinical Director of North Arrow ABA, as the new Quality Committee Chair. Recently the Committee has been continuing its search for a quality outcomes measurement expert to provide guidance and consultation to MiBAP. Members have been participating in research and review of payer requirements, review of legislator criteria, and best-practice measures of quality outcomes. Future activities will include the development and delivery of a training webinar for Clinical Operations Promoting Quality Outcomes for ABA providers. Any members interested in joining this discussion should contact Jon Timm, Quality Committee Chair, through MiBAP.
We have been faced with numerous issues as an industry in the past year. Whether it be COVID closing/reopening, boilerplate language, or our ability to conduct ABA during school hours, there has been one fundamental theme – the power to determine an individual’s course of treatment needs to reside with the supervising clinician, parents, and treatment team. Guidance, policies, or roadmaps that do not acknowledge this necessity will only serve to strip an individual of the ability to receive the highest quality of individualized care. We strongly believe that the best clinical decisions are made at the individual level, by treatment teams, and we will continue to advocate for what we believe to be best practice.