December 29, 2017

Texas Association for Behavior Analysis – Public Policy Group (TxABA-PPG) provided comments on the proposed rule changes to the Medicaid waiver Texas Home Living (TxHML) program.

• We suggested revising the new definition of chemical restraint.

• We suggested that the procedures used must be evidence-based as determined in formal research. 

• We suggested that individuals receive medical, psychological, or behavioral services after experiencing abuse or neglect.

• We suggested that all references to Board Certified Behavior Analysts or BCBAs as the providers of behavior support be changed to Licensed Behavior Analysts, effective September 1, 2018.

• We objected to the removal of social work services from the rules.

December 31, 2017

Texas Association for Behavior Analysis – Public Policy Group (TxABA-PPG) provided comments on the proposed rule changes to the Medicaid waiver Community Living Assistance and Support Services (CLASS) and Community First Choice program, 40 TAC, Part 1, Chapter 45.

• We suggested that the procedures used must be evidence-based as determined in formal reviews for the population in question.

• We suggested that behavioral conditions be included as basis for treatment.

• We suggested that the terminology be changed to Licensed Behavior Analysts, effective September 1, 2018, as the providers of behavior support.

• We objected to the removal of social work services from the rules.

December 31, 2017

Texas Association for Behavior Analysis – Public Policy Group (TxABA-PPG) provided comments on the proposed rule changes to the Medicaid waiver Home and Community-based Services (HCS) program and Community First Choice, 40 TAC, Part 1, Chapter 9, Subchapter D.

• We suggested that the new definition of chemical restraint be revised.

• We suggested that the procedures used must be evidence-based as determined in formal reviews for the population in question.

• We suggested that behavioral conditions be included as basis for treatment.

• We suggested that the terminology be changed to Licensed Behavior Analysts, effective September 1, 2018, as the providers of behavior support.

• We objected to the removal of social work services from the rules.

January 01, 2018

The Texas Association for Behavior Analysis – Public Policy Group (TxABA-PPG) provided comments on the proposed rule changes to the Medicaid waiver Deaf Blind with Multiple Disabilities (DBMD) and Community First Choice Service, 40 TAC, Part 1, Chapter 42.

• We suggested that the procedures used be evidence-based as determined in formal research reviews for the population in question.

• We suggested that behavioral conditions be included as basis for treatment.

• We suggested that the terminology be changed to Licensed Behavior Analysts, effective September 1, 2018, as the providers of behavior support.