Just some information I got regarding Colorado in case it is of interest to someone

[Guest guest]

This

is a post from P2P regarding the changes to the DD waiver here in the state of

CO.

If

you are on the waiver or are on the wait list for the waivers you will want to

read this.

The

Division for Developmental Disabilities has had at least two ad hoc committees

working on various aspects of the re-writing of some Medicaid waivers. Jo

Rymer has given some information on the " 1:1 committee " that

discussed changes to be made to the HCBS-SLS waiver relative to supporting the

needs of people who need 1:1 support in various settings. There was another

committee that met to talk about the HCBS-DD waiver concerning the provision of

behavior supports. The DD waiver language concerning behavior supports is the

one we are writing about here.

There will be a period for public comment, and it will be important that people

in the parent and advocacy community have some background information in order

to weigh in with facts, figures and perspectives when the waiver re-writes are

opened for public comment. While I don't know the language in the DD waiver

that will be released for public comment, the draft language I've seen is very

restrictive and offers no choice in behavior support strategies.

I am very concerned about the process that is being used to rewrite the

description of Behavioral Services in the HCBS-DD waiver, and I am very

concerned about the content. The process must include a generous amount of time

for public input, and it must be announced so that people in services and their

family members, and advocates, have time to understand the proposed changes and

to have their input incorporated in the amended waiver language.

I am frankly alarmed at the proposed changes in that they greatly restrict the

types of behavior supports that will be available to people. There are now four

categories for people who can provide behavioral supports: Lead Therapist,

Senior Therapist, Behavior Plan Specialist, and Behavioral Line Staff. The

proposal is to collapse four categories into two: Lead Therapist and Behavioral

Line Staff. What is alarming is what is included in the definition of Lead

Therapist. This person must:

1. Have a doctoral degree with a specialty in psychiatry, medicine or clinical

psychology and be actively licensed by the state board of examiners, and have

1500 hours of direct experience in behavioral therapies that are consistent

with best practice and research on effectiveness for people with developmental

disabilities.

2. Have a Master's degree, or higher, in behavioral sciences and be nationally

certified as a " Board Certified Behavior Analyst " .

3. Have a Master's degree or higher in one of the behavior or health sciences

and licensed as a psychotherapy provider to provide individual and/or group

counseling.

4. Have a Baccalaureate degree, or higher, in behavioral sciences and be

nationally certified as a " Board Certified Associate Behavior

Analyst. "

Please note that " Board Certified Behavior Analyst " and " Board

Certified Associate Behavior Analyst " are trademarked, but this fact is

not noted in the draft amendment language. Those who become certified are

certified in only one approach – ABA (Applied Behavior Analysis). The

organization that provides these certifications is the Behavior Analyst

Certification Board, which includes the following notice on its documents:

" The trademarks " Behavior Analyst Certification Board, Inc., "

" BACB, " " Board Certified Behavior Analyst, "

" BCBA, " " Board Certified Assistant Behavior Analyst, "

" BCaBA, " " Board Certified Behavior Analyst-Doctoral " , and

" BCBA-D " are owned by the Behavior Analyst Certification Board. All

rights reserved. Copyright © 1998-2010 by BACB® All rights

reserved. "

By restricting the provision of behavioral services to Board Certified Behavior

Analysts the HCBS-DD waiver would prevent anyone from accessing people and

approaches that have worked for them, such as PBS (Positive Behavior Support),

RDI (Relational Development Intervention), and any other approaches and

interventions that are yet to be developed as we gain more knowledge through research

and implementation of best practices.

Follow the money! As important as understanding that only one, trademarked,

approach would be allowed is the understanding that there are people who stand

to make money from the proposed restriction of access to behavior services. Not

only does it cost money to become certified, there are businesses that contract

with CCB's in the metro area to provide these `certified' services. Go to the

link on the BACB website to find out who in the metro area is certified (http://www.bacb.com ), and you will find that

key staff and contractors in local CCBs are on the certification registry.

Another source of information on local efforts is at http://www.4caba.org/

If the language remains as I've seen it, in the proposed amendment to the

HCBS-DD waiver, the waiver would be a virtual funnel for the business of

providing behavioral services in this very restricted and exclusive `certified'

way of using just one very narrowly defined approach to applied behavioral

analysis.

We need to demand an open and public process that allows DDD to incorporate

public demands for more flexibility and choice for people to access behavior

supports that are individualized to people's needs and experiences.