The public comment period for HFS’ proposed rules for ABA therapy is coming to a close. There is still time to submit public comments through this coming Monday, February 27th. The proposed HFS rules for ABA can be found on pages 315-316 and 337-343 in Volume 47, Issue 2 of the Illinois Register. HFS’ umbrella service of Adaptive Behavior Support services includes two distinct services: ABA therapy and Developmental Interventions.
Illinois Autism Insurance Coalition 
ABA – the language would not allow Easterseals to participate since the majority of our clients are in clinic. We would also need clarification of the term “independent enrollment.” As the current language stands, Easterseals would not be able to serve ABA families outside of their home/community setting, which is not in the best interest of our families.
Public Act 102-0953 requires the licensure of BCBAs to provide diagnosis and services to children with Autism Spectrum Disorder in order for reimbursement by Medicaid. The current language opens the door for SLP’s and OTs to also provide ABA services. This language appears to contradict PA 102-0953.
Lastly, Therapy Changes would require Physician Review every 90 days; removing authorization requirements for Speech Therapy services but require Prior Authorization for PT/Ot. This would mean that we would need to have a physician sign off on progress notes for Medicaid clients every 90 days, adding administrative burden and increase the number of documents we are shuffling back and forth.
We respectfully request that the above issues be addressed when the language is re-written after public comments.
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