FABA Legislative and Public Policy Committee

Eric Pruttsman - Lobbyist & Legal Council - Email Eric

Yulema Cruz – Co-Chair – Email Yulema

Mary Riordan, PhD – Co-Chair – Email Mary

Political Action Committee Email - Email the Committee


AHCA Announces New Proposed Changes to Florida Medicaid Behavior Analysis

The Agency for Health Care Administration (AHCA) hosted a packed meeting in Tallahassee on March 29, 2019, to announce updates regarding the delivery of Florida Medicaid Behavior Analysis services. The meeting featured a presentation by representatives from the Agency where they announced a number of updates, which are summarized below. 

A number of these updates may be positive developments that will hopefully increase access to service and efficiency in the near future. However, the proposed rate reductions are concerning and have the potential to dramatically limit quality providers’ ability to render service. The most effective way to put a stop to these proposed changes is by reaching out to your lawmakers and asking them to STOP THE CUTS. You can seamlessly email and call them NOW using the FABA Action Center.

Here is a summary of the updates that were announced:

Changes to Reimbursement Rates
AHCA believes the current rates are significantly higher than is necessary to ensure access to the service statewide, especially when examining the actual wages earned by professionals providing the service. AHCA is working to realign provider reimbursement rates with a revised methodology. 

The proposed changes in the rates include:

  • The rates for a Behavior Analysis Assessment will decrease from $385.19 to $301.31
  • The rates for a Behavior Analysis Reassessment will decrease from $192.59 to $150.65
  • The rates for a Behavior Analysis Lead, per quarter hour, will remain the same at $19.05
  • The rates for a Behavior Analysis Assistant, per quarter hour, will decrease from $15.24 to $10.52
  • The rates for a Behavior Analysis Registered Behavior Technician, per quarter hour, are decreasing from $12.19 to $5.98

Provider Enrollment Moratorium
AHCA is seeking to partially lift the moratorium in Miami-Dade and Broward counties. This will include registered behavior technicians, lead analysts, and board certified assistant behavior analysts seeking enrollment to participate as a member of a provider group that is already enrolled in Florida Medicaid. However, the moratorium will remain in effect for new group providers and lead analysts wishing to practice independently. The goal is for this to take place at the end of April. AHCA will host provider enrollment trainings in late April and early May.

Health Care Clinic License
Provider groups will be required to prove that they have a health care clinic license by December 31, 2019 or provide a copy of the certificate of exemption. This requirement is not new, but stronger verification procedures will be implemented. 

Multidisciplinary Team Approach
In an attempt to streamline the delivery of medically necessary services, AHCA will be implementing a Multidisciplinary Team (MDT) approach. The MDT approach includes telephone or home visit contacts with parents, medical documentation review by clinicians from two separate disciplines, and a team meeting that can include the provider.

Coverage Policy Revisions
The behavior analysis coverage policy will be combined into one policy with other Medicaid-covered behavior modification and intervention services. However, the Agency did not address one of FABA’s top priorities regarding a requirement that treatment programs be administered by a lead analyst who is a Board Certified Behavior Analyst.

Electronic Visit Verification
The Agency is working on implementing an Electronic Visit Verification (EVV) requirement. The EVV policy will require providers to check in and check out using an app on a mobile phone. This will link the provider check in with a claim submission and ensures submitted claims information is valid and aligns with prior authorization information.

This is the first of a series of meetings that will be held across the state. Over the next month and a half, additional meetings will be held at the following locations:

  • Tampa
    Friday, April 5 at 10:30am
  • Orlando
    Thursday, April 18 at 10:30am
  • Jacksonville
    Friday, April 19 at 10:30am
  • Miami
    Thursday, April 25 at 10:30am
  • Ft. Lauderdale
    Friday, April 26 at 10:30am
  • Pensacola
    Friday, May 10 at 10:30am

It’s important to note that none of these changes are finalized right now, so it is critical that FABA members do everything possible to attend these meetings and provide feedback and public testimony. We also need as many providers and parents as possible to email their lawmakers and the governor using the FABA Action Center.