Office of Public Affairs 1425 K Street, N.W. Suite 200 Washington, DC 20005 202.347.3066 phone 202.347.7385 tty 202.737.7914 fax www.easterseals.com
September 30, 2013 The Honorable Chuck Hagel Secretary United States Department of Defense 1000 Defense Pentagon Washington, DC 20301-1000 Dear Secretary Hagel: Easter Seals writes today regarding Section 735 of the 2013 National Defense Authorization Act. We understand that the Department of Defense is now collecting input on the TRICARE program with the goal of ensuring that dependent children of members of the armed services can access appropriate health services. Easter Seals is the leading non-profit provider of services for individuals with autism, developmental disabilities, physical and mental disabilities. As the Department considers modifications to the TRICARE program, Easter Seals asks you to consider the following recommendations:
TRICARE should adopt a specific definition of medical necessity that applies only to children and that is consistent with guidelines established by the American Academy of Pediatrics (AAP).
TRICARE must ensure that children of military service personnel can access primary care providers and specialists in a timely fashion and regardless of national shortages and regional concentrations. Children should not be required to travel great distances to obtain health care services for illness or to access habilitation or other services to address a chronic health condition or disability. TRICARE must not promote or maintain inflexible policies and authorization hurdles, such as being seen on base first or a distance limit.
TRICARE must adopt policies that ensure access to appropriate and high quality early identification and intervention services for all young children, especially those with disabilities or at risk for developmental delay.

Applied Behavioral Analysis (ABA Therapy), consistent with the AAP definition of medical necessity, should be provided as a medical benefit to all TRICARE beneficiaries. Such services must not be limited to children with a specific diagnosis. .
The design and structure of the TRICARE program can have major impact on children with special health care needs and their families. Barriers to early screenings, interventions, and supportive care hinder the optimal development of young children with developmental delays and disabilities. As a result, these children are at increased risk for later school failure and challenges in adulthood. Thank you for considering our views. Sincerely,
Katherine Beh Neas Senior Vice President, Government Relations
2