July 4, 2013
Dear Military Families,
On June 25th, TRICARE issued new policy guidance addressing how Applied Behavioral Analysis (ABA) will be provided to the military children of our active duty and retiree families. Advocates across the military family arena are shocked and dismayed at the language this new policy contains as much of it is arbitrary and capricious. Our expectation is that many military families and their children will have their therapy either curtailed significantly or lose this much needed therapy entirely. The following is our assessment of this new policy and our initial areas of concern. Simply put, because of TRICARE’s failure to work with military families and the organizations that represent them, our assessment at this time is preliminary….there are simply too many unanswered questions. We think it is critical to ensure you know about this new policy now and have an opportunity to understand how this policy change might impact your family. We have tried to keep these points as easy to understand and communicate to others as possible. We expect a more thorough analysis from Autism Speaks and other groups in the near future and will continue to keep you informed as we know more. •
ALL military families (both active duty and retirees) must be referred via a TRICARE-authorized provider for ABA services. All authorization will go thru TRICARE BASIC (medical side) first, which covers the assessment for eligibility for services, plus then treatment program design, supervision of the ABA program and parent training, if approved.
In order to qualify for ABA services, child MUST have an Autism Spectrum Disorder as defined by the DSM-IV. This includes Autism, PDD-NOS, Aspergers and the other disorders under the Autism Spectrum. The diagnosis can be made by a child’s primary care physician, pediatrician or a specialist provider such as a developmental pediatrician. There is a note that the policy will be updated at a later date to reflect the DSM-5, which was recently released.
The initial ABA assessment must include Autism Diagnosis Observations Scale (ADOS-2) and Vineland Behavioral Scale II (VBS-II) test batteries. (Policy does not state if TRICARE will cover the costs of these tests however). Results of these tests must be included in assessment.
The psychometric testing referenced above must be repeated EVERY SIX MONTHS to assess the progress of your child. You can lose your ABA services if your child does not show measurable progress. For some of our children, simply ‘not regressing’ is considered progress, but will that count when it comes to reauthorizations? Also, not considered is the effect of PCSing, which often results in regression. Additionally, we have questions regarding children that have extreme behaviors (i.e. SIBs, destructiveness, aggression) or other co-morbid conditions or special needs that make testing difficult or impossible.
These tests can be administered by your ABA provider (some have licensed psychologists or other qualified persons on staff), or if they are not qualified to administer them, by another authorized Tricare provider. There is no mention of what provision there is if there are problems finding qualified providers or for long wait lists for a qualified provider. We are extremely concerned that this alone could delay therapy authorizations for many families.
If you’re stationed overseas, ABA can only be provided by either a BCBA or BCBA-D, regardless of what program you use. If you live in a location where your host nation has no BCBAs or BCBA-Ds, there is NO benefit available for your family.
The policy limits the usage of ABA therapy to no more than two years, but is authorized a year at a time. If your child still shows the need for ABA therapy after two years, you can request an exception to policy waiver, but there is no guidance provided as to criteria for waiver approval.
Skills gained via therapy must be generalizable between settings and durable over time for continuation of ABA therapy.
ABA is available for beneficiaries aged 18 months to 16 years. We are unsure as to why Tricare has chosen these age limits.
Family members/caregivers must participate during ABA sessions. Your ABA providers will be training you to implement and reinforce skills and behaviors. In fact, the parents/caregivers will be “graded” as the ABA provider must submit an annual report of how well you are consistently able to implement the interventions at home. If cannot do this, you can lose your ABA services, is this qualifies for discharge criteria.
If your current ABA Supervisor is a BCaBA, they can no longer supervise ABA tutors. All ABA therapy must be supervised by a Master’s Degree level BCBA or Doctorate level BCBA-D. But, BCaBA-level supervisors can be tutors now. At a reduced rate, of course.
We do not know whether this policy will affect all children immediately from July 25th or whether in place authorizations will be honored. We just want to keep you informed and educated about TRICARE decisions and are available for any of your questions and comments.
American Military Families Autism Support & Military Special Needs Network