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BS License Mandate, Time to Inform Families
January 22, 2013

On January 15 the Children’s Committee reviewed feedback and reports from the Department of Public Welfare (DPW) regarding the mandate for providers of Behavior Specialist Consultant (BSC) services. DPW continues to take the position that “Act 62 calls for Behavior Specialists to be licensed within one year of the regulations being promulgated in order to bill either private insurance or Medial Assistance for the Behavior Specialist service. This means individuals working with children with Autism to ‘design, implement, or evaluate a behavior modification plan’ who desire to bill for the services should plan on becoming a licensed Behavior Specialist prior to May 26 2013.”

The committee reviewed a range of information that included:

  • A January 4 communication from the DPW Policy Director that stated the department would only accept a personal professional license, not a DPW mental health facility license.
  • An Office of Mental Health and Substance Abuse Services report which estimated that several thousand BSC staff would need to apply to the Medical Licensing Board for a personal Behavior Specialist license and to receive that license.
  • A January 2 report from the Board of Medicine that on that date 252 applications were pending, 8 licenses had been issued, and 20 of the pending applications had discrepancies and letters were sent to applicants. It was reported that the Board of Medicine has recruited staff and will bring to three the number of application processor staff.
  • A PCPA survey showing that the majority of BSC staff are working with strong agency support, but against significant barriers to submit BS license applications by March.
  • The PCPA survey also shows that 60 percent of BSCs are working to apply for professional licensure. For a range of reasons about 30 percent of current BSCs cannot or will not apply for a BS license by March.

PCPA and its members have worked to comply with DPW and avoid alarming families unnecessarily about the potential impact on them and their children. Based on the information now available and recognizing the ethical and professional obligations of professionals and provider agencies to consumers and families, it was strongly recommended that providers begin to immediately inform families of any possible changes in staff assignments or reductions service capacity related to the DPW mandate. Because DPW states that this mandate applies to both Medicaid and commercial insurance beneficiaries a broad notification may be indicated.

Each agency will need to assess the potential impact on staffing and service obligations and make notification decisions within their organizations. To assist members in communications, PCPA has prepared a model family notification letter. Provider organizations should edit, revise and use this letter only as a model and make agency and consumer-based decisions about when and how to notify families.

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