BHCOE has been actively working on behalf of Florida providers to encourage ACHA to change the existing H codes to the newly AMA adopted CPT 9 codes. Our latest meeting with ACHA Chief of Staff, Cody Farrill was very positive, and the state has given strong indication that they would like to make this change. We will keep everyone updated as this initiative progresses forward. 

BHCOE CEO Sara Gershfeld Litvak and VP of Government Relations Anna Bullard recently met with Texas HHSC regarding the concerns related to access to care for children with autism due to the feedback from our accredited providers related to the rates. We provided information that will hopefully continue to encourage state leaders along with the many other organizations to consider the opportunity to focus on the quality of the services for Medicaid beneficiaries and how to ensure equal access to those individuals. 

There are two licensure bills that have had movement in the last month prior to the 2022 legislative session beginning that BHCOE has been following. 

Pennsylvania advocates and professionals have begun the uphill battle of getting a BCBA licensure bill filed that would carve out BCBAs from the existing License Behavior Specialist (LBS). In Georgia, HB 412 which would create a license for Board Certified Behavior Analyst is currently under review with the Governor’s Occupational Regulatory Review Council. 

Oregon SB 358 was signed by the governor on July 27, 2021. This prevented the sunset of the autism mandate by extending the requirement that the health benefit plan provide coverage for treatment of autism spectrum disorder provided by ABA professionals to January 2, 2030. 

The Oklahoma Department of Insurance issued a bulletin stating that Oklahoma insurance companies have been applying treatment and dollar amount limitations for ABA that violate Mental Health Parity Law and 36 O.S. § 6060.11. The Department of Insurance also advises that the existing limitation under the current statute 36 O.S.§ 6060.21(E) conflict with 36 O.S. § 6060.11 and the federal statutes and regulations governing MHPAEA. The department has recommended that carriers that cover ABA be in compliance no later than December 31, 2021.

If you have any additional information on licensure or legislation that you would like us to support or share in our newsletter please contact Anna Bullard at

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