I would like to thank the members of the IACC for allowing me to offer testimony today. I am speaking to you as the Founder and President of Special Needs Network, as a civil rights attorney, and as the mother to a child with an autism diagnosis.

You are aware that federally qualified health centers are entitled to federal grant money and enhanced Medicaid payments for certain licensed providers. These supplemental payments make it financially feasible for clinics to operate in poor and historically underserved neighborhoods. But a critical community of providers is left out of the current legislative scheme that enables those supplemental payments—the behavioral health specialists who provide critical services and intervention for those with autism and other developmental disabilities.


For more than 16 years, Special Needs Network has been working to close the gap in services available to lower-income and BIPOC children with autism and other developmental disabilities. We provide direct services in the form of behavior health treatment through our clinics, paid at a rate that is 30- 40% of what a private health insurance carrier would receive for that same service. The legislation that allows for enhanced payments does not designate our Board Certified Patient Advocates (BCPAs) as eligible.

Although states don’t have a licensing process for behavior analysts, BCPAs are highly educated in their field; most have master’s degrees and many have PhDs. Their education and expertise allows them to conduct assessments of children with behavioral health issues, write treatment plans, provide direct intervention services, and even supervise other clinicians providing direct intervention services. However,  under current Medicaid provisions, these experts are not considered “qualified” when delivering services to someone who has Medicaid insurance.

This arrangement puts providers like Social Needs Network at an extreme disadvantage even as we deliver much needed behavioral health treatment to the most vulnerable patients in the communities we serve.  This reality is detrimental to our capacity to pay our clinicians, to expand our services, or simply operate at a level that is sustainable. The reality is preventing organizations from serving these vulnerable populations.

As we face a crisis point in being able to deliver services, Special Needs Network is requesting your help in communicating to the Office of Health and Human Services of the dire need to expand the definition of providers under Medicaid who are eligible to receive enhanced payment.

This change would make available a larger pool of providers to deliver behavioral health treatment to our nation’s most vulnerable patients—those at the intersection of disability, racial inequities, and poverty.

Today, 1 in 44 children are diagnosed with autism. That is a 244% increase over the year 2000. The data is clear that earlier intervention brings better outcomes and affords people greater opportunities to lead productive and fulfilling lives. Earlier intervention also benefits society as a whole: National Audit Office research indicates that supporting more people with high-functioning autism and Asperger syndrome quickly becomes cost neutral, and can potentially lead to long-term savings from higher tax incomes and reduced benefit payments as people are supported into employment. Such intervention also reduces mental health and criminal justice costs as people are supported before they reach a point of crisis.

There is precedent for the advocacy we are requesting. The Improving Access to Mental Health Act of 2021 proposes amending the current law that prevents clinicians from billing Medicaid for behavioral health care. If passed, the bill would allow clinicians to bill for 75% of a psychologist’s rate and would also increase the reimbursement rate for clinical social workers from 75% to 85% of the physician fee. If this bill is reintroduced in the new Congress, we see an opportunity to support the expansion or an amendment that would increase the reimbursement rate for those certified behavior analysts who provide behavioral health treatment.

This is about advancing equity and racial justice. The current scheme creates a dual system where the wealthy have access to more providers and services, while low income and poor people—particularly people of color—are receiving diagnosis, assessment, and intervention services two years later than their peers. Increasing provider payment rates for Medicaid will help improve provider participation and expand access to care for those who have, for too long, been left behind by an unjust system.