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IBHS Clarification Regarding 1:1 ABA Services and Group from OMHSAS

Date: January 05, 2021

Good Afternoon OMHSAS Stakeholders,

The Pennsylvania Department of Human Services (DHS) Office of Mental Health and Substance Abuse (OMHSAS) is committed to ensuring children, youth and young adults receive appropriate behavioral health services to meet their individual needs and do so in settings that provide the best opportunity for accomplishing their documented treatment goals.

OMHSAS has been contacted by some families and service providers about the      availability of 1:1 center-based Applied Behavior Analysis (ABA)
provided by a licensed Intensive Behavioral Health Services (IBHS) agency and
Medical Assistance payment for these services.

The IBHS regulations and OMHSAS guidance allow Medical Assistance payment
when group services are provided in a center-based community-like setting. 

Group services may include individual interventions that address the therapeutic needs of the child, youth, or young adult. 

As a result, payment for 1:1 ABA services that are provided as a component of group services is allowed pursuant to the IBHS regulations. 

OMHSAS expects that most center-based services are provided as part of group services,
as many of the comments that we received emphasized the importance of children developing group learning skills and interacting with peers.

In addition, when it is determined to be medically necessary and clinically appropriate, Medical Assistance will pay for ABA services provided in a community like a center-based setting. 
OMHSAS will release guidance on when it would be appropriate for a child, youth, or young adults to receive 1:1 ABA services in a center-based setting in the near future.  

There also seems to be a concern that the IBHS regulations prevent 1:1 center-based services even if Medical Assistance will not be paying for the services.  

The IBHS regulations do not address payment by commercial insurance
for 1:1 center-based services
and licensed IBHS agencies may continue to provide these services and bill commercial insurance

We appreciate the concern raised by families and providers who have communicated with our office and recognize that changes to program regulations and design can create uncertainty about continuity of care. 

The changes our office is implementing are designed to ensure that services are meeting minimum licensing standards, provided by qualified staff, and have regular oversight to ensure the wellbeing and safety of the children and youth we serve.


Kristen Houser, MPA | Deputy Secretary

Department of Human Services | Office of Mental Health and Substance Abuse Services

P.O. Box 2675 | Commonwealth Towers | 11th Floor | Harrisburg, PA 17105-2675