DHS Proposes changes to EIDBI – Autism Therapy

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Alright – so, The Minnesota Department of Human Services (DHS) is proposing changes to amend the current early intensive developmental and behavior intervention (EIDBI). See what they are proposing and my public comments below.

Idil Abdull, Somali Autism Mom & Advocate

Submitted at 8am on June 3rd, 2022,

Comments for DHS’ proposed changes to EIDBI

Proposed changes

DHS is proposing to:

  1. Remove authorization requirements and limit on billing units for the individualized treatment plan (ITP):

This would allow providers to bill for this service as needed without authorization. Currently, the limit is 60 units to develop the ITP, with the option for providers to request an additional 30 units every six months. By removing the limit on how many units a provider can bill and the requirement to request authorization, the provider will have the flexibility to develop person-centered treatment plans and ample opportunity for progress monitoring updates. It also will ease the burden on families who transition to a new EIDBI provider agency and request an updated ITP.

My comment: First, I would like to state that I have requested the restrictions that were put on the ITP back in 2019 to be removed. DHS came back with incorrect information stating that it was CMS and not them who can do/request the changes. The idea that DHS is now asking what I have suggested years ago speaks volumes of how deaf tone the state Medicaid agency is to the needs of children with autism and their families. I want CMS to understand this and keep it in their mind. DHS does not listen to nor validate our needs, concerns, and suggestions until I usually have to complain to you at CMS. This should not be the case; the state Medicaid agency should be willing and open to suggestions from stakeholders. I respectfully ask CMS to always look at DHS’ changes to EIDBI with an extra eye and always ask them how they involved families, advocates, and providers. Do not assume what the state Medicaid agency is telling you is accurate, please verify with stakeholders.

2nd, I am confused about the wording in this change because it does not clarify what the end intent is. What I asked was to keep the 72 hours maximum we had before the 2019 code edits. Is DHS asking the same thing? Is there a limit to the initial ITP’s 60 units and 30 each six-month treatment plan?

  1. Eliminate the Technical change form, DHS-6516 (PDF):

Currently, providers submit the technical change form to DHS to request an adjustment to an existing, approved service agreement. By eliminating this step, providers would, instead, request all ITP updates or changes directly through the medical review agent.

My Comment: I did not initiate this change and I am ok with it. I support. However, please note, that DHS did not consult with families, advocates, and providers on this.

  1. To update the definition of “on-site” as it relates to high-intensity intervention (i.e., high staff ratio) services:

Currently, the QSP or Level I provider must be in the same physical location to meet the requirements of being “on-site.” DHS is proposing to update the definition of “on-site” to include that a QSP or Level I provider can be present and available via telehealth when appropriate to increase access to this essential service.

Note: A higher staff ratio is defined as two or more qualified EIDBI providers delivering the intervention to one person under the direction of an “on-site and available” qualified supervising professional (QSP) or Level I provider.

My Comment: This is fine, and I agree as it is sometimes difficult for the QSP to be present physically. Again, DHS did not consult with families, advocates, and stakeholders. They are always trying to shove down our throats their ideas without caring about how the people on the ground will be affected by their changes and rules.

The process to submit comments

Email comments to DSD.PublicComments@state.mn.us no later than 4 p.m. on Friday, June 3, 2022.

Additional input

In addition to the public comment period, DHS will consult with the EIDBI advisory group, providers, parents/guardians, and other interested parties before making these proposed changes.

Comment: I think DHS needs to do this before it suggests things. Talk with stakeholders, not at them, engage with us not dictate. Practice what you preach with action.


Idil Abdull, Somali Autism Mom and Advocate


The above words do not reflect any candidate, agency, or committee.

Idil – Autism Mom & Advocate

Category: Autism Policy