Our Advocacy
Ongoing advocacy on behalf of CASP members and the families they serve
CASP gives its 350+ member organizations a voice with federal and state policymakers. We advocate for policy reforms that strengthen the industry and help people with autism access high-quality, evidence-based care when and where they need it.
Federal advocacy
As a nonprofit trade association representing 300+ diverse organizations from across the nation, it is our mission to support our members by cultivating, sharing, and advocating for provider best practices in autism services.
On the federal level, CASP has retained an experienced bi-partisan lobbying team that is on the ground in Washington, D.C.
Our federal priorities include:
- The recognition and adoption of our clinical practice guidelines as generally accepted standards of care by TRICARE, the Department of Labor (DOL), and the Centers for Medicare and Medicaid Services (CMS).
- The recognition and adoption of the Autism Commission on Quality’s accreditation by CMS and DOL.
- The inclusion of autism service providers in relevant legislation and regulation.
Behavioral Health Information Technology Coordination Act (BHITCA)
The CASP lobbying team is advocating for the inclusion of behavior analysts in the Behavioral Health Information Technology Coordination Act and recently met with bill sponsors, Congresswoman Doris Matsui and Senator Markwayne Mullen. This would be the first mention of behavior analysts in federal statute if included. Read our BHITCA one-pager here.
National Academies of Science, Engineering, and Mathematics (NASEM) Independent Analysis of the Comprehensive Autism Care Demonstration Program
We are collaborating with advocacy organizations engaged in the National Academies of Science, Engineering, and Mathematics (NASEM) study of the TRICARE Autism Care Demonstration, including representatives from Autism Speaks and Mission Alpha Advocacy. The NASEM Committee next meets on January 12, 2024, and several members of the CASP Community are invited speakers. You can find the agenda and registration link here.
Mental Health Parity
CASP recently submitted public comment for the Proposed Rule: Requirements Related to the Mental Health Parity and Addiction Equity Act, which the Employee Benefits Security Administration posted in August 2023.
- The Proposed Rule sets forth amendments to regulations implementing the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA) and proposes new regulations implementing the nonquantitative treatment limitation (NQTL) comparative analyses requirements under MHPAEA, as amended by the Consolidated Appropriations Act, 2021 (CAA, 2021).
- Specifically, these proposed rules would amend the existing NQTL standard to prevent plans and issuers from using NQTLs to place greater limits on access to mental health and substance use disorder benefits as compared to medical/surgical benefits.
- Read CASP's public comments here.
State advocacy
CASP supports our member organizations' state advocacy efforts through access to:
- Member-led State Advocacy Groups (SAGs), each of which has a CASP-funded online platform for communication and resource sharing.
- Ongoing public policy updates.
- Ongoing advocacy trainings to empower SAG members. This includes trainings on the use of powerful advocacy tools, including CASP’s:
- Voter Voice Grassroots Messaging System.
- Bill Track 50 Bill-tracking Service
- Assistance in hiring state-level lobbyists (when member organizations pool funds to hire them.)
- Ongoing guidance on working with state lobbyists.
- A list of lobbyists and attorneys with relevant expertise.
Network adequacy
CASP is collaborating with the California Association for Behavior Analysis (CalABA) to ensure providers can continue to provide essential applied behavior analysis (ABA) services for people with autism.
Unfortunately, access to ABA services in California is increasingly under threat. Extremely low reimbursement rates have remained stagnant since the passage of the autism insurance law more than ten years ago. This, in combination with dramatically increasing provider costs (including wages, mileage, and overall inflation), has proved catastrophic.
While payers continually indicate that their networks are adequate, providers are experiencing substantial barriers to hiring under the current workforce conditions. As a result, many families are languishing on wait lists or are not accessing the hours prescribed as medically necessary. Rate negotiations in California have been a non-starter, with payers frequently closing networks or declining negotiations.
CASP, with support from Juniper, developed and analyzed publicly available network adequacy data for the Medi-Cal MCOs', identified existing legislation that had not yet been implemented, and collaborated with relevant California regulatory agencies. As the result of these activities, there is a clear path forward for publicly available, adequate and sustainable rates that serve as the floor by which rate negotiations occur with the MCOs. There is also the opportunity to establish consistent policies and expectations across the Medi-Cal ABA benefit.
The estimated timeline to complete this project is July, 2025. To ensure the success of this initiative, please consider a 2025 donation to the California Lobbyist Fund.
You can help by supporting our California Lobbyist Fund.
Caregiver and Community Advocacy
State legislators have the ability to address this crisis. They need to hear from constituents and understand the realities that they are facing.
Share your Story with your California Legislator Here
CASP and CalABA are working together to engage with California families to make sure they have the latest information about how to access care.
California Family Webinar Recording October 2023
California Family Webinar Slides October 2023
How Families Can Help (English)
How Families Can Help (Spanish)
Caregiver survey
Family engagement is instrumental in effecting change with the current barriers to accessing ABA services. Please distribute the caregiver survey found below to current clients and those contacting you for services.
Caregiver Survey in English
Survey en Español
Contact your regulators
It also is critical for regulators to hear directly from families about the difficulties they face when accessing ABA services.
To assist with this, CASP has provided information about how to contact regulators for both commercial and Medi-Cal plans. Please share the flyer with any families experiencing difficulties accessing services and ask them to take action.
Provider advocacy: rate and network capacity surveys
Accountability and transparency are essential to address this crisis. Because of this, CASP and CalABA have created two provider surveys. It is important that providers complete both surveys.
(Please note that survey data related to rates are confidential and will only be seen and aggregated by non-provider CASP staff.)
Please contact advocacy@casproviders.org with any questions.
Other state updates
Advocacy Related Resources
SAG leaders are developing resources to support autism service providers in a variety of ways, including addressing regulatory and legislative concerns related to:
- Network Adequacy & Access to Care
- Mental Health Parity
- Concurrent billing and code sets
- Location of services
- Credentialing
- Services across the lifespan
We are pleased to introduce the 50 State Applied Behavior Analysis Medicaid Comparison as the first of these resources.
To obtain a clean copy of this document, please complete this request form.
Read about CASP's recent advocacy in Oklahoma, Texas, California, New York, Hawaii, and Illinois.
Read CASP's response to the Massachusetts OIG report: MassHealth and Safety Net: 2024 Annual Report; MassHealth's Applied Behavior Analysis Program: Service Providers.
Questions? Please contact advocacy@casproviders.org.
