During new-business discussion March 12, advisory committee members raised concerns about the role of targeted case managers (TCMs) in developing behavior support plans for individuals with developmental disabilities and Medicaid waivers.

Committee members reported seeing instances where TCMs or agencies produced behavior-support documents without behavioral training, and they questioned whether that practice aligns with the intent of Kansas licensure law governing behavior-analytic services. One committee member said the industry has observed that many TCMs prepare person-centered support plans that include behavior-management language but lack function-based assessments, replacement behaviors and other elements behavior analysts expect in a function-based behavior intervention plan.

The committee discussed differences between "title protection" (who may call themselves a licensed behavior analyst) and "practice protection" (what acts are restricted to licensed professionals). Members noted that the state law that created autism insurance coverage and the early licensure rules were historically shaped by stakeholders present at the time and that some roles (such as TCMs) were not represented in those hearings.

Executive Director David Fye confirmed the board's limited ability to introduce legislation directly; the board must work with legislators to obtain an RS (reviser of statutes) number and meet committee deadlines. He said the board had previously coordinated with Representative Will Carpenter and other legislative contacts to shepherd bill drafts, and he encouraged building relationships with members of the House Health and Human Services Committee and the Senate Public Health and Welfare Committee in advance of next year's session.

Committee members agreed the issue has implications for consumer protection and for consistency of behavior interventions used with people with intellectual and developmental disabilities. Some said they will pursue off-agenda, non-board advocacy (as private citizens or members of external professional groups) to clarify how behavior-support planning should be coordinated between TCMs and licensed behavior-analytic providers.

Why it matters: If untrained workers are authoring behavior plans without behavioral oversight, consumers may receive interventions that are not function-based or that use inappropriate procedures. Committee members discussed potential next steps including targeted outreach to KDADS (Kansas Department for Aging and Disability Services), possible educational materials, or rule changes clarifying who may develop and implement function-based behavior intervention plans.

Ending: Members asked staff to add the TCM topic to a future agenda for focused discussion and to consider how the advisory committee's work plan can address supervision, scope and interagency coordination.