The updates to the Ontario Autism Program website include a few fast ones!
In reviewing any of the updates to the Ontario Autism Program (OAP) website, I like to perform a full site comparison to the previous version. Sounds crazy right? Well trust me, it’s the last thing I want to be doing. But my trust level is at an all-time low given the shenanigans coming out the ministry since the February 6 announcement. Trust is earned, and as of right now there is absolutely zero reason to put your trust behind the government on this file.
It’s always interesting to see the seemingly minor website edits aside from the major net new updates. Without a site compare, these minor changes would likely go unnoticed by most. What I find interesting is that some of these edits give you insight into the thinking going on within the government and their partners as they start to actually think through their “make it up as we go” policy.
In this article I’ll highlight the website edits that for me raised a Spock’s eyebrow, followed by a commentary on the net new program notes coming from the ministry.
First things first, let’s look at the not so minor edits.
From diagnosed to assessed
What’s up with this edit? Providing additional supports based on “diagnosed needs” insinuates that a professional, like a psychologist with autism credentials or a pediatrician with autism credentials, would have a say on the child’s needs. Changing it to “assessed needs” makes you wonder who exactly will assess the needs? Perhaps this is just a wordsmithing refinement, but it raised an eyebrow as the government has not been transparent on how they will assess needs.
Maybe this change was just made to give the government flexibility as they enter the consultation phase of addressing the “more complex needs”, however as many speculate, they may have already determined how they’re going to do this, and the consultations are just a public relations move.
From receiving to being eligible
Someone felt the need to change “will” to “are eligible”. Are eligible? Well, eligibility is not well defined on the OAP website. I presume they added this to mean that you must register for the OAP to be eligible, whereas the previous statement said that youth with a diagnosis of autism will receive the Childhood Budget. I hope that’s all this is.
Did I mention my trust level is low?
Wiping the April 1 reference
Ummm yeah. No one believed that anyone would get a Childhood Budget on April 1. Glad you guys caught this one and made the change to the month of April 2019 as you figure out how the heck you’re going to get this program going.
In all seriousness though, the government loses all credibility when they say the new program started April 1. Why try to pull the wool over our eyes with this claim? It’s embarrassing. When a program starts, program details are publicly readily availability, people can register, and services are ready to go. None of this was true April 1. April Fools Day indeed. The only reason the government says the program started April 1 is because this is when their fiscal year starts. Here’s the thing, the public does not care about the government’s internal fiscal year policies! The program is ready when the program is ready. It’s not ready for prime-time, so don’t press the start button!
Lowering the public’s expectations
OK, this one is funny. You can see the internal folks in the ministry pushing back on playing a “key role in supporting families”. Who approved saying we’ll play a key role? We need to set reasonable expectations here and just say we’ll support families because we all know darn-well we’re not playing a key role in supporting families; we’re just doling out the Childhood Budgets.
Data privacy concerns
While the element of an independent intake agency is not new, it also hits on the element of data privacy again. Currently your data is with a regional provider, yet the ministry is taking this role during the time it takes to set up an independent intake agency over the next year. So presumably your data will need to be passed to the ministry, only to eventually be passed over to the independent intake agency. While I’d like to be able to trust that my child’s personal data can be handled well between a government funded regional, to the ministry’s Central Intake and Registration Team, and then to an independent agency, I would feel a lot better if they’d just be transparent on this process. This is protected confidential data we’re talking about here.
Did I mention that my trust level is low?
Lowering the expectations of Autism Ontario
Again, with the “key role” changes. You can only imagine Autism Ontario pushing back on the expectations. To be fair, the ministry had misstated Autism Ontario’s role right from the get-go, so no surprise they’re looking to protect themselves from being blindsided by the ministry again.
From verified and qualified providers to experienced and trained
The original could be read as if the service providers themselves would have their qualification verified. The revised version makes it clear that the government will only verify clinical supervisors and that they have up until April 1, 2021 to validate their qualifications.
Now onto the net new changes.
The waitlist formula
Don’t expect to get the details on this formula. Someone in the ministry, perhaps the same KPMG consultant that came up with original income tested Childhood Budget plan, has come up with a detailed formula based on OAP children’s ages, their childhood budget amounts, and evaluates the costs against the OAP budget which would then give an indication as to when they could take someone off the waitlist. This is likely why you’ll receive your Childhood Budget “within the next 18 months”. They know there will be a certain amount that turn 6 and move down to $5k, and another amount that turn 18 and age out of the OAP, plus they’ve planned for net new registrations into the OAP, or you’d at least hope they have.
Ministry letters and waitlist questions
No surprise here, the ministry has indicated that the regional providers would no longer administer communications to families. Yet, since adding this to the OAP site, families continue to receive updates from their regional providers about the OAP changes and their place on the waitlist. The question is what waitlist? The OAP waitlists for ABA therapy were region based. What has happened to the waitlist? Is there any regional element to the waitlist anymore? There really shouldn’t be given the new OAP is a financial supplement rather than regional based services. So, is there a master Ontario OAP waitlist, or a so-called list of the lists? If so, I go back to my previous question of what information has been provided to the ministry on your file from the regional providers, and is there a data privacy breach at play here?
The return of evidence-based behavioural services, but where’s the regulation?
Evidence-based services has made it back into the OAP. OK great, so the OAP is still onboard with ABA which is important because every single person who was registered in the OAP was either receiving or waiting for ABA. This was the only service available in the OAP until the changes on April 1. Understandably there are many that want choice, which is totally fine, however you weren’t registered in the OAP for anything other than ABA. So now, if you want to access ABA with your Childhood Budget an OAP Clinical Supervisor must oversee the services. A list of OAP Clinical Supervisor’s will be administered by Autism Ontario.
OAP Clinical Supervisor’s have 2 years to get themselves qualified by April 1, 2021. They must have one of these designations:
· Board Certified Behavior Analyst (BCBA)
· Board Certified Behavior Analyst — Doctoral (BCBA-D)
· Clinical Psychologist or Psychological Associate registered with the College of Psychologists of Ontario (CPO) with documented expertise in Applied Behaviour Analysis (ABA)
They must also have:
· At least 3,000 hours post-certification/registration experience
· A Vulnerable Sector Check
· Professional liability insurance
· Adherence to a professional code of conduct
This is great, we all want regulation of ABA, but this falls way short of regulation.
Which begs the question, what the heck is going on with the Ministry of Health’s review of the various Colleges in order to bring in regulation to the ABA industry?
I think a follow-up question to Minister’s MacLeod and Elliott from Citytv’s Cynthia Mulligan may be in order here. On February 6th Mulligan asked Minister MacLeod about regulation.
Watch below for what she said:
Here’s the transcript:
We are regulating the profession. We are working with the Ministry of Health right now in order to bring those regulations forward. So right now the Ministry of Health is undergoing a review of many of the Colleges, but this is certainly one of our key components.
To be clear here, the OAP Clinical Supervisor requirements DO NOT equate to the regulation statement made by Minister MacLeod.
Removing reference to certification
Why take this out? May be related again to wanting to distance themselves from fulfilling Minister MacLeod’s assertion that the Ministry of Health was going to regulate ABA. Why else remove this line?
Unregulated Behavioural Services
To make matters worse, the new OAP allows for completely unregulated behavioural services that are not evidence based. It’s really something else. Here’s an example of such services that I guess anyone can do without verification of qualifications:
As Gina Green, a very well respected U.S. based behaviour analyst notes from the ONTABA Facebook page:
if an intervention, curriculum, model, or program really is based on the principles of behavior analysis, it follows that to be implemented safely and effectively it should be designed and overseen by a professional who has met empirically and legally validated standards for formal and experiential training in those principles and their applications, and has demonstrated knowledge by passing an objective professional exam in behavior analysis.
To cover themselves, the government says this:
The government might as well say to families, we realize there may be bad actors out there swindling you of your OAP Childhood Budgets, but that’s on you, not us! Buyer beware!
Duplicate respite services to SSAH
The respite services section is interesting as it includes things “like community recreational activities and classes, cultural activities and camp programs that promote independence and support the development of social, communication and life skills. This includes sports activities, arts and music programs, museums, camps, and autism specific programs.”
It’s no wonder so many fear that the Special Services at Home (SSAH) benefits may be altered for those with autism as everything on this list is covered by SSAH!
Administrative fees
Not comfortable managing your child’s childhood budget? No problem. You can use 10% of your Childhood Budget to hire someone for administrating your plan.
Can you imagine blowing $2,000 of your child’s $20,000 Childhood Budget on having someone plan and administer your child’s OAP Childhood Budget? I can’t, however I can appreciate that some need help with this. Here’s what the ministry says the 10% can be used for:
planning and coordinating services for their child, delegating budget management responsibilities, and managing administrative supports specifically related to the Childhood Budget such as bookkeeping, bank fees, payroll and scheduling.
These are downloaded responsibilities that used to be covered by the ABA service providers under the previous OAP whether direct service or direct funding. One reason the government may have added this is for those in rural areas that need to employ people rather than pay for a service. Although possible, I find it strange. You’d think a professional would offer a service, and then you pay for the service, there’s no employer/employee relationship for obtaining services.
Maxing out your Childhood Budget with travel and the latest iPhone
Not sure if your child will go through their entire Childhood Budget? Well, get yourself a travel journal and start keeping track of your to and from travel for services, as you may be able to max out that Childhood Budget after all!
Don’t want to track your travel? Well, you can also max out your Childhood Budget with a computer, laptop, tablet or smart phone. Your child is eligible for a device upgrade every two years! No cost limits here folks, so feel free to line up outside of the Apple store for the launch of their new iPhone and pass the receipt onto the OAP. The government does recommend that families consult with a professional about what device is best suited for your child. Right … thanks for the recommendation!
Autism Ontario as a Service Navigator
The site updates end with a large list of ineligible expenses, followed by details on Autism Ontario’s role as a service navigator. There’s also a link to Autism Ontario’s Autism Program Provider List, which upon clicking you’ll find a link for providers to register, but no actual listed providers.
So, there you have it folks, more half-baked updates from the ministry, mixed with a bunch of cover your butt edits for a policy they’re making up as they go! Trust is earned. Unfortunately, the more this government reveals new program details and changes past stances, the more we distrust!
