Applied Behavior Analysis (ABA) State Mandates
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Summarizes state-specific legislative and regulatory requirements for coverage, provider qualifications, diagnostic requirements, service limits, and delivery settings for Applied Behavior Analysis (ABA) services that affect Optum members and providers.
Interim reviews and updates occurred on 07/22/2025, 11/18/2025, 12/16/2025, and 07/21/2026 reflecting new and updated state mandate content.
State Coverage Criteria and Mandates
inv-02: Massachusetts EI limits and supervision
Massachusetts Early Intervention limits and supervision
Supervision of paraprofessionals during home visits may require supervisor and direct service provider to be present at the same time.
inv-03: Kansas Medicaid criteria and treatment rules
Kansas Medicaid eligibility, diagnostics, treatment, and exclusions
Allowed provider types include psychologists, family practitioners, general practitioners, neurologists, psychiatrists, general pediatricians, exempt license physicians, Indian Health Services, and qualified physicians with documented ASD diagnostic training; documentation of additional training may be audited.
A validated ASD diagnostic assessment tool (ADOS or CARS) is required.
Prior authorization required and will be reviewed after submission of all requested documentation; medical necessity is determined case-by-case.
inv-04: Kentucky coverage and treatment plan requirements
Kentucky commercial member coverage and review rules
Insurer may request utilization review not more than once every 12 months (unless agreed otherwise); providers must furnish records substantiating medical necessity and improved clinical status upon insurer request.
inv-05: State access and referral rules (New Jersey and New York)
New Jersey and New York access and referral requirements
Acceptable QHPs include physicians, psychologists trained/certified in behavior analysis, and BCBAs for treatment planning.
MMC enrollees should contact their MMC plan for coverage/billing guidance.
inv-06: State-specific mandate provisions (excerpt) — who may provide, telehealth availability, age limits, definitions
State mandate excerpts in this section summarize who may provide, telehealth availability, age limits, and definitions where specified.
Expands who may provide diagnostic and treatment services under Ohio commercial mandates.
Telehealth allowed; non-enrolled providers may need single case agreement and prior authorization.
Mandated coverage for <21 and supervisory allowance.
Definition and medical necessity language applicable to Virginia fully‑insured plans.
ABA services (CCTS/IIS) are explicitly not authorized when the claimed purpose is one of the program exclusions listed in state rules. Examples include provision for speech therapy, occupational therapy, vocational rehabilitation, supportive respite care, recreational therapy, orientation and mobility, services provided in a PRTF/hospital setting, or when the services are duplicated through another source or setting.
Services delivered under an Individualized Education Program (IEP) or obligations imposed on a public school by the Individuals with Disabilities Education Act (IDEA) are not authorized as covered ABA services; however, the policy specifies that ABA is not denied solely because the child's school is identified as the location of services.
None explicit in this excerpt.
Program exclusions that will prevent authorization repeat the non-authorization list: ABA services will not be authorized for speech therapy, occupational therapy, vocational rehabilitation, supportive respite care, recreational therapy, orientation and mobility, services provided in a PRTF/hospital setting, or where services are duplicated by another source/setting. Additionally, services provided under an IEP or required of a public school under IDEA are not authorized as covered ABA services (though school location of services is not a basis for denial).
Within the chunks reviewed there are no explicit statements
Prior Authorization, Documentation, and Billing Actions
Kansas Medicaid prior authorization required for CCTS/IIS
For Kansas Medicaid CCTS and IIS (ABA) services, prior authorization is required and will be reviewed after all requested documentation has been submitted; medical necessity is determined on a case-by-case basis.
- Applies to Consultative Clinical and Therapeutic Services (CCTS) and Intensive Individual Support Services (IIS).
- Submit all requested documentation to initiate prior authorization review.
Ohio Medicaid: secure single case agreement if not enrolled
If an Ohio Medicaid ABA provider is not enrolled with Medicaid, obtain a single case agreement before providing services; review Ohio Administrative Code for eligible practitioner lists and any applicable prior authorization requirements.
- Single case agreement required when provider is not enrolled with Ohio Medicaid.
- Follow Ohio Administrative Code for prior authorization rules and eligible practitioner lists.
Ohio Medicaid prior authorization / single case agreement requirement
Ohio Medicaid may require prior authorization and/or a single case agreement for providers not enrolled with Medicaid; verify enrollment status and secure required authorizations per Ohio Administrative Code prior to delivering ABA services.
- Confirm provider enrollment with Ohio Medicaid.
- If not enrolled, arrange single case agreement and any applicable prior authorization.
Utilization review may be requested no more than every 12 months
Insurers may request utilization review of autism treatment not more than once every 12 months (unless a more frequent review is mutually agreed), which may affect continued authorization and require provider submission of supporting records.
- Insurer bears cost of obtaining any review.
- Providers must furnish medical records, clinical notes, or other necessary data upon request to substantiate medical necessity and improved clinical status.
Provide detailed treatment plan and clinical documentation on request
Required clinical documentation and treatment plan elements must be provided upon insurer request to support initiation and continued ABA services, including diagnosis, treatment goals, and measures of progress.
- Treatment plan should include diagnosis, proposed treatment type/frequency/duration, anticipated outcomes/goals, and update frequency.
- Goals must be specific, directly observed, continually measured, and address ASD characteristics.
- For referrals (e.g., NY Medicaid) include patient age, diagnosis, date of initial diagnosis, co-morbid diagnoses, symptom severity/level of support, statement of need for ABA, and DSM-5 diagnostic checklist when applicable.
Kansas: document diagnosis with validated tools and qualified diagnostician
Kansas requires diagnostic documentation by a qualified Kansas BSRB clinical psychologist or qualified physician using a comprehensive diagnostic evaluation and a validated ASD diagnostic assessment tool (e.g., ADOS or CARS); documentation of additional ASD diagnostic training may be subject to Optum audit.
- Member must be age 20 or under for Kansas Medicaid eligibility.
- Recommended diagnostic components include cognitive evaluation (e.g., CAT/CLAMS, MSEL, BSID) and an adaptive behavior measure (e.g., ABAS or VABS).
- Once diagnosed per policy, re-evaluation is not required and there is no time limit to start treatment.
Ohio Medicaid telehealth: verify enrollment and authorization requirements
When providing ABA to Ohio Medicaid members via telehealth, follow Ohio Medicaid telehealth guidance and ensure provider enrollment or a single case agreement is in place; verify and comply with any applicable prior authorization requirements.
- ABA is available through telehealth under current Ohio Medicaid guidelines.
- If provider is not enrolled with Medicaid, a single case agreement would be needed.
Do not authorize ABA for specified excluded program purposes or duplicate services
Do not seek authorization for ABA services when the claimed purpose is an excluded program purpose (speech therapy, occupational therapy, vocational rehabilitation, supportive respite, recreational therapy, orientation and mobility), when services are provided in a PRTF/hospital setting, or when services duplicate those already provided in another setting.
- Services specifically listed as non-authorizable include: speech therapy; occupational therapy; vocational rehabilitation; supportive respite care; recreational therapy; orientation and mobility.
- Services provided in a PRTF/hospital setting or duplicated by another source/setting will not be authorized.
Authorize additional hours beyond mandate only with medical necessity
Additional ABA hours beyond state-mandated weekly limits (e.g., Maryland mandates up to 25 hrs/wk for ages 18 months–5 years and up to 10 hrs/wk for ages 6–18 years) will only be authorized if determined medically necessary and appropriate; Optum will review requests for additional treatment using medical necessity guidelines.
- Maryland: services meeting initiation/continuation criteria will not be denied solely on number of hours up to the specified amounts; additional hours require medical necessity determination.
- After exhausting mandated benefits, Optum reviews additional treatment requests under its standard medical necessity policy.
Risk of denial if Ohio Medicaid provider enrollment or single case agreement not in place
If a provider is not enrolled with Ohio Medicaid, lack of enrollment may trigger denial risk unless a single case agreement is executed and any required prior authorization is obtained; verify enrollment status before billing or providing services.
- Single case agreement is required for non-enrolled providers to deliver ABA to Ohio Medicaid members.
- Failure to secure required agreements/authorizations may risk denial of payment.
Service Settings and Levels of Care
inv-27: Outpatient / early intervention / Medicaid service settings
Outpatient, early intervention, and Medicaid service settings and utilization rules
Prior authorization required in some Medicaid programs and will be reviewed after submission of requested documentation.
ABA Service Rules, Supervision, and Limits
inv-28: Supervision and hour limits — state-specified ABA service rules and supervision requirements
State-specified ABA service rules and supervision requirements
Supervision during home visits may require supervisor and direct service provider to be present simultaneously.
After mandated hours, Optum will review additional requests using medical necessity guidelines.
ABA services will not be authorized for specified excluded purposes (e.g., speech therapy, OT) or when duplicated by other sources/ settings.
inv-29: ABA supervision and coverage notes (1 top-level node)
This impacts who may act as a supervisor under PA rules.
Covered Treatment Modalities
inv-30: ABA for Down syndrome
Down syndrome defined in MA as presence of extra whole or partial copy of chromosome 21.
State Visit and Hour Limits
Coding and Billing Guidance
| No codes listed |
Key Definitions
Clinical Background
Background: The document references diagnostic criteria and the clinical focus of ABA in relation to autism spectrum disorder (ASD). ABA addresses deficits in social, communication/language, and adaptive functioning and is provided based on individualized treatment plans that limit services by intensity (e.g., Kansas: up to 40 hours/week when clinically indicated; Massachusetts EI: up to 30 hours/week; Maryland: up to 25 hours/week for ages 18 months–5 years and 10 hours/week for ages 6–18 years without denial solely for number of hours). Several state rules require qualified diagnosticians and use of validated diagnostic tools or refer to DSM-based ASD definitions and require documentation and periodic review of progress as a condition of continued authorization.
Policy Revision History
Interim review: Kansas Medicaid updates incorporated into the ABA state mandates document.
Interim review: Kentucky revision to the ABA state mandates document.
Interim review: Updates made to Kentucky, New Jersey, and Washington sections of the ABA state mandates document.
Interim review: New ABA state mandates document created to accompany the ABA Supplemental Clinical Criteria.
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