Applied Behavior Analysis (ABA) — New Mexico Medicaid
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State-specific clinical criteria for coverage, authorization, and delivery of ABA services for New Mexico Medicaid members, including eligibility, provider requirements, and stage-based evaluation and treatment processes.
No material clinical or coverage changes in this revision.
Coverage Criteria and Medical Necessity
Initial eligibility (At-Risk or Diagnosed ASD)
ABA services are medically necessary when the member meets ONE of the two categories below and subsequent stage-specific requirements are met.
Eligibility categories
- At-Risk for ASD: At-Risk requires Risk Evaluation via an approved AEP CDE; member age 12–36 months; meets at least one listed risk criterion: developmental differences/delays on standardized assessment, some ASD characteristics (impaired social communication or early indicators for restricted/repetitive behavior), or at least one genetic risk factor (e.g., older sibling with ASD, Fragile X).age 12–36 months
Services are time-limited when full DSM criteria are not met.
- Diagnosed ASD: Documented medical diagnosis of ASD per the latest DSM or ICD from an AEP or Grace Exception Practitioner; confirmation via AEP CDE or use of a targeted evaluation when behaviors have changed since the last CDE; ABA is needed to ameliorate symptoms, build adaptive behaviors, or reduce maladaptive behaviors to enhance health, safety, functioning, or prevent deterioration.
Stage requirements and prior authorization
Stage-based criteria and required sequence
BA is responsible for assessment, goal selection, measurement, and treatment documentation.
Family or AP may request ISP modifications prior to the six-month authorization point if immediate changes are warranted.
General medical necessity and delivery criteria
Covered when ALL of the following are met
Includes requirement to include objective baseline data and standardized assessment scores where applicable.
Clinical management and case supervision requirements are detailed in the BH policy and billing manual.
Focused vs Comprehensive ABA criteria
Service model selection logic
Dosage determined by individualized factors including ISP and ASD level.
Dosage individualized; adult ranges vary by tier (10–40 hrs/week).
Excluded from coverage are activities that do not directly accomplish objectives specified in the member's ABA treatment plan or that are not based on the principles and application of Applied Behavior Analysis (ABA). Examples include interventions that are better characterized as other therapies (e.g., speech, occupational, physical therapy, counseling) even if provided by someone with ABA training, and activities that are essentially staff training, certification, licensure, or supervision requirements rather than clinical ABA casework. Services that occur in school settings and have the potential to supplant educational services are also excluded.
ABA services delivered in a school under an Individualized Education Program (IEP) or Individualized Family Service Plan (IFSP) do not, by themselves, preclude coverage of medically necessary ABA provided across natural settings. School-based IEP/IFSP services remain the mechanism to address educational goals and to ensure a student receives a Free and Appropriate Public Education; ABA in clinical or community settings should support the member’s ability to access those educational services rather than replace them. Services provided in school that risk supplanting educational instruction are non-covered.
Coding, Authorization Periods, and Key Intervals
| 97151 | Behavioral analysis assessment |
| 97152 | Family/caregiver training (assessment related) |
| 0362T | Targeted/Risk evaluation (as used collectively with 97151 for Stage 2) |
| T1026 | Comprehensive Diagnostic Evaluation (CDE) / ISP references T1026 TG |
| T1026 TG | CDE (documented form) |
| T1026 TG/HI | Individual Service Plan (ISP) associated with CDE |
| T1026 HK | Targeted/Risk evaluation code referenced for adults |
| 97156 | Family training (Stage 3) - implemented in Treatment Plan |
| 97157 | Multiple-person family training / group |
Authorization, Documentation, and Provider Requirements
Prior authorization required for Stage 3; reauthorize every 6 months
Prior authorization is required for Stage 3 (ABA Treatment) services and must be obtained initially and every six (6) months within the state-defined authorization period.
- Authorizations follow state timeframes: up to 3 years for members < age 8 and up to 6 years for members age 8 and older.
- At each six-month authorization point the reviewer will assess need for ISP or treatment plan changes with input from the family and the AP's BA.
PA required for Stage 3 and certain Comprehensive ABA (EPSDT-aged)
Prior authorization is required for ABA Stage 3 services; for EPSDT-aged recipients, Comprehensive ABA delivered at less than 20 hours/week on average also requires prior authorization.
- Prior auth requests must include evaluations, ISP, treatment plan, model, hours requested, and supervision/clinical management hours when exceeding thresholds.
- Comprehensive ABA for EPSDT-aged recipients requires prior authorization if services average under 20 hours/week.
Three-stage service progression (Stage 1 → Stage 2 → Stage 3)
Services follow a three-stage progression: Stage 1 (AEP completes CDE/ISP and refers to an AP), Stage 2 (AP agency completes behavior/functional analytic assessment and develops the ABA treatment plan), then Stage 3 (implementation of the treatment plan by BA/BCaBA/BT).
- Stage 1: AEP develops Integrated Service Plan (ISP) and referral to approved ABA provider agency.
- Stage 2: AP conducts assessment to select focused or comprehensive model and completes treatment plan.
- Stage 3: Stage 3 practitioners implement the treatment plan under required supervision and authorization.
Adult-specific access: Stage 2 available without CDE; CDE only if medically warranted
Adult recipients may access Stage 2 services without a CDE; a CDE is not required for adults unless medically warranted. Adults must complete a Targeted/Risk evaluation and ISP prior to the end of their first service authorization and must document ASD confirmation by a Grace Exception Practitioner within the last three years to access Stage 3.
- If clinically warranted during authorization, adults may receive CDE or Targeted/Risk evaluation and a new ISP; medical necessity must be documented.
- Adults transitioning from EPSDT at age 21 may continue Stage 1–3 services when an ABA Stage 3 Treatment Plan is approved.
Documentation required to obtain initial and ongoing PA for Stage 3
To secure initial and ongoing prior authorization for Stage 3, the AP must submit the prior authorization request including the CDE or targeted evaluation and the ISP from the AEP, plus the ABA treatment plan and details about model, hours, supervision, clinical management, and other services.
- Include the CDE or targeted evaluation and the ISP developed in Stage 1 along with the ABA treatment plan developed in Stage 2.
- Specify requested treatment model (focused or comprehensive), maximum hours/week, hours of case supervision if >2 per 10 hours of intervention, hours of clinical management if >2 per 10 hours, and need for collaboration with an ABA specialty care provider.
- Document hours allocated to other services in the ISP (e.g., early intervention, PT, speech) to determine feasibility of requested ABA intensity.
CDE (T1026 TG) and ISP timing and deliverables
The CDE (T1026 TG) report must be issued within 60 calendar days of completion, and the individualized ISP (T1026 TG/HI) must be issued within 30 calendar days (no more than 45) after completion of the CDE; copies must be included in the recipient's record and provided to the family/PCP.
- CDE must include direct observation, interviews, and relevant informants; the CDE record must be signed by the AEP.
- ISP must include statements supporting that requested ABA services are expected to result in measurable improvement and must link to CDE findings.
- ISP must be issued within required timelines and must indicate how other recommended services align with ABA.
Denial risk: non‑covered activities and activities outside ABA scope
Services that are not designed to accomplish objectives in the ABA treatment plan, not based on ABA principles, that supplant school educational services, are better described as other therapies, or are staff training/certification activities are non‑covered.
- Non-covered activities include interventions outside the ABA treatment plan, non-ABA modalities, school activities that supplant educational services, services better described as speech/OT/PT/counseling, and staff training or certification tasks.
Prior authorization note — Stage 3 and EPSDT Comprehensive ABA
Reminder: Prior authorization is required for Stage 3 services and Comprehensive ABA for EPSDT-aged recipients averaging less than 20 hours/week requires prior authorization from the MCO/TPA.
- Stage 3 PA submissions must include treatment plan, CDE/ISP, model, hours requested, and supervision/clinical management details.
- EPSDT-aged recipients receiving Comprehensive ABA under 20 hours/week on average need PA.
Service Settings and Level of Care
Outpatient ABA services (stage-based with possible specialty care)
If not responding, AP must attempt internal remedies and may request new evaluations before termination.
Outpatient/Community-based ABA
Coordinated with school resources and other therapies as specified in the ISP.
Service intensity determined by individualized assessment, functional needs, and risk level.
Stage Definitions, Assessments, and Treatment Planning
ABA Stage criteria
Clinical ABA coverage is organized into three stages (Evaluation, Assessment, Treatment) with specific provider roles and documentation/authorization requirements.
AEP must be an approved autism evaluation provider.
Family Set and stakeholders included in goal selection.
AP must document hours, supervision, clinical management, and coordination with other services.
Stage 2 (Assessment and Goal Setting)
Stage 2 assessment and treatment plan requirements
Data collected serve as the primary basis for baselines, discharge goals, and response evaluation.
Data represented graphically where possible to inform modifications.
Stage 3 (Implementation, Supervision, and Settings)
Stage 3 treatment plan and delivery requirements
Must be updated prior to each Prior Authorization period and include coordination with other therapies and community resources.
Family participation strategies (including telemedicine) required if family cannot attend in-person.
Supervision and clinical management details are provided in the BH policy and billing manual.
Treatment Modalities and Delivery Options
Applied Behavior Analysis (ABA)
Telemedicine
BICC, BACB, and NM RLD psychologist board support telehealth for ABA.
Direct Treatment Intensity and Visit Ranges
Key Definitions
Coding and Billing Notes
| 97151 | Behavioral analysis assessment |
| 97152 | Family/caregiver training (assessment related) |
| 0362T | Targeted/Risk evaluation (as used collectively with 97151 for Stage 2) |
| T1026 | Comprehensive Diagnostic Evaluation (CDE) / ISP references T1026 TG |
| T1026 TG | CDE (documented form) |
| T1026 TG/HI | Individual Service Plan (ISP) associated with CDE |
| T1026 HK | Targeted/Risk evaluation code referenced for adults |
| 97156 | Family training (Stage 3) - implemented in Treatment Plan |
| 97157 | Multiple-person family training / group |
Background and Clinical Context
Autism Spectrum Disorder (ASD) is a lifelong neurodevelopmental condition for which Applied Behavior Analysis (ABA) is an evidence-based set of techniques intended to increase adaptive skills and reduce maladaptive behaviors that impair health, safety, or functioning. ABA treatment is delivered through a staged process (evaluation, assessment, then treatment) and must be individualized, measurable, and documented in an ISP and ABA Treatment Plan. ABA supports may be provided across natural settings (home, clinic, community, and school) but will not be covered when they supplant required educational services or when activities fall outside ABA principles.
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