Fidelis Expects 80% ABA Attendance From October 1, With Barriers Documented

Fidelis Care told providers on August 31 that an updated ABA clinical policy, FC.CP.BH.104, and a newly adopted documentation policy, CP.BH.105, take effect October 1, 2026, covering medical necessity, treatment planning and utilization management.

The attendance line comes first because it turns a family's missed sessions into your documentation problem: “Members are expected to maintain at least 80% attendance, with barriers and provider follow-up documented when applicable.”

What changes October 1

From Fidelis's notice:

• “Requests over 6 hours per day or 30 hours per week may trigger additional clinical review and should include supporting clinical justification.”
• “Caregiver guidance remains a required component of care and must include measurable goals, participation, barriers, and efforts to address engagement.”
• Documentation standards are updated for treatment planning, progress updates, assessment data, crisis planning, discharge and transition planning, and coordination of care.
• “Supervision expectations have been clarified, including minimum oversight requirements and rationale for supervision beyond policy standards.”
• Diagnostic evaluations must include clinician-administered and caregiver-report assessment tools, and the approved tool list is updated.
• “Telehealth may be considered case by case when clinically appropriate and supported by documentation.”

The turn: the same company can't write this rule in California

Fidelis is a Centene plan, and it makes caregiver guidance mandatory. In California, DHCS's All Plan Letter 23-010 says Medi-Cal managed care plans “cannot require participation by parents/guardians,” and “must not reduce the number of Medically Necessary BHT hours” for time spent in school. Health Net, Centene's Medi-Cal plan there, has used Centene's CA.CP.BH.104 since April 20, and it operates under that letter.

Different states' rules, not a company changing its mind. But a provider working in both can't use one caregiver clause in its treatment plan template.

The limits

The notice summarizes the policy, and the detail, including specific supervision thresholds, is in FC.CP.BH.104 itself. Centene marks that text as not for reproduction, so this article quotes only the public notice. Read the policy in Fidelis's provider policy library before setting protocols. The 80% figure is an expectation with documentation attached. The notice doesn't describe it as an automatic denial.

An earlier version of this article quoted the policy text directly. It has been rewritten from public sources.

What you must know or do

• Before October 1, run every active Fidelis authorization against 80%. Divide sessions completed by sessions scheduled, and list each member below it.
• For each one, document the barrier and your follow-up. The notice asks for both, not just the reason for absences.
• Check each Fidelis treatment plan for measurable caregiver goals, and make sure notes record participation, barriers and what you did about engagement.
• Put clinical justification in any request over 6 hours a day or 30 a week before it goes in, not at appeal.
• Multi-state directors: find the caregiver-participation clause in your template. It can't read the same for Fidelis in New York and a Medi-Cal plan in California.
• Read FC.CP.BH.104 and CP.BH.105 in Fidelis's provider policy library for the supervision standard before October 1.