Fidelis Wants 80% Session Attendance Documented by October 1

Fidelis Care posted an update to its ABA clinical policy on August 31. It applies to all providers delivering ABA and takes effect October 1, 2026 — four weeks out.

Read the attendance clause first, because it is the one that turns a family's missed sessions into your authorization problem.

“Documentation of 80% of scheduled sessions successfully completed for the member/enrollee and caregiver participation per visit attestation form.”

“If attendance falls below 80% of the authorized hours within an authorization period… supporting documentation is required to justify continuation of ABA services at the previously approved level.”

Where absences are attributed to medical, educational or family barriers, the documentation “must also demonstrate the actions taken to address such barriers.” Not that the barrier existed — what you did about it.

The numbers to put in your protocols

• 80% of scheduled sessions completed, evidenced per visit by attestation.
• 6 hours a day or 30 a week — requests above either may trigger additional clinical review and should carry clinical justification.
• Under 20 hours a week if the member attends school full time, as a stated consideration in setting hours.
• Supervision at no more than 20% of direct service hours, unless clinical documentation justifies more.
• Caregiver training ideally at least two hours a month, with clinical documentation justifying fewer, plus an assessment of barriers to family engagement and a documented plan for addressing them.
• Updated functional behavior assessment and skills-based assessment at least every six months.

One more sentence deserves attention because it changes what an authorization request is: if documentation justifies that a lower intensity, frequency or duration would reasonably achieve the goals, “the health plan may authorize services at a lower intensity, frequency, or duration than requested.” Your own documentation can be read back as the argument for less.

The same company says the opposite in California

Fidelis is a Centene plan, and the policy is Centene's CP.BH.104 family. We wrote about the California edition this week: Health Net adopted CA.CP.BH.104 for Medi-Cal on April 20, superseding the CASP practice guidelines. Put the two side by side and they disagree on the two questions a treatment plan has to answer.

• School. California states twice that “the number of medically necessary BHT hours may not be reduced based on time spent in school or participating in other activities.” New York names “less than 20 hours per week if attending school full-time” as a consideration in setting hours.
• Caregivers. California's Medi-Cal edition says plainly: “Parent/guardian participation is not required.” New York makes parent and caregiver training a required component, performance-based and caregiver-driven, with baseline data, mastery criteria and a barriers plan.

Both are current. Both are Centene. A provider operating in both states cannot write one treatment plan template, and a clinical director who standardized on either one has it wrong somewhere.

The limits

These are different products under different state rules — California's is a Medi-Cal policy written against that state's EPSDT framework and All Plan Letters, New York's applies across Fidelis lines of business — so the divergence is partly regulatory rather than a company changing its mind. That explains it; it does not help the multi-state provider, who still has to run two protocols. The 80% figure is a documentation trigger rather than an automatic denial: falling below it requires justification to continue at the approved level, not termination. And “ideally” two hours of caregiver training a month is exactly as soft as it sounds — the enforceable part is the documented plan and the barriers assessment.

What you must know or do

• Before October 1: work out whether you can produce a per-visit caregiver participation attestation at all. If your notes do not capture it today, that is a form and a workflow change, not a documentation habit, and four weeks is not long for it.
• Run your Fidelis authorizations against 80% now. Take each active authorization period, divide sessions completed by sessions scheduled, and list every member under 80%. Those are the ones needing a barriers narrative before renewal — and the narrative has to say what you did, not what happened.
• Check your supervision ratio against 20% of direct hours. Over it without documented justification is an easy finding for a reviewer, and it is arithmetic you can do this afternoon.
• Multi-state directors: pull your treatment plan template and find every place it asserts caregiver participation is required, or that school hours reduce service hours. One of those sentences is wrong in one of your states.
• Everyone on a Centene plan elsewhere: find your state's edition of CP.BH.104 and check its date. Arizona has run it since June 2025, California since April, New York from October. The reference number travels; the terms do not.