CMS Gave Florida's ABA Task Force 11 Recommendations. It Meets Again Monday.

Approved minutes of the August 31 meeting record a CMS official urging no telehealth supervision, supervision ratios and a 40-hour audit flag. Meeting 4 takes up outcomes, payment and supervision.

Florida's ABA Task Force approved the minutes of its August 31 meeting on September 28. They record something our September 6 update didn't have: a list of 11 recommendations from Dr. Caprice Knapp of the Centers for Medicare & Medicaid Services, presented with CMS's ABA toolkit. The task force meets again Monday, October 5, and its agenda takes up exactly the topics those recommendations target.

What CMS recommended, as recorded in the minutes

  1. Focus on primary use of the service for autism diagnoses; set better parameters for non-ASD diagnoses.
  2. Ensure treatment planning is done comprehensively.
  3. Establish conflict-free case management protocols and policies.
  4. Establish a narrower set of screening tools.
  5. Establish supervision ratios.
  6. “Do not allow supervision via telehealth.”
  7. Adequate utilization management controls, with higher intensity “based on acuity.”
  8. “Eliminate consolidated billing.”
  9. “Utilizing 40 hours per week as a flag for audits.”
  10. “Establish a written policy for naps and breaks.”
  11. “Look at value-based care in reimbursement models.”

The turn: these are a CMS official's emphasis, not Florida's position

The minutes say Knapp “emphasized” these. They're a summary prepared by task force staff, not a CMS document, and the task force adopted none of them. When the chair invited recommendations at the end of the meeting, “The task force members did not have any items to discuss.” The same meeting heard Florida Medicaid staff compare current coverage to the toolkit, and members raised questions about value-based purchasing's effect on children with complex needs.

But Monday's agenda lines up with the list: “ABA Outcomes and Accountability: Linking Assessment, Treatment Duration, and Payment,” “Supervision Requirements and Best Practices,” and “Optimizing Quality in ABA Services,” followed by member discussion and recommendations and public comment. It runs 10:00 a.m. to 3:30 p.m.

The limits

Minutes of the September 28 meeting aren't published yet. Nothing here binds Florida Medicaid. The task force's recommendations are due to the Governor, Senate President and House Speaker by December 31, 2026.

What you must know or do

  • Florida owners: count how much of your 97155 is delivered by telehealth and how many clients are authorized at 40 or more hours a week. Those two numbers are your exposure if items 6 and 9 become policy.
  • Clinical directors: if you want to speak to supervision or the 40-hour flag, Monday's public comment slot is on the agenda.
  • Everyone else: these 11 items are what CMS told one state to do. If your state has convened its own review, check its agenda for the same items: telehealth supervision, the 40-hour flag and consolidated billing.