From 2028, an Illinois Speech Pathologist's Diagnosis Can Open ABA Coverage

Public Act 104-0561 lets qualified SLPs diagnose autism in children under 3 within Early Intervention, for both commercial insurance and Medicaid. Until then, it doesn't count.

Governor Pritzker signed HB 5225 on July 10, 2026. As Public Act 104-0561, it lets a licensed speech-language pathologist's autism diagnosis support ABA coverage, under both the Insurance Code mandate and Illinois Medicaid. It takes effect January 1, 2028. One summary reported it as effective immediately. The enrolled text says otherwise: "This Act takes effect January 1, 2028."

The diagnosis counts only under narrow conditions, and intake teams will need all of them on a checklist.

The four conditions (new 225 ILCS 110/8.4)

  • "the child is under 3 years of age and has no known co-occurring medical conditions, such as seizures, gastrointestinal problems, or sleep disorders"
  • the SLP has completed training from an approved continuing-education sponsor
  • "at least 5" of the SLP's required continuing-education hours are in autism diagnostic methods, certified at renewal
  • "the diagnosis occurs as part of the Illinois Early Intervention Program"

Coverage

  • Commercial: Insurance Code 356z.14 adds the SLP to who can prescribe, perform or order the diagnostic evaluation. The mandate covers people under 21, and its $36,000 annual cap is existing law.
  • Medicaid: Public Aid Code 5-30.11 covers ABA when ordered by a physician, psychologist or qualifying SLP, "and (2) evaluated by a behavior analyst."

What you must know or do

  • Intake leads, now through December 31, 2027: an SLP-only diagnosis doesn't support an Illinois ABA authorization. Ask for a physician or psychologist diagnosis.
  • Intake leads, for 2028: draft the rule now. Accept an SLP diagnosis only if the child was under 3, had no known co-occurring medical conditions, was seen in Early Intervention, and the file documents the SLP's training. One failed condition means it doesn't qualify.
  • BCBAs: the behavior analyst evaluation stays mandatory for Medicaid. Nothing in the act replaces it.