Michigan Finalizes Its ABA Rewrite: No Physical Exam, Six-Month Progress Reports

MDHHS issued MMP 26-18 on October 1, adopting the Behavioral Health Treatment changes it proposed in April. The physical exam is gone, and the bulletin now spells out what every behavior plan and progress report has to carry.

On October 1, 2026, the Michigan Department of Health and Human Services issued MMP 26-18, “Updates to Behavioral Health Treatment (BHT) Requirements for Autism Services.” It's the final version of proposal 2613-BCCHPS, which we reported on September 7. Back then we couldn't find a final bulletin. This is it.

What's new since the proposal

The direction hasn't changed. A child no longer needs a physical exam before starting BHT. A diagnostic re-evaluation is required only when a physician or other qualified licensed practitioner finds it medically necessary, or when the family asks for one (Public Act 111 of 2021). What's new is that it's now policy, and the full text is public. The text sets requirements the proposal notice only summarized.

The dates don't line up neatly. The bulletin's header reads “Effective: As Indicated,” and no section gives a later date. The state plan amendment behind it, MI-25-0020, was approved by CMS on February 19 and took effect June 1, 2026. Both dates have passed.

What the bulletin requires

  • Every behavior plan sent to the PIHP or CMHSP for prior authorization has to follow “generally accepted standards for ABA,” measure each goal with a standardized system that “may include” VB-MAPP or ABLLS-R, give a timeline and treatment hours for each goal, and document that the provider is licensed to provide ABA in Michigan.
  • Interim progress assessments are due at least every six months. Each one measures progress on every goal with the standardized system and gives an updated anticipated timeline and treatment hours for that goal, based on re-evaluation. PIHPs can ask for them more often.
  • Discharge “cannot be based on a set timeline (e.g., one year, three years, etc.),” and treatment “should not be denied or withheld based on caregiver availability.”
  • Settings: services can be delivered in a clinic, the home, school, residential or other community settings, and each plan has to name the setting for each goal.
  • Who can assess: an LBA, an LABA under an LBA, or a licensed psychologist with ABA training working with an LBA. A psychologist qualifies with at least two years working with people with ASD, three BACB-required courses and one year developing ABA-based behavior treatment plans.
  • Who can diagnose: physicians and psychologists, plus APRNs, physician assistants and master's-level fully licensed clinical social workers. Each needs at least two years diagnosing developmental disorders, plus a year of supervised didactic learning and/or work in a collaborative team model.

The limits

The bulletin went to Community Mental Health Services Programs and Prepaid Inpatient Health Plans, not to providers directly. It reaches you through your PIHP contract, on whatever schedule your PIHP updates its own forms and authorization rules. It says to keep it on file “until the information is incorporated into the MDHHS Medicaid Provider Manual,” so the manual may lag for a while. It names VB-MAPP and ABLLS-R as tools the measurement “may include,” not as the only ones allowed.

What you must know or do

  • Intake staff: stop asking families for a physical exam before BHT starts. If your PIHP's referral checklist still asks for one, send the PIHP MMP 26-18, page 1.
  • Clinical directors: pull the next five treatment plans due for reauthorization. Check that each goal has a standardized measure, a timeline and its own hours, and that the plan names the setting for each goal. Those are the items the bulletin requires.
  • Anyone setting discharge criteria: remove any fixed-duration language from your discharge templates. The bulletin rules out discharging on a set timeline.
  • Owners: ask your PIHP in writing which date it's applying the bulletin from (October 1 issuance or the June 1 state plan date) and when its prior authorization forms will change.

Correction, October 26, 2026: This article originally said interim progress assessments use the same measurement, timeline and hours as the behavior plan. The bulletin requires each assessment to measure progress on every goal and to give an updated anticipated timeline and treatment hours for it, “based on both the initial assessment and subsequent re-evaluations.”