Missouri Autism Centers Must Revalidate by October 1. ABA Providers Are Next.

Missouri Medicaid Audit and Compliance is running a two-phase off-cycle revalidation, outside the normal five-year cycle, and ABA is in both phases. Phase I covers clinics (provider ID beginning “50”) with the Autism Center specialty code “AC,” and its deadline is October 1, 2026. The monthly 120-, 90-, 60- and 30-day notices for that phase went out June 1 through September 1.

Phase II covers “Applied Behavioral Analysts (Provider Type #s beginning with ‘73’),” who must revalidate before March 2, 2027.

The turn: the notice goes to one inbox

MMAC sends every notice by email to the address in the provider's eMOMED account, and nowhere else. Its FAQ is blunt: “Failure to update contact info does not exempt the provider from revalidation requirements.” If you haven't seen a Phase I notice and you're an autism center clinic, the likeliest reason is an old email address, not an exemption.

The consequence is the same in both phases: “administrative action, including termination.” Termination “stops all claims payment, and reinstatement requires re-enrollment.”

The details

• Phase I: administrative action begins October 1, 2026 for non-compliant providers.
• Phase II: public notice October 1–31; monthly notices November 1, 2026 through February 1, 2027; administrative action from March 3, 2027. Home health, private duty nursing, hospice and substance use providers are in the same phase.
• Managed care doesn't exempt you. “Providers must maintain state Medicaid enrollment even if in a managed care organization.”
• Recent enrollment does. Providers newly enrolled or revalidated within the last 12 months don't need to revalidate again.
• Extensions “are not guaranteed.”

Why ABA is on the list

The trigger was an April 23 CMS letter asking every state for a swift revalidation of high-risk providers and a two-year strategy. The letter doesn't name ABA. States have added it themselves:

• South Carolina put ABA providers among 5,713 prioritized for rapid revalidation within 12 months, with site visits and fingerprint-based background checks.
• Maine will send revalidation notices to “Adaptive Behavior Services for Children” providers in January–March 2027. It pends claims 60 days after a missed revalidation date and terminates at 90.
• Rhode Island put a six-month moratorium on newly enrolling HBTS/ABA providers from June 16, 2026.

The limits

MMAC hasn't published what the revalidation itself requires beyond “the steps exactly as outlined” in each notice, and doesn't list fees by type in the notice itself. It points to the MO HealthNet Enrollment Guide's Quick Glance. Missouri hasn't said whether it will add site visits or fingerprinting, as South Carolina has.

What you must know or do

• Owners of Missouri clinics enrolled as Autism Centers: confirm today that Phase I revalidation is complete. If no notice ever arrived, call the MMAC Provider Revalidation Unit at 573-751-5238 before October 1.
• Everyone enrolled as provider type 73: log in to eMOMED and check the contact email this week. Phase II notices start November 1 and go only there.
• Assign one person to that inbox and put November 1 and March 2 on the compliance calendar.
• Check when you last enrolled or revalidated. Within 12 months, you're out of scope. Keep the date on file in case a notice arrives anyway.