New York Froze New ABA Enrollments and Sales in July. Revalidation Letters Come Next

ABA (COS 0590 and 0591) has been under an enrollment and change-of-ownership moratorium since July 27, for at least six months. Now high-risk, ABA providers start getting Phase 2 revalidation notices this winter.

New York's Medicaid program put applied behavior analysis under a temporary enrollment moratorium effective July 27, 2026. It covers ABA's two categories of service, COS 0590 and COS 0591, and remains in effect "for a minimum of 6 months," so not before late January 2027. The same DOH initiative raised ABA to high risk, and ABA providers are in Phase 2 of revalidation, with notices beginning "Winter 2026."

If you're already enrolled, you can keep billing. The moratorium closes the door on growth by enrollment and on sales.

What the moratorium stops

  • "No Changes of Ownership (CHOWs), reinstatements, or new enrollments will be accepted."
  • Pending applications "regardless of stage of review" were discontinued. Applicants can start again once the moratorium ends.
  • It doesn't affect revalidations or most routine maintenance, such as address changes.
  • DOH's call-in slides also list, among the triggers for raising an individual provider's risk level, "at least 6 months following the lifting of a temporary moratorium" for a provider type it covered.

A practice under contract to sell, or planning a new entity that needs its own enrollment, is blocked until the moratorium ends. DOH hasn't published an end date.

What high risk means at revalidation

  • Standard screening plus a pre- or post-enrollment site visit.
  • Fingerprint-based background checks for every owner of 5% or more.
  • Revalidation every three years rather than five.
  • Everything goes through the Provider Services Portal. The paper process ended in May 2026.
  • From the first notice you have 123 calendar days: a reminder at day 60, then at day 90 a termination notice effective 33 days later. Every enrolled provider needs an NPI.

This applies to providers serving managed care members only, too. DOH says everyone who treats NYS Medicaid members must be enrolled and is subject to revalidation.

It lands on a field already absorbing the $9.63 rate for 97153 and OMIG's ABA audit protocol.

What to do

  • Owners in a sale, merger or new-entity plan: have counsel check closing conditions and dates against a moratorium that runs until at least late January 2027 and has no published end.
  • Owners, before the letter: list every person holding 5% or more and tell them a fingerprint appointment is coming. Make sure you can log into the PSP and that the mailing and email addresses on file are current.
  • Credentialing lead: check the Notification List on DOH's revalidation page, sign up for the enrollment LISTSERV, and confirm every enrolled LBA has an NPI on file.
  • If you got two "initial" letters between July and September, DOH says a system error caused it and the later date governs.