Four States Audited, Four More Under Way

The HHS Office of Inspector General is running an ongoing audit series on Medicaid payments for ABA services delivered to children diagnosed with autism. Announced in January 2022, it now has four completed audits — Colorado, Maine, Wisconsin and Indiana — and four more in progress, with estimated completion in fiscal year 2027.

The stated objective

OIG will "audit Medicaid claims for ABA services provided to children diagnosed with autism to determine whether a State Medicaid agency's ABA payments complied with Federal and State requirements."

The work plan is explicit about motive: while early intervention and therapy can improve social and behavioral development, some providers have engaged in questionable billing patterns, resulting in federal and state payments for unallowable services.

Why this belongs next to the CMS toolkit

Guidance without enforcement changes little. Read together, the sequence is legible: OIG audits find problems in individual states, CMS converts the findings into a national description of good oversight, and state agencies write the rules. North Carolina's revised policy is what the end of that sequence looks like.

What you must know or do

The four completed reports — Colorado, Maine, Wisconsin, and Indiana — are public, and each names the specific documentation failures that produced its findings. That is an itemized list of what your own records will be measured against, published years before your state gets around to writing it into policy.

Read the one nearest you, then check whether those failures exist in your files. Not whether you would pass in principle — whether a reviewer pulling the same sample would find the same thing.

Four more are due by fiscal 2027. The list gets longer, not shorter, and each report tells the next state what to look for.