Oklahoma's Three Medicaid Plans Doubled ABA Supervision. Fee-for-Service Didn't.

On September 12 we reported Oklahoma's fee-for-service ABA rules: a 32-unit ceiling on the assessment, supervision at five percent, and two Medical Advisory Committee items on supervision and 97151 whose substance sat in attachments we hadn't seen. We've now read them. They aren't changes to the state rule. They're approvals letting each SoonerSelect plan go further than it.

Every approval document starts from the same contract clause: plans “may not impose prior authorization guidelines/criteria or utilization management practices that are more restrictive than OHCA without OHCA prior approval.” OHCA gave that approval to all three plans.

Supervision: 10% at every plan

Aetna Better Health of Oklahoma, Humana Healthy Horizons in Oklahoma and Oklahoma Complete Health each asked to “increase case supervision to 10% of direct treatment hours,” and OHCA approved the same wording for all three:

• “1-2 hours of case supervision for every 10 hours of direct treatment”
• “If direct treatment totals less than 10 hours per week, 2 hours of supervision is required”

OHCA lists the Aetna and Humana changes as effective May 19, 2026. Oklahoma Complete Health told providers its change took effect June 30, 2026.

Assessments: 24 units, then 16

• Initial 97151: limited to 24 units (6 hours).
• Reassessment: billed as 97151-TS, capped at 16 units (4 hours) every six months.

OHCA approved Humana's request February 25, 2026, and Humana estimated 2026 savings at $339,000. Aetna's is listed as effective May 20, 2026. Oklahoma Complete Health could implement on or after June 30, and its approval allows exceptions “up to 32 units when medically necessary due to documented clinical complexity.” From September 16, 2026, OCH requires modifier TS in position 1 on every reassessment claim, and says claims without it “may not process as intended.”

Hours: a cap at one plan, a trigger at another

Aetna has a 30-hour weekly cap on 97153, effective May 14, 2026, with exceptions through prior authorization. Aetna's request estimated about 20% of its ABA members were above that line. Oklahoma Complete Health's December 2025 approval sets review thresholds at 24 units a day and 30 hours a week, which its document calls “utilization management triggers, NOT coverage limits.”

The limits

Fee-for-service SoonerCare still runs on OAC 317:30-5-311 and -314 as we reported them, so a practice with both kinds of members is now working to two supervision standards and two assessment ceilings. OHCA's list gives no effective date for Humana's assessment change. Only Oklahoma Complete Health has published a TS modifier instruction. And we couldn't reach Aetna's provider notices.

What you must know or do

• Split supervision tracking by payer. For Aetna, Humana and Oklahoma Complete Health members, measure case supervision against 10% of direct treatment hours, and two hours for any week under ten hours of direct treatment. Five percent is only the fee-for-service number.
• Add TS in position 1 to every Oklahoma Complete Health 97151 reassessment billed on or after September 16. Ask Aetna and Humana in writing whether they want the same, since both approvals describe it.
• Budget plan-member assessments at 24 units. If a case genuinely needs more, write the complexity into the record before you bill, not after a denial.
• Pull Aetna members authorized above 30 hours a week of 97153 since May 14 and check each one has an exception on file.