TennCare's Annual ABA Quality Attestation Comes Due Again October 1

Every ABA provider contracted with a TennCare managed care plan (BlueCare, UnitedHealthcare Community Plan or Wellpoint) owes the plans an Annual ABA Provider Quality Assurance Attestation. The form says the requirement is “Effective October, 1, 2025, and annually thereafter.” Read literally, the second cycle falls on October 1, 2026, nine days out.

The turn: the signature covers more than the form

The form itself is short. It asks whether two things exist, marked “Y = Policy/Process in Place” or “E = Explanation Provided”:

• A Telehealth Policy and Procedure
• A Parent/Caregiver Involvement Policy and Procedure

The signature line goes further: “my signature attests that my organization has read and is following the ABA Provider Requirements and Program Description.” That's the joint document all three plans use, revised June 13, 2024. Signing puts your organization on record as meeting all of it, and the form adds that “each MCO may select a subset of providers for a quality review,” including “sharing policies for review, clinical documentation, and other supporting documentation.” The program description says those reviews use “a random sampling of providers.”

What you're attesting to

• “Individualized treatment plans within thirty (30) days of admission and reviewed every six (6) months thereafter.”
• An “updated evaluation of functioning via standardized tools at least every two years.”
• “Measurable parent/caregiver goals” and documented parental “commitment for engagement.”
• A termination-of-services policy that follows the BACB Ethics Code.
• For telehealth, protocols covering clinical appropriateness of each model (direct service, clinical direction, caregiver consultation), HIPAA-compliant technology, therapeutic benefit and provider competence.

The completed form goes to the TennCare Provider Registration Portal.

The limits

No document we found says “due October 1, 2026” in those words. That date is our reading of “annually thereafter.” None of the documents says what happens if a provider doesn't file, and the form doesn't say whether a provider in all three networks files once or once per plan. We noted the attestation in passing in our piece on BlueCare's assessment guideline. This piece covers the date and what the form commits you to.

What you must know or do

• Compliance leads: find last year's submission in the TennCare Provider Registration Portal. If there isn't one, file now rather than on October 1.
• Owners: put a dated, written telehealth policy and caregiver-involvement policy on file before you sign. If either doesn't exist yet, mark “E” and explain rather than checking “Y.”
• Clinical directors: before signing, check ten charts for three things: a plan within 30 days of admission, a review every six months, and a standardized re-evaluation within two years. The signature says those are true.
• Billing: ask your provider representative at each plan whether one portal upload covers all three networks.