Utah Made ABA Providers 'High Risk.' Revalidation Notices Give 60 Days.

Utah Medicaid has moved providers specializing in applied behavior analysis to its “High Risk” screening category. Its July Medicaid Information Bulletin dates the change July 1, 2026. Revalidation notices to existing ABA providers started going out in phases in September 2026. Each notice gives you 60 days from the date on the letter.

The turn: the notice may already be sitting in your mail

The bulletin gives every existing ABA and SUD provider 18 months to revalidate. That window sounds generous, but it isn't the one that matters. Your deadline is 60 days from your own letter, and the phased mailing has already begun. The same bulletin (item 26-62) says revalidation letters to high-risk billing providers go by mail to the “Pay-To” address in PRISM, and that billing providers who haven't revalidated since July 1, 2025 get 90 days from their letter, with termination if they miss it. Mailing for that track began July 15. The bulletin doesn't say which clock wins for an ABA provider who gets both kinds of letter, so plan around the shorter one.

What high-risk screening requires

From item 26-61 of the July 2026 bulletin:

• Report every individual or corporation with a 5% or greater direct or indirect ownership interest.
• Each individual owner at 5% or more needs a fingerprint-based criminal background check (FCBC). The bulletin points to FBI-approved channelers for live scan.
• DHHS or its designee may make unannounced site visits, before or after enrollment.
• Pay the 2026 federally mandated $750 enrollment fee, unless you can show active enrollment and fee payment with Medicare or another state's Medicaid program.

Failing to finish by the deadline “may result in termination from the Utah Medicaid program.”

The limits

Utah's own documents give two different start dates. The bulletin says July 1. The department's June 23 release says it raised ABA and SUD providers to high risk under 42 CFR §455.450(e) effective May 1, 2026, and plans to screen 4,644 high-risk billing providers by June 5, 2028. Either way, the requirements are the same. The enrollment moratorium in that release covers new SUD and mental health rehabilitation enrollments. ABA isn't named in it.

Utah is one of several states acting on CMS's April 23 request for swift revalidation of high-risk providers (Missouri's version is here). Alabama put ABA therapy on its high-risk off-cycle list on June 30. Nevada's swift-revalidation list, published June 5, leaves ABA (provider type 85) off.

What you must know or do

• Owners: list everyone with 5% or more ownership, direct or indirect, and book their fingerprint appointments now. Live-scan results can come back within 24 hours, while the mailed-card route adds postage time. The 60 days start on the letter's date, not the day you open it.
• Billing or credentialing lead: log into PRISM today and confirm the Pay-To address, correspondence address, email and phone are current. Then check the mail received at that address since September 1 for a revalidation letter, and note its date.
• Finance: find your receipt for the Medicare or other-state enrollment fee. If you have one, you may not owe Utah's $750. If you don't, budget for it.
• Office manager: decide who greets an unannounced DHHS site visit and where your enrollment and licensure documents are kept.