Vermont Resets Every Medicaid ABA Prior Auth on New Forms Starting October 1

Vermont Medicaid changes how ABA is authorized on October 1, 2026. DVHA's August 21 notice says prior authorizations for current ABA members “will be staggered based on the member's existing treatment plan date,” with an updated request form, a new Comprehensive Assessment form, new clinical criteria and an updated ABA Supplement, dated August 4.

The turn: the family is now part of the medical necessity file

Asked whether family economic status, education, employment and belief systems would be used in authorization decisions, DVHA answered: “DVHA believes demographic information is an important aspect of determining medical necessity and understanding the overall needs of the child and the family.” On caregivers: “The ability of the parent or caregiver to participate in treatment has and will continue to influence prior authorization decisions.”

So how you describe a family's availability and participation feeds directly into the hours approved.

Who files what, and when

• Next assessment or treatment plan due before 10/1/26: the October 1 request needs the State of Vermont ABA Prior Authorization Request Form, the prescription, a current diagnostic assessment, the Comprehensive ABA Assessment Form and the treatment plan.
• Due after 10/1/26: “their current prior authorization will be extended until the end of their current treatment plan.” DVHA adds: “Providers should not update the treatment plan or the assessments prematurely.”
• New members: the full package from the first request.
• The Comprehensive Assessment must be completed “in its entirety,” and providers “may not reference outside documents.” It scores 11 developmental domains from 0 to 3, a total of 0 to 33, which DVHA says is “independent from diagnosis.”
• From the Supplement: 97151, 97152 and 0373T are each limited to 4 hours every 6 months without prior auth. 97155 by telehealth is allowed only “if at least one of the providers is onsite,” and a BCBA delivering direct treatment must be onsite.

The limits

DVHA refers to a Medical Necessity Determination Tool with Mild, Moderate and Severe impact levels, but we couldn't find it published, so it isn't clear how a score becomes hours. DVHA doesn't say how much weight demographic factors carry. It also concedes an error: the Supplement lists four prescriber types, but DVHA says that section “has not been edited since before 2019,” that eligible prescribers “remain the same,” and that it will correct the Supplement.

What you must know or do

• Intake and billing: list every Vermont Medicaid client with the date their next assessment or treatment plan is due. Due before October 1 means a full new package for the October 1 request. After October 1 means nothing until that date.
• BCBAs: write each Comprehensive Assessment as a standalone document. Restate the content rather than citing another report, which DVHA won't accept.
• Write the caregiver section concretely: who attends, how often, what training they'll receive and what limits their participation. DVHA has said it weighs this.
• Don't refresh a plan early to get ahead of the change. DVHA has asked providers not to.