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👋 Hey there!
Every rule in this issue was already in force before you opened it.
Indiana's accreditation bulletin is dated March 26, and its deadline passed on August 1 — five weeks ago. South Carolina's rewritten manual took effect July 1, off a bulletin from May 15. Virginia's 20-hour cap is dated July 1. Kentucky's reversal letter is July 23, Illinois signed its ownership act on July 24, and Ohio brought back its shelved rule on July 30.
None of them arrived as news. They arrived as a bulletin in a shared inbox, a manual edition that replaced the one you'd bookmarked, a line in an appropriation act. A rule doesn't announce itself. It starts applying, and most providers meet it in a denial.
None of them are rate cuts, either. They're conditions on getting paid the rate you already have: accreditation, independence of the diagnosis, who signs, who owns, who was in the room.
Health Net and Fidelis both now tie continuation to progress you can document rather than progress you can describe.
Five minutes. Start with your own state, and check the dates before you assume you're current.
⭐ Featured This Week
Section 150 of the Illinois Behavior Analyst Licensing Act bars any business organization from providing ABA services after January 15, 2027 if any owner, shareholder, officer or interest holder is unlicensed. SB 712 did not move that date — it exempted nonprofits and schools, and added personal liability for unlicensed clinical decision-makers.
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📚 Research Digest
Agana and colleagues review a decade of JABA studies and argue social validity should be an ongoing, interactive process that changes the intervention, not a one-time measure taken at the end.
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DRO remained efficacious for most participants at 100%, 80% and 60% procedural fidelity, and inefficacious for most at 40% and 20%, when commission and omission errors occurred together. It was a human-operant arrangement, not a clinical one.
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In a Fall 2026 JABA study, 73.33% of 15 undergraduates met mastery criteria for implementing matching after scoring video models alone, and 46.67% generalized to imitation and listener responding without in vivo training.
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A component functional analysis correctly predicted function for six participants with isolated functions and two with synthesized functions, and showed high specificity for one participant whose multielement FA was undifferentiated.
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⚖ Legislation Tracker
Kentucky ABA providers spent six weeks planning around a rate cut that did not arrive. The rates that survived are the April ones — and the letter reversing the cut is explicit that the problem behind it has not been solved.
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Maryland loosened its ABA combination-of-service rules rather than tightening them, and told providers the wrongly denied claims would be reprocessed and paid. Separately, H2012 is gone — treatment planning belongs in 97151 now.
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South Carolina Medicaid now treats ABA as non-covered when the treating clinic is connected to the clinic that diagnosed the child. The manual carrying the rule took effect July 1, 2026, and cites APA and BACB conflict-of-interest standards.
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Virginia's enacted budget imposes a 20-hour weekly ABA limit effective July 1, 2026, exceedable under EPSDT. Children five and under may use a provisional diagnosis for one year, and school-based FFS behavior therapy is carved out entirely.
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South Carolina's ABA caseload limits are counted per behavior analyst across all employers, not per clinic. BCaBAs went from a maximum of 16 cases to 12, and indirect RBT supervision is not reimbursable under 97155.
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Since July 1, 2026, South Carolina Medicaid no longer allows CPT 97151 to be delivered via telehealth, and does not treat a telehealth-conferred ASD diagnosis as valid. 97156 became permanently telehealth-eligible.
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Indiana required every enrolled ABA group to document that it had begun accreditation by August 1, 2026, on pain of deactivation. A CMS-approved enrollment moratorium has also blocked new agencies and changes of ownership since June 6.
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Ohio Medicaid's ABA spend went from $21.8M in 2020 to $99.6M in 2025 while the autism population doubled. Its revived draft rule requires CARF or Joint Commission accreditation and prohibits billing ABA under community behavioral health codes.
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💼 Industry News
The criminal takedowns get the headlines. The civil settlements are more instructive, because they show what a payer's lawyers can prove from a chart — and it is never clinical judgment.
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Centene's CP.BH.104 supersedes CASP criteria for Health Net Medi-Cal members under 21. Six months without clinically significant progress, plus no reasonable expectation a revised plan would help, is grounds for discontinuation.
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Fidelis Care's updated ABA policy takes effect October 1, 2026. Below 80% attendance in an authorization period, continuing at the approved level requires documentation — and supervision is capped at 20% of direct service hours.
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