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More of what payers check now sits in the clinical record rather than on the claim. CareSource Ohio has refused ABA claims that arrive without the treatment record since September 1. From October 29, Indiana wants a complete FBA behind every behavior a BIP targets, refreshed at each reauthorization.
The measures those records rest on are less settled than the rules asking for them. Across two assessments of the same 49 toddlers, agreement on DSM-5-TR severity level was κ = 0.318 and 0.195, and CMS's toolkit calls it best practice to set weekly hours by that level. A review of the BOSCC, a tool built to detect change, found it moved no further than the ADOS in the studies that used both.
The payers' requirements still stand. What the research changes is where the case for hours should come from: your own assessment data, written down, rather than a severity level copied from a referral.
⭐ Featured This Week
From October 29, Indiana Medicaid wants a complete FBA for each behavior a BIP targets: an indirect assessment from six named tools, graphed with raw responses, plus ABC data and a function statement, refreshed every reauthorization. That's 18 days out.
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📚 Research Digest
CMS's toolkit calls it best practice to set ABA hours by DSM-5-TR severity level — 10, 20 and 30 a week. Agreement on those levels across two assessments of the same 49 toddlers was κ = 0.318 and κ = 0.195.
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Across 19 studies and 789 children, BOSCC scores improved by g = −0.32 in intervention arms and −0.15 in controls. In the four studies that also used the ADOS, both tools moved by almost the same amount: −0.31 and −0.32.
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⚖ Legislation Tracker
Medi-Cal's Behavioral Health Treatment manual now lists eight elements every S5110 or S5111 note must carry, including the names and relationships of the family members trained, and bars billing both codes on the same date for the same service.
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Texas extended its state-funded autism ABA program to anyone under 22 and dropped the 180-hour yearly cap on August 25. HHSC's 2028–29 reduction schedule then listed the program for elimination, $13.7 million over two years.
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Approved minutes record CMS's Dr. Caprice Knapp urging Florida's ABA task force to bar telehealth supervision, set supervision ratios, flag 40-hour weeks for audit and end consolidated billing. The task force adopted none of them. Recommendations are due to the Governor by December 31.
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North Carolina Medicaid won't pay for sessions by technicians without RBT or ABAT certification once their 120-day grace period ends: late November for staff employed August 1. The August 31 bulletin also rewrote the supervision rule.
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Indiana Medicaid stops offering peer-to-peer reviews on fee-for-service prior authorization requests November 1; scheduling ends October 31. Denials then go only through administrative review and appeal. A same-day bulletin clarifies ABA referral rules.
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From January 1, 2027, SB 1049 gives California providers at least 90 days from a plan's denial or overpayment notice to submit a corrected claim. Plans and insurers can't deny it as late under any other filing deadline.
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Indiana Medicaid's September 29 bulletin bars keeping ABA clients awake because nap time isn't billable. Naps go in the treatment plan schedule per AAP guidance, and lower 97153 use must be documented with nap dates and durations.
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AB 2011, signed September 30, requires California commercial plans and insurers to follow federal parity rules and guidance as they existed on January 1, 2025, including the 2024 final rules. It takes effect January 1, 2027.
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From January 1, 2027, SB 685 requires California to suspend or revoke a nonpublic agency's certification for listed failures, cuts the staff-change notice from 45 days to 30, and makes death notices due within 24 hours.
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Montana's Medicaid ABA manual authorizes an initial 1,260 units (315 hours) per 180 days, expires unused units at day 180, and requires the BCBA to file at least 14 calendar days before continued services start.
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DHCS submitted State Plan Amendment 26-0033 to CMS in September, asking for a July 1, 2026 effective date. It revises Medi-Cal BHT language on utilization management and fraud controls. DHCS projects no added cost.
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💼 Industry News
Colorado's September Medicaid bulletin names ten intervention types, including ACT, social stories and sensory diets, that draw added review in pediatric behavioral therapy plans. Each needs a measurable target, assessment link and progress measure. Submit PARs 14–21 days early.
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Alaska Medicaid's autism fee schedule effective July 1, 2026 raised 97153 from $22.63 to $31.95 and 97155 from $29.78 to $41.97. Family guidance (97156) more than doubled to $41.97, matching 97155. Check July–September remittances.
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From November 1, Regence's ABA policy BH18 limits members to one authorized ABA provider at a time, bars billing 0373T with 97153 or 97155, and requires written justification for group treatment and for each modality's weekly hours.
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Health Plan of San Joaquin/Mountain Valley's April 29 alert requires ABA groups to be Medi-Cal enrolled through PAVE. Groups that can't show enrollment efforts within six months, about October 29, risk termination.
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Philadelphia's CBH raised standard rates 5% on July 1 and negotiated rates 3% on October 1, excluding Regionalized IBHS and IBHS-ABA. The Regionalized IBHS bonus cap falls from 15% to 10%, starting with November's payout.
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Since July 8, Community Care's Pennsylvania Medicaid guidelines require every continued-stay plan for center-based ABA to include a plan to taper hours. Full days for convenience don't qualify, and school-age graduates can't return for summer without a new order and assessment.
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Since September 1, CareSource Ohio Medicaid requires the member's treatment record to be submitted before any ABA claim: “Claims will not be accepted without accompanying treatment documentation.” H0036 isn't paid when an ABA code fits.
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From January 1, 2027, Illinois's 30-day Attorney General notice for health care deals no longer sunsets and reaches anyone owning or controlling the parties, including private equity. Provider organizations contracting for 20+ providers are covered.
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