Medicaid reimbursement for applied behavior analysis (ABA) is in flux across the country – in terms of rates, documentation, and compliance requirements. And because Medicaid is primarily a state responsibility, approaches to managing Medicaid ABA services vary. 

Minnesota has been at the center of changes to Medicaid autism service oversight with federal intervention in response to claims of fraudulent billing (see  Minnesota Medicaid Autism Treatment Authorization Backlog Reaches 1,000 Treatment Plans). By mid-August, approximately 1,000 autism treatment plans were awaiting authorization, delaying care for families and preventing provider organizations from billing Medicaid for affected services.

In April 2026, North Carolina enacted legislation imposing new restrictions on Medicaid autism treatment, including limits on out-of-state provider enrollment and telehealth, additional supervision requirements, and mandatory national certification for…