CMS Lays Out New Guidance for ABA Medicaid Benefits
By Chris Larson | August 5, 2026
Photo by The White House on Wikimedia Commons (Official White House Photo by Molly Riley)
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Autism/IDD
The Centers for Medicare & Medicaid Services (CMS) has released a comprehensive 173-page guide for state Medicaid programs to navigate the reassessment of Applied Behavior Analysis (ABA) coverage and oversight.
Clinical Standards and Provider Credentialing take up much of the document, offering a detailed examination of federal expectations for regulators and providers treating Medicaid patients. While the guide has no prescriptive authority, it presents widely accepted clinical practices and ideal objectives.
CMS Administrator Dr. Mehmet Oz highlighted the toolkit’s role in fraud prevention:
“Every dollar lost to fraud or waste is a dollar that cannot reach a child who genuinely needs it… This toolkit is our commitment to help states ensure ABA services are clinically appropriate, personalized, and delivered by qualified providers.”
Despite its title, "State Medicaid & Children’s Health Insurance Program Applied Behavior Analysis Toolkit," the guide emphasizes that CMS does not mandate ABA coverage. It attributes the explosive growth in ABA spending (from $1.94 billion in 2021 to $10.1 billion in 2025) and utilization (a 189% increase in children receiving ABA services versus a 67% increase in ASD diagnoses) to various factors, including increased incidence rates and substandard billing practices.
Industry responses were varied:
Lorri Unumb, CEO of the Council of Autism Service Providers (CASP), defended ABA’s use, citing its evidence-based effectiveness and acknowledging the complex interplay between increased spending, utilization, and rising ASD incidence rates.