CMS Launches New State Toolkit to Protect Children with Autism, Strengthen Oversight of Applied Behavior Analysis Services

CMS Launches New State Toolkit to Protect Children with Autism, Strengthen Oversight of Applied Behavior Analysis Services

Resource supports child-centered, evidence-based care while strengthening program integrity, protecting children from inappropriate treatment, and safeguarding Medicaid and Children's Health Insurance Program (CHIP) resources

Children with autism deserve care that is individualized, effective, and free from fraud and financial exploitation. To help states meet that standard, the Centers for Medicare & Medicaid Services (CMS) released the State Medicaid and Children's Health Insurance Program (CHIP) Applied Behavior Analysis (ABA) Toolkit, a comprehensive resource to help state Medicaid and CHIP agencies address growing concerns about increasing expenditures, inconsistent clinical practices, and fraud schemes targeting autism services.

"We are helping states shut down fraud schemes that exploit children with autism and misuse funds from American taxpayers," HHSSecretary Robert F. Kennedy, Jr., said. "This toolkit gives states practical tools that may be used to identify bad actors, protect families, and hold providers accountable. President Trump has made protecting both vulnerable children and taxpayer dollars a top priority, and we are delivering on that commitment."

"Every dollar lost to fraud or waste is a dollar that cannot reach a child who genuinely needs it," said CMS Administrator Dr. Mehmet Oz. "Families deserve confidence that ABA services are clinically appropriate, personalized, and delivered by qualified providers, and this toolkit is our commitment to help states make that a reality."

CMS data shows that between 2021 and 2025, ABA spending in Medicaid and CHIP increased 421%, far outpacing the 67% growth in the number of children with an autism spectrum disorder (ASD) diagnosis receiving services. That disparity is not just a fiscal concern. It raises important questions about whether Medicaid resources are consistently supporting medically appropriate care. It also signals that rapid program growth requires stronger oversight to ensure children receive services based on medical need rather than financial incentives. A troubling number of investigations, prosecutions, and convictions related to kickbacks and harm to children have raised serious fiscal and oversight concerns.

This toolkit is not a restriction on autism services. It does not establish new federal requirements; reduce Early and Periodic Screening, Diagnostic, and Treatment (EPSDT) obligations; endorse any single treatment approach to ABA; or direct states to limit access to medically necessary care. Rather, it gives states practical tools to help ensure that every child receiving ABA services gets individualized, evidence-based care that is free from fraud and financial manipulation and is delivered by qualified providers.

The ABA toolkit provides states with useful information and suggested practices across key policy and operational areas, including:

• Helping ensure children receive ABA services that are medically necessary, individualized, and appropriate for their clinical needs.
• Helping states support treatment intensity that reflects each child's clinical needs rather than standardized service models.
• Protecting families by helping states ensure ABA providers are qualified and properly supervised.
• Promoting responsible stewardship of taxpayer dollars by discouraging unnecessary or inappropriate services.
• Helping to ensure states' ability to identify fraud, waste, and abuse, and other improper billing practices.
• Helping states continue providing medically necessary autism services to eligible children through Medicaid.

The toolkit addresses a wide range of operational and policy considerations - from clinical standards and Medicaid benefit design to payment methodologies, provider enrollment, credentialing, utilization management, and program integrity strategies designed to identify fraud, waste, and abuse. A checklist is included to help states assess whether their ABA policies support effective implementation, strong oversight, and responsible stewardship of Medicaid funds. States are encouraged to use this toolkit to inform decision-making with the understanding that solutions will vary based on their unique program structures, populations, and priorities.

The toolkit is informed by Medicaid data, peer-reviewed literature, and broad stakeholder engagement. It draws on a targeted review of more than 40 literature sources; an assessment of more than 240 publicly available state-level Medicaid coverage and policy references; and qualitative input from a broad range of state agencies, providers, advocates, and other stakeholders.

CMS will continue working with states to strengthen oversight of ABA services, protect children and families, promote evidence-based care, and ensure Medicaid resources are directed toward medically necessary services that improve outcomes for children with autism.

The ABA toolkit is available at: https://www.medicaid.gov/medicaid/downloads/autism-services-aba-toolkit.pdf

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