ABA Demand Isn’t the Problem. Execution Is. Here’s What Top Providers Do Differently.

Scrutiny of ABA billing intensified in 2026. CentralReach's revenue cycle management team reported an unprecedented increase in audits among its customers. At the federal level, the HHS Office of Inspector General completed additional state audits in Maine and Colorado as part of its ongoing review of Medicaid payments for ABA and related services.

In each audit, all 100 sampled enrollee-months contained at least one claim line classified as improper or potentially improper. Documentation was a recurring issue, with findings citing insufficient session notes, missing signatures, and unclear evidence of billable time.

An improper payment isn't necessarily evidence of fraud. It can result from documentation, billing, credentialing, or other compliance gaps. But the financial consequences can still be serious: even clinically appropriate care may face denials, payment delays, or recoupment if the documentation doesn't clearly show the service met payer requirements. Providers that stay audit-ready will be the ones that document correctly the first time.

Delivery also depends on people. Staffing gaps limit capacity and disrupt continuity of care, and the gains from improving retention are significant: across the organizations in our data, a 10-percentage-point improvement in turnover would mean approximately 10,000 more people staying with their organizations. Caregiver training is another opportunity.