The Association for Behavioral Health and Wellness (ABHW) Supports the Administration’s Efforts to Decrease Fraud, Waste, and Abuse (FWA), Encourages Access to Clinically Appropriate Care

Washington, D.C. – April 2, 2026 – In alignment with the Administration’s March 16 Executive Order aimed at strengthening oversight and reducing fraud, waste, and abuse across federal health care programs, the Association for Behavioral Health and Wellness (ABHW), the national voice for payers that manage behavioral health insurance benefits for 200 million people, submitted comments on the CMS Request for Information Related to Comprehensive Regulations to Uncover Suspicious Healthcare (CRUSH), highlighting the need to reduce fraud, waste and abuse, enhance accountability and improve program integrity for clinically appropriate behavioral health care in two key areas: Applied Behavioral Analysis (ABA) and Substance Use Disorder (SUD) Residential Treatment Facilities. 

Applied Behavioral Analysis. ABHW members recognize the important role that Applied Behavior Analysis (ABA) services can play in supporting individuals with autism spectrum disorder (ASD) when delivered appropriately by qualified clinicians. However, recent oversight activity has raised program integrity concerns associated with the rapid growth in ABA utilization without clear evidence of patient functional improvement. ABHW encourages federal and state policymakers to strengthen program integrity safeguards for ABA services while preserving access to clinically appropriate care. 

SUD Residential Treatment Facilities. ABHW members remain concerned about persistent fraud, waste, and abuse within certain segments of the SUD treatment system, particularly among some residential treatment providers. Federal and state enforcement actions have identified troubling practices, including patient brokering schemes, kickbacks for referrals, and billing for medically unnecessary services or services that were not actually delivered. 

To address these concerns, ABHW recommends the following: 

• Ensure all facilities are appropriately licensed and accredited to provide SUD services. 
• Identify, disseminate, and adopt quality standards, best practices, and model policies to support appropriate levels of care and treatment. 
• Strengthen oversight and enforcement related to fraudulent administrative and billing practices. 

As policymakers address fraud, waste, and abuse, it is essential to ensure limited resources are directed to clinically appropriate services that deliver meaningful outcomes. At the same time, oversight must be carefully calibrated to avoid indiscriminately cutting valuable services that patients rely on. ABHW and its members are committed to working with partners to strengthen program integrity while preserving access to high-quality behavioral health care.