Washington D.C. – The Association for Behavioral Health and Wellness (ABHW) today welcomed the Centers for Medicare & Medicaid Services’ (CMS) release of its State Medicaid & Children’s Health Insurance Program Applied Behavior Analysis (ABA) Toolkit, calling it an important step toward strengthening the quality, consistency, and accountability of ABA services for individuals with autism spectrum disorder (ASD).
“ABHW applauds CMS for focusing on what matters most, ensuring individuals receive high-quality, evidence-based care that delivers meaningful outcomes,” said Debbie Witchey, President and CEO of ABHW. “As research continues to evolve, we know ABA remains an important treatment option for many individuals with autism, but it is not the only evidence-based intervention, and more services are not always better. Care should be individualized, guided by clinical evidence, measurable progress, and unique needs.”
While ABHW continues to review the 173-page toolkit, the association is encouraged that many of the recommendations it shared with CMS are reflected in the guidance. These include requiring individual National Provider Identifiers (NPIs) for all ABA providers, strengthening provider supervision requirements, emphasizing measurable treatment goals and ongoing reassessment, reinforcing caregiver involvement, and enhancing safeguards against fraud, waste, and abuse.
“Requiring individual NPIs for all providers, which would include Registered Behavior Technicians (RBTs), is a significant step toward greater transparency and accountability,” Witchey said. “Combined with stronger supervision standards and a greater focus on documenting clinical progress, these recommendations will help ensure Medicaid beneficiaries receive appropriate, high-quality care while protecting the integrity of the program.”
ABHW also commended CMS for emphasizing individualized treatment planning, interdisciplinary care coordination, ongoing assessment of treatment effectiveness, and evidence-based decision-making rather than a one-size-fits-all approach to care.
“We appreciate CMS’s recognition that treatment decisions should be based on an individual’s unique clinical needs and functional progress, not predetermined hours of care or a single treatment model,” Witchey said. “This toolkit provides states with a thoughtful framework for improving quality, supporting families, and ensuring Medicaid resources are invested in care that makes a meaningful difference.”
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ABOUT THE ASSOCIATION FOR BEHAVIORAL HEALTH AND WELLNESS
ABHW is the leading health plan association working to improve access and quality of care for mental health and substance use disorders. ABHW’s members include national and regional health plans who care for approximately 200 million people. Together, we work to reduce stigma and advance federal policy on mental health and substance use disorder care. ABHW member companies include Aetna Behavioral Health, Elevance Health, Centene Corporation, Evernorth, a Cigna company, Health Care Service Corporation, Kaiser Permanente, Lucet, Magellan Health, Molina Healthcare, Optum, and PerformCare, a subsidiary of AmeriHealth Caritas. To learn more, visit www.abhw.org and follow us on BlueSky and LinkedIn.
