Earlier this month, the Centers for Medicare & Medicaid Services (CMS) released the State Medicaid and Children’s Health Insurance Program (CHIP) Applied Behavior Analysis (ABA) Toolkit, a resource to help state Medicaid and CHIP agencies address concerns about rising expenditures, inconsistent clinical practices, and fraud schemes targeting autism services.

CMS data shows that between 2021 and 2025, ABA spending in Medicaid and CHIP increased by 421 percent, outpacing the 67 percent growth in the number of children with an autism spectrum disorder (ASD) diagnosis receiving services. According to the news release, this raises questions about whether Medicaid resources consistently support medically appropriate care. CMS stated that a troubling number of investigations, prosecutions, and convictions related to kickbacks and harm to children have raised serious fiscal and oversight concerns.

The toolkit aims to give states practical tools to ensure that each child receiving ABA services receives personalized, evidence-based care that is free from fraud and financial manipulation, delivered by qualified providers. 

The ABA toolkit provides states with information and suggested practices on 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 relying on standardized service models. 
• Protecting families by helping states ensure that ABA providers are qualified and properly supervised. 
• Promoting responsible stewardship of taxpayer dollars by discouraging unnecessary or inappropriate services. 
• Helping ensure states can identify fraud, waste, and abuse, as well as other improper billing practices. 
• Helping states continue to provide medically necessary autism services to eligible children through Medicaid.

A checklist is included to help states assess whether their ABA policies support effective implementation, strong oversight, and responsible stewardship of Medicaid funds.

The toolkit draws on Medicaid data, peer-reviewed literature, and broad stakeholder engagement, CMS noted.