During the last state budget process, families advocated successfully for a Medicaid benefit to cover applied behavior analysis (ABA) treatment for Medicaid recipients. Approximately $42 million was dedicated to the Department of Healthcare and Family Services (DHFS) budget to cover the benefit. DFHS has submitted a state plan amendment to the federal government to add this behavioral treatment service to the Medicaid state health plan. DHFS is now asking stakeholders to comment on a recently released pubic notice about the benefit.

Based on the released DHFS public notice, the Coalition has several concerns with barriers being created that will limit Medicaid recipients’ access to applied behavior analysis (ABA) treatment in Illinois.

(1) Extremely limited provider types – the only two provider types DHFS states can provide ABA treatment services are licensed social workers or a doctorial level licensed clinical psychologist who is also a board certified behavior analyst (BCBA-D). This means masters level BCBAs could not direct and supervise ABA treatment programs under the new Medicaid benefit. Currently, all health insurance plans in Illinois allow masters level BCBAs to direct and supervise ABA treatment programs without being licensed or supervised. Many Medicaid programs in other states allow unlicensed, masters level BCBAs to provide ABA treatment.

Concern: If this benefit is implemented with only two provider types,  Medicaid recipients will be severely restricted in the number of providers that can provide ABA treatment services, putting Medicaid recipients on extremely long waitlist compared to their non-Medicaid insured peers.

Our Ask:  We are asking DHFS add board certified behavior analyst (BCBA) to the list of providers types who can direct, supervise and render ABA treatment services. We are also asking for board certified assistant behavior analyst (BCaBA) who are supervised by BCBA/BCBA-D be added as a provider type that can supervise and render services.  We believe if a licensed social worker will be directing and supervising ABA treatment programs, they need to prove ABA treatment is in their scope of practice.

(2) Not utilizing the recognized Tiered Service-Delivery Model for ABA. DHFS is not utilizing the common tiered service-delivery model currently used in employer-based health insurance around the state and country including our state’s autism mandate. This delivery model is authored in the Practice Guidelines for Applied Behavior Analysis Treatment of Autism Spectrum Disorder by the Behavior Analyst Certification Board and noted in the Model State Plan Amendment (SPA) document developed by the Autism Legal Resource Center and Association of Professional Behavior Analysts.

The Tiered Service-Delivery Model for ABA Treatment services can be:

  • Directed, supervised or rendered by BCBAs and BCBA-Ds; 
  • Rendered or supervised by BCaBAs who are under the supervision of a BCBA or BCBA-D and;
  • Rendered by Behavior Technicians or Registered Behavior Technicians (or equivalent credential) who are under the supervision of a BCBA, BCBA-D or BCaBA.

Concern: Without recognizing the appropriate tiered service-delivery model, Medicaid recipients will be placed on extremely long waitlist and will struggle accessing services in their own communities.

Our Ask: DFHS needs to authorize and reimburse ABA treatment services through the recognized tiered service-delivery model as is currently done under employer-based health insurance and the Illinois autism insurance mandate law.

We need your Advocacy! Please consider sending a quick email regarding the above-mentioned concerns to the e-mail address: HFS.bpra@illinois.gov.  Please contact us if you have any questions or comments. Please consider sharing the responses you receive with us by calling 614.565.5765 or through our contact page.