The Centers for Medicare and Medicaid Services has launched a state toolkit with resources on applied behavior analysis (ABA) therapy with the goal of helping states protect children with autism.
The toolkit (PDF), a 173-page document, was informed by Medicaid data, peer-reviewed literature and stakeholder input, including state agencies, providers and advocates. The agency said the resource will help strengthen program integrity, protect children from inappropriate treatment and safeguard Medicaid and CHIP resources. The toolkit will help states address growing concerns about increasing expenses, inconsistent clinical practices and fraud schemes targeting autism care, according to CMS.
“We are helping states shut down fraud schemes that exploit children with autism and misuse funds from American taxpayers,” HHS Secretary Robert F. Kennedy Jr. said in an announcement. “This toolkit gives states practical tools that may be used to identify bad actors, protect families, and hold providers accountable. President Trump has made protecting both vulnerable children and taxpayer dollars a top priority, and we are delivering on that commitment.”
The toolkit does not establish new federal requirements or endorse any single treatment approach to ABA. Instead, CMS said it gives states practical tools to ensure every child gets individualized, evidence-based care “free from fraud and financial manipulation.” The toolkit advises that states prohibit care over a certain duration without a break, require prior auth thresholds and track clinic outcomes.
There were no specifics on which fraud schemes the administration was referring to, with CMS' announcement referring generally to “a troubling number of investigations, prosecutions, and convictions related to kickbacks and harm to children” in its announcement. A New York Times report earlier this year examined how private equity acquisitions of ABA therapy chains have led to overprescribed therapy hours, conflicts of interest and child abuse.
“We were seeing quite an explosion in costs,” Caprice Knapp, a top Medicaid official, told The New York Times on Tuesday, adding, “We want to make sure the profit motivation isn’t overtaking what’s in the best interest of children.”
CMS data show that between 2021 and 2025, ABA spending in Medicaid and CHIP increased 421%, far outpacing the 67% growth in the number of children with an autism spectrum disorder (ASD) diagnosis receiving services. In the first quarter of 2025, deal flow in behavioral health jumped more than 35% year over year, with autism deals doubling to the highest quarterly count since 2020, Fierce Healthcare previously reported.
Medicaid officials told the Times that profit-driven clinics are taking advantage of state mandates that require Medicaid to cover autism treatment. Knapp said the discrepancy in spend versus diagnoses was likely due to the overprescription of care and private equity involvement.
Over 2.3 million kids have autism. ABA therapy is one treatment modality that can involve one-on-one teaching or group instruction. Its goal is to promote positive behaviors, increase communication skills, improve attention and decrease problem behaviors.
In a statement, Lorri Unumb, CEO of the Council of Autism Service Providers and a parent of a child with autism, said that "ABA is a proven, scientific therapy" that requires a highly tailored approach, with recommended frequency varying depending on the child.
"The reasons for recent increases in Medicaid reimbursement for ABA therapy are complex," Unumb went on. "While [the] amount of care and growth of clinics contribute, there has also been a dramatic increase in diagnoses and people seeking ABA treatment in recent years."