New Regulations Will Negatively Impact Access to Medically Necessary ABA for Children with Autism and Down Syndrome
On December 11, 2025, Carelon/MBHP distributed the 2026 Medical Necessity Criteria and Performance Specifications for Applied Behavioral Analysis (ABA). These changes go into effect February 15, 2026 and represent a substantial deviation from current regulations, which will negatively impact access to medically necessary ABA for children with autism and down syndrome.
MPAAQ has many concerns with these new policies, which have not been presented for public comment, but the most significant concerns include:
- Increasing minimum age for behavior technicians (paraprofessionals) from 18 to 21.
- Excessive assessment requirements to obtain prior authorization for treatment
- Excessive requirements for center-based ABA services
- Limiting access to group instruction (a cost-effective and less restrictive level of care) to less than half the national standard.
MPAAQ understands the necessity of policy and regulations to protect quality of ABA services and to ensure the MassHealth program is financially sustainable. MPAAQ is eager to partner with MassHealth and EHHS on policy that protects both access and quality of ABA services in the commonwealth.
“However, MPAAQ cannot stand by silently when major policy changes are released at the last minute, without public comment,” said Ashley Williams, PhD, LABA, BCBA-D, Board Member, MPAAQ Board of Directors. “These changes will make it even harder for families to access critical services.”
The new policy limits access to care for current (and future) clients by introducing new and excessive assessment requirements to authorize treatment and overly stringent expectations to justify center-based ABA services.
“These requirements are not in line with our field’s generally accepted standards of care and will lead to children accessing lower doses of treatment and potentially discharging prematurely,” said Rebecca Thompson, PhD, BCBA-D, Chair of MPAAQ.
Further, MassHealth is limiting group instruction, a cost-effective and less restrictive model of treatment, to less than half of federal policy. The Centers for Medicare & Medicaid Services (CMS) establishes guidance on the typical maximum number of units a service code may be used per day, called Medically Unlikely Edits (MUE’s). When medically justified, a higher number of service units may be delivered per day. The CMS MUE for group treatment is 18 units (of 15 minutes each) or 4.5 hours, but MassHealth will be limiting this service to 2 hours per session and a total of 10 hours per week.
ABA is an effective and well-researched method of teaching children with developmental differences a variety of skills related to communication, social interaction, motor skills, and problem solving. This therapeutic approach has been proven to improve the functional capabilities of children diagnosed with autism and Down syndrome by systematically breaking down challenging tasks into smaller components. Research shows that for the autism population, ABA services can save the commonwealth more than $2 million per child over their lifetime.
In addition, increasing the age requirements for behavior technicians – who are front-line staff – immediately reduces MPAAQ members’ potential workforce by 20 percent. These ABA providers already face a direct care workforce shortage, and this new policy exacerbates this issue. It will also increase costs, as people who have been in the workforce longer will require higher wages to compensate for their experience. Demand for services will increase in 2026, as new law goes into effect mandating coverage for ABA for Down Syndrome, in addition to autism. This new policy restricts MPAAQ members’ potential workforce, just as thousands more individuals will be eligible for care.
About the Massachusetts Providers for ABA Access and Quality (MPAAQ) :
The Massachusetts Providers for ABA Access and Quality (MPAAQ) is the dedicated, nonprofit trade association representing organizations who render ABA services across the Commonwealth. We champion evidence-based, equitable ABA services, working to ensure strong policies that uphold clinical integrity, workforce sustainability, and meaningful outcomes for individuals and families. Learn more at www.mpaaq.org
Sources:
Jacobson, J. W., Mulick, J. A., & Green, G. (1998). Cost-benefit estimates for early intensive
behavioral intervention for young children with autism—general model and single state case.
Behavioral Interventions, 13(4), 201–226.
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