ABA reauthorization in Florida Medicaid: the 180-day continuation request, step by step

Florida Medicaid requires authorization before ABA services begin and at least every 180 days after that¹. The behavior plan reflects the period you request, up to six months¹. Three clocks run in parallel:

The two core instruments are the Vineland-3 Comprehensive Parent Interview Form (plus the Maladaptive Behavior Domain from age 3) and the BASC-3 PRQ for ages 2 through 18¹. Assess sooner when a new behavior interferes with a major life activity or when more services are medically necessary to address it¹. A change in provider can lead to a full assessment, but a practitioner’s change of status, such as an RBT becoming a BCaBA, does not justify a reassessment¹. For the first report, see the initial assessment guide.

The 180-day sentence sits in a section of the policy written for the fee-for-service system¹. Managed care plans must meet the policy’s coverage requirements unless their AHCA contract says otherwise¹, and they set their own forms. Sunshine Health’s form, for example, has a concurrent treatment request that asks for the CDE, the referral, the latest assessment with the Vineland and BASC scoring reports, and a plan that meets sections 6.2.2 and 6.2.3⁵. It also asks for the score of the latest assessment and of the previous one⁵.

For children handled by Acentra, its manual asks for the continuation request no less than 10 and no more than 30 business days before the approval period ends, and caps an approval at 180 calendar days⁴. A 97151 request with modifier TS from the current provider is entered as a continued stay⁴. If information is missing, the provider has two business days to answer before a technical denial⁴. The manual was posted in May 2026 but its last internal review is dated 8/24, so confirm the current rules with Acentra.

A continuation packet has everything the initial report needs, plus the items of section 6.2.3¹:

• The updated behavior assessment and behavior plan, signed by the lead analyst and the parent or guardian¹.
• For each goal, whether it was met, not met or modified, with an explanation¹.
• Parent or caregiver training goals, procedures and dates¹. The parent training guide covers them.
• The supervision plan with named supervisors, and care coordination¹.
• Data on the parent or guardian’s participation in services¹.
• The IEP, or the documentation the policy allows instead, if services are delivered at school¹.
• The scoring reports of the core instruments when the 12-month point arrives¹.

Reassessment hours have a ceiling: the 2026 fee schedule pays up to 18 units of 97151 with modifier TS⁶.

The policy asks for data that reflect the progress of every behavior targeted for improvement, and each behavior under treatment must have its own data table and graph¹. Add a narrative of progress and a statement that justifies continuing care at the intensity requested¹.

If the child did not make significant clinical progress during the period, the provider must explain why and describe the treatment changes that will promote progress¹.

Section 4.2.4 lists six conditions. The policy says a child who meets one or more is considered for discharge¹:

• No longer eligible under the policy.
• No longer meets the medical necessity criteria of Rule 59G-1.010.
• No longer engages in maladaptive behaviors.
• Data show the frequency and severity of the behavior, or the level of functional impairment, no longer pose a barrier to functioning in the child’s environment.
• The level of functional impairment expressed through behavior no longer justifies continued services.
• The parent or guardian withdraws consent.

The plan itself carries a transition (fading) plan, a crisis management plan and a discharge plan¹, and they carry into each continuation because section 6.2.3 adds to section 6.2.2¹. Sunshine’s form asks for the anticipated date of transition to a lower level of care⁵.

The toolkit asks plan updates to describe the child’s response with established outcome measures rather than provider-created ones, and it suggests documenting an anticipated treatment duration with a description of a transition plan⁷. On functional discharge criteria, the meeting 4 materials mention them only on an outside presenter’s slide that points to the CMS toolkit⁹. The task force has not adopted criteria: its minutes say the concepts raised in meeting 3 were not approved recommendations⁸.

This guide follows the December 2024 policy, in effect since February 10, 2025¹². The ABA Task Force must give its recommendations by December 31, 2026¹⁰. As of October 15, 2026, AHCA’s page lists no minutes for meeting 4. Check the current policy and your plan’s requirements before each submission.