ABA rate cuts and hour caps in other states' Medicaid in 2026, and what Florida could copy

Indiana says its changes aim to strengthen program integrity, promote sustainability and support consistent service delivery¹. Since April 1, 2026:

• Rates. Maximum fees for individual ABA codes fell 6%, and a further 4% cut on all ABA codes is set for April 1, 2027. For 97153 by an RBT, the 15-minute rate goes from $17.06 to $16.04, then $15.39¹.
• Lifetime allocation. Comprehensive ABA, 16 or more hours a week, is allocated up to 4,000 hours per lifetime, then up to 15 hours a week of targeted ABA. More comprehensive ABA is covered under EPSDT if a later review finds it medically necessary, and 97155 and 97156 do not count¹.
• Age. ABA is covered only through EPSDT, for members under 21, and since October 1, 2026 Indiana no longer pays it for members 21 and older¹.
• Supervision. At least one hour per eight technician hours, per child, measured monthly and subject to postpayment review¹².
• Telehealth. 97151, 97152, 97153, 97154 and 0373T can no longer be billed by telehealth. Video supervision may supplement, not replace, in-person oversight¹².
• Caregivers. Every authorization request must include caregiver coaching, up to 18 hours per six months¹.

Under a federal rule for provider types at high risk of fraud, waste or abuse³, CMS approved Indiana’s enrollment pause: since June 6, 2026, no new ABA groups or ownership changes are enrolled, for six months that can be extended, while individual clinicians can still enroll⁴. Exceptions require accreditation, and every ABA group must be accredited by ACQ or BHCOE by October 1, 2027⁴⁵.

For eligible people under 21, federal law includes in EPSDT the treatment needed to correct or ameliorate conditions found through screening, whether or not the state plan covers it¹⁵. The CMS toolkit of August 2026 says states may not apply hard limits, meaning limits that can never be exceeded, to EPSDT services, but may use prior authorization and medical necessity reviews¹⁶. Indiana’s allocation has an EPSDT review path¹, and these limits also allow more care:

• Virginia. The 2026 Appropriation Act orders a 20-hour weekly limit per recipient that documented medical necessity under EPSDT can exceed, plus an autism diagnosis, provisional for up to one year at age 5 or younger⁶. DMAS says authorizations will not change until CMS approves⁶. The amendment it sent on August 7, 2026 proposes October 1, 2026⁷.
• Nebraska. Since February 7, 2025, up to 6 hours a day and 30 a week, with requests for more reviewed for medical necessity⁸.

Whether a specific cap complies with EPSDT is a legal question for each state.

• Nebraska adjusted its rates on August 1, 2025 to align with nearby states, citing federal efficiency and economy standards. It said its rates had been significantly higher than other state Medicaid programs, some more than twice as high, and that its ABA spending rose from about $4.6 million in 2020 to $85.6 million in 2024. It set 97153 at $18.70 and 97155 at $22.72 per 15 minutes⁹²⁴.
• North Carolina cut its research-based intensive behavioral health treatment codes (97151 to 97157) by 10% on October 1, 2025, to stay within the funding the General Assembly provided¹⁰.
• New York asked CMS to lower the rate for adaptive behavior treatment by unlicensed technicians from October 1, 2025, to pay providers equitably for training and experience, and said it did not expect a significant drop in services¹².

Not every state cut. Utah’s SB 160 made permanent a mechanism that, when its General Fund growth factor is 102% or more, gives each ABA rate substantially the same yearly percentage increase as the per-member payments to its Medicaid plans¹³.

• North Carolina. In a December 10, 2025 update, the state said court rulings required it to reverse the cuts and restore its September 30, 2025 rates. It added that the cuts had been necessary to keep Medicaid solvent, with a $319 million funding gap¹¹.
• Nebraska. Providers objected to the hour guideline, to supervising RBTs at 10% to 20% and to 2 to 4 hours a month of caregiver involvement. The state kept the cap with a medical necessity exception and said it would not deny coverage for lack of caregiver involvement alone⁸.
• Florida. Public comment at the task force meeting of September 28 covered access to care, treatment-planning requirements, diagnostic evaluations and administrative burden¹⁸. A provider presentation in the October 5 materials argued that more hours are not inherently better and fewer hours not inherently worse, and that spending growth alone does not establish unnecessary care¹⁹.

On the integrity side, MassHealth requires an hour of supervision per 10 hours of direct service, and in 2024 its Inspector General estimated overpayments of up to $17.3 million, including $16,761,445 in claims that missed that ratio¹⁴.

Florida’s ABA task force must evaluate limits on how long ABA can be authorized, potential caps on months of service, and enrollment and billing standards²⁰. On August 31, AHCA showed it a state comparison that included Indiana’s lifetime limit and Virginia’s justification rule above 20 hours a week¹⁷.

We found no proposal for a new moratorium or a rate cut in the task force documents published through October 16, 2026.

• Indiana: second rate cut on April 1, 2027; accreditation by October 1, 2027; the moratorium can be extended in six-month steps¹⁴⁵.
• Virginia: DMAS said in July 2026 that the limit awaits CMS approval and that it will announce the date⁶.
• North Carolina: rates are back at September 30, 2025 levels¹¹.
• Florida: the coverage rule in force dates from February 10, 2025, and the task force report is due December 31, 2026²²²⁰. None of these ideas is adopted. For rates, see the 2026 fee schedule.

This is not legal or billing advice. If another state’s change affects your patients or contracts, confirm with that state’s Medicaid agency, your plan or a health care attorney.