CalABA Public Policy
Fingerprinting
CalABA is gathering information about fingerprinting practices related to staff hiring, and we want to hear from agency leadership.
📝 Please complete the survey or share it with leadership at your agency. Your input will help inform CalABA’s public policy efforts.
⏱️ The survey takes approximately 5–10 minutes to complete.
👉 CalABA Fingerprinting Survey
Leadership Roundtable – OIG Audits
On May 20, 2026, agency leaders gathered to discuss the recent audits conducted by the U.S. Department of Health and Human (HHS) Office of Inspector General (OIG).
What the OIG Audits Examined
- State Medicaid (Medi-Cal) compliance with its own policies and procedures
- Improper and potentially improper payments made to providers
- Compliance and documentation issues—not clinical or medical necessity
🙏 Special thanks to Health O’Shea, Andi Waks, Chanti Waters, Becky Thompson, Mariel Fernandez, Allyson Moore, Jenna Minton, and many others who contributed their expertise and insights.
OIG Audit Findings Across States
The following audit findings were extrapolated from sampled claims reviewed by the OIG:
| State | Total ABA Payments in Audit Year(s) | Estimated Improper Payments | Federal Share |
|---|---|---|---|
| Maine (2023) | $76.7 million | $45.6 million (59.45% of total) | $28.7 million |
| Wisconsin (2021-2022) | $121.1 million | $18.5 million (15.28% of total) | $12.2 million |
| Indiana (2019-2020) | $151.1 million | $56.5 million (37.39% of total) | $39.4 million |
| Colorado (2022-2023) | $289.5 million | $77.8 million (26.87% of total) | $42.6 million |
These figures are extrapolated estimates based on audit samples reviewed by the OIG.
What Providers Can Do Now
Compliance & Policy Review
- Review payor policies, procedures, and contracts
- Review Medi-Cal BHT policies and applicable All Plan Letters (APLs)
- Review the California State Plan Amendment (SPA) related to ABA/BHT services
- Conduct regular internal documentation audits - APBA has a free resource!
- Standardize session notes (CASP templates are recommended)
Clinical Documentation Tips
- BCBAs/BCaBAs - clearly document your clinical decision-making—even when no program changes occur
- Ensure behavior technicians understand session goals and how services connect to the treatment plan
California-Specific Medi-Cal ABA Resources
- 📄 DHCS All Plan Letter (APLs) 23-010 – Guidance issued to Managed Care Plans regarding BHT services
- 🌐 DHCS Behavioral Health Treatment Website
- 📘 Behavioral Health Treatment Policy & Coverage Overview
- 🧩
California ABA/BHT State Plan Amendment (SPA)
California currently has a pending SPA related to the Fee-for-Service ABA/BHT benefit awaiting CMS approval.
Additional Training & Resources
- 📝 CASP Session Note Templates (available for all through CASP training sessions)
- 📅 CASP Webinar:
Show Your Work: Why it Matters to Make Your ABA Session Notes Count
June 1, 2026 at 11:00 AM PST - 🏛️ APBA Public Policy Corner
- 🔍
APBA Audit Preparedness Considerations
CASP 2026 Conference Resources
These presentations have been made available for $20 for those who were unable to attend the full conference.
- 📚 OIG Audits of State Medicaid ABA Programs Presented by Lonie Kim and Annie Weber (HHS OIG)
- 🚨
Heads Up! The OIG is Paying Attention. Are You Ready? Presented by Andi Waks, Jenna Minton, Mariel Fernandez, and Chanti Fritzsching Waters
CA Budget/May Revise
DHCS Proposed Changes
Utilization Management for Applied Behavior Analysis/Behavioral Health Treatment
CalABA reviewed the Governor’s May Revise Budget proposal and shared concerns with Budget Subcommittee Chairs and legislators regarding a proposed change that would require an Autism Spectrum Disorder diagnosis for individuals aged 5 and older to receive ABA services.
CalABA believes this proposal would:
- Restrict access to medically necessary behavioral health treatment
- Contradict existing DHCS All Plan Letters
- Conflict with:
- California Mental Health Parity Law (SB 855)
- Federal Mental Health Parity and Addiction Equity Act
- Federal EPSDT requirements
Proposed Medi-Cal Asset Cap Changes
Although the Governor’s May Revise did not include major ABA funding reductions, it did propose reinstating strict Medi-Cal asset limits beginning January 1, 2027:
- From $130,000 → $2,000 for individuals
- From $195,000 → $3,000 for couples
These changes could result in many individuals with disabilities and seniors losing access to Medi-Cal and IHSS.
What You Can Do
- Contact your local legislators and share concerns about the impact of these proposed changes
- Share information about CalABLE accounts with your clients, which allow eligible individuals to save up to $100,000 without jeopardizing state or federal benefits
Save the Date for our Next Roundtable!
July 29th, 2026 at 12 pm
Agency leaders are invited to participate in our next Leadership Roundtable on July 29th at 12 pm PT. We’d love your thoughts on our next topic!
📅 Roundtable Date: July 29th, 2026
🕒 12:00 - 1:00 pm PT
👉 Let us know your interest
here
(a calendar invitation will be sent as we get closer to the date)
