Payer and Medicaid Rules · Fixed Scope

What each state requires, and how your operation lines up.

State-by-state payer and Medicaid rules, organized, cited, and mapped to how you bill, staff, and document. Your counsel advises on how the rules apply to you.

Already received a notice from a payer or regulator? Your first call is your counsel.

Book a free 30 minute scoping call
By state
The rules you actually operate under
Mapped
To how you bill and staff
Cited
Every position to primary law
Written
A brief you can act on

Where operators get surprised.

The change

The rule moved on its own date

Payer manuals, amendments, and policies change on their own schedules. What you assumed once may not be what applies now.

The roster

Who can deliver, supervise, and bill

Which staff can do what, under which credential, differs by state and by payer. The assumption gets built into the schedule and rarely checked.

The assumption

Where the service is delivered

Where a service is delivered can decide whether it is paid. The assumption is usually made once and never tested.

What you get.

01

The rules, by state

What each payer and Medicaid program requires for the states you operate in, organized and cited to the source.

02

Mapped to your operation

Your billing, staffing, and documentation lined up against those rules, with the gaps named.

03

A written brief

Every position cited to primary law, so you can act on it or hand it to your counsel.

04

A fixed scope

Agreed before anything starts. No meter running. If the work is bigger than the question, I say so before I begin, not halfway through.

Where it fits.

The research is published free. The Wire tracks payer and enforcement changes, dated and cited.

The rulesMedicaid and insurance analysis, by stateWhat each state's Medicaid program and the payers inside it require for ABA, cited to the source.
The licenseLicensing rules, by stateWho can deliver, supervise, and bill depends on the credential, and the credential depends on the state.
Where it is deliveredPlace of serviceWhere a service is delivered can decide whether it is paid. This is the method for checking it payer by payer.
The recordHow Georgia's Medicaid plans repriced ABAThe verified record of the 80 percent cut, how the amendments were executed, and what the audit and revalidation exposure looks like.
LiveGeorgia's dominant Medicaid payer cuts ABA rates 20%CareSource Georgia cut ABA reimbursement to 80 percent of the state Medicaid fee schedule in March 2026.
LiveFederal auditors are sweeping state Medicaid ABA programs, and the refunds are stacking upHHS audits of Indiana, Wisconsin, Maine, and Colorado found improper Medicaid ABA claims in every sampled month.

This engagement applies all of it to how you actually bill. To see what is exposed in your records before the rules are mapped, a compliance audit comes first.

Steve Antico, Garfunkel Wild

Operating ABA Clinics for Payment Scrutiny With Steve Antico - Partner Director Garfunkel Wild

Feb 24, 2026
Listen

Which states are you looking at?

Tell me the states and how you bill. I will tell you whether this is work I can do and what it takes, before anything starts.

Book a free 30 minute scoping call

Engagements are business and compliance advisory, delivered alongside your counsel, who provides legal advice. Nothing here is legal advice. No engagement creates an attorney-client relationship.