CMS orders all 50 states to submit provider revalidation plans
Read the full entry belowThe federal government is auditing state Medicaid ABA programs one by one, and every audit so far has come back the same way. In 2022 the HHS Office of Inspector General announced a series of reviews of Medicaid ABA payments. Four are now public: Indiana, Wisconsin, Maine, and Colorado. In each one, all 100 sampled enrollee-months contained at least one improper or potentially improper claim, and the recommended federal refunds now exceed $123 million combined.
The audits are aimed at the states, not directly at providers, but providers feel the recoupment. The findings are consistent across every state: session notes that do not support the time billed, missing signatures, billing codes that do not match the documentation, and services delivered by uncredentialed or undersupervised technicians. In Colorado, auditors estimated that 1,500 to 2,000 technicians may have been working without the required training and supervision. These are documentation and credentialing failures, not findings of fraud, but they are exactly the failures that convert into clawbacks when a state acts on them.
Behind the audits is an explosion in spending that drew the scrutiny. ABA payments in the audited states rose at rates from roughly 100 percent to over 1,300 percent in a few years. That growth, and a Wall Street Journal investigation documenting some providers billing hundreds of dollars an hour, put the benefit on the radar of federal auditors, Congress, and the Department of Justice at once.
The pressure is now spreading past the four audited states. In April 2026 CMS directed all 50 state Medicaid programs to submit provider revalidation plans within 30 days, the House Energy and Commerce Committee opened investigations touching eleven states, and commercial payers began adopting parallel documentation requirements. The OIG has said more state audits are coming and the series has no set end. This dossier tracks the audit sweep and the state and federal responses it is driving.
Timeline, newest first
- 2026-04-21Live
CMS orders all 50 states to submit provider revalidation plans
Acuity, OIG Medicaid ABA auditsCMS Administrator Mehmet Oz announced that all 50 state Medicaid programs must submit plans to revalidate their providers within 30 days, calling ABA billing a massive problem. In parallel, the House Energy and Commerce Committee opened investigations touching eleven states, and the Department of Justice brought criminal charges against the owners of a Minnesota based ABA center. The audit pressure, which began as four state reviews, is now a national program integrity push that reaches every state.
- 2026-03-02
Colorado audit: $77.8 million improper, all 100 sampled months flagged
HHS OIG, Colorado ABA audit (A-09-24-02004)The OIG found Colorado made at least $77.8 million in improper fee-for-service Medicaid ABA payments in 2022 and 2023, with another $207 million potentially improper, and recommended a $42.6 million federal refund. Every one of the 100 sampled enrollee-months contained an improper or potentially improper claim. Auditors estimated 1,500 to 2,000 technicians may have been working without the required 40-hour training, competency check, and supervision. Colorado's ABA spending had risen from $60.1 million in 2019 to $163.5 million in 2023. The state disputed the refund amount but agreed to issue additional billing guidance.
- 2025-07-10
Wisconsin becomes the third audit; the pattern holds
HHS OIG, ABA audit seriesThe OIG published its Wisconsin audit, identifying $18.5 million in improper payments and $94.3 million in potentially improper payments for 2021 and 2022, with a recommended federal refund of $12.2 million. As in Indiana before it, all 100 sampled enrollee-months contained at least one improper or potentially improper claim. Maine's audit followed, with a $28.7 million recommended refund. The consistency across states signaled that the problem was systemic oversight gaps, not isolated provider misconduct.
- 2024-12-26
The first audit lands: Indiana, and every sampled month is flagged
HHS OIG, ABA audit seriesThe OIG published the first audit in the series, covering Indiana. It estimated at least $56 million in improper fee-for-service Medicaid ABA payments for 2019 and 2020, plus $76.7 million in potentially improper payments, and recommended Indiana refund $39.4 million as the federal share. Every one of the 100 sampled enrollee-months contained an improper or potentially improper claim. Deficiencies included unsupported CPT code billing, missing session notes and signatures, and insufficient state oversight. Indiana later began re-auditing the same dates of service and recouping from providers directly.
- 2022-01-24
The OIG announces it will audit ABA in a series of states
HHS OIG, ABA audit seriesThe OIG announced a series of audits of state Medicaid ABA payments, citing questionable billing patterns and payments for unallowable services. The series was structured to examine whether state Medicaid agencies' ABA payments complied with federal and state requirements. Project titles were held unpublished until each report posted. What began as a work-plan entry became, over the following years, the most consequential federal scrutiny the ABA industry has faced.
ABAWiser provides research, analysis, and compliance advisory services. We are not a law firm, we do not provide legal advice, and no engagement creates an attorney client relationship. Dossiers track developments as they occur and may be incomplete or updated as a story evolves. Confirm any statutory or regulatory point against the primary source before acting on it.