Part II: The CMS autism toolkit is a build spec in disguise: where the 421 percent ABA spending curve creates real openings in UM, credentialing, documentation, and payment integrity

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Part II: The CMS autism toolkit is a build spec in disguise: where the 421 percent ABA spending curve creates real openings in UM, credentialing, documentation, and payment integrity

Aug 06, 2026

∙ Paid

ABA spending in Medicaid grew 421% from 2017 to 2022. Children served grew 66%. That gap is hours and billing. And it is a software problem.

The structural flaw: RBTs deliver the care. BCBAs own the NPI on the claim. The claim literally does not know who was in the room. Every integrity product hits this wall.

The enforcement pattern is consistent: BCBAs …

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