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 with more than 24 hours of claims in a single day. Telehealth billed at the in-home rate. Credentials lapsed months ago still generating claims.
CMS just handed 50-plus state agencies a shared vocabulary for medical necessity, provider qualification, and fraud detection. States with budget problems will move fast. The blunt instruments are legally fragile. The defensible ones require software.
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