The Signal Is Now a Mandate
For years, accreditation in ABA was optional — a gold star you could pursue if you wanted to signal quality. That era is ending.
In October 2024, Massachusetts became the first state to mandate third-party accreditation for Medicaid-funded ABA providers. Under the new rule, MassHealth managed care organizations can only contract with accredited providers. Center-based providers must be accredited by January 1, 2027. All other providers — including new entrants — by January 1, 2028.
This isn’t a suggestion. It’s a condition of doing business with the state’s Medicaid program.
Why Massachusetts Moved First
The mandate didn’t come out of nowhere. It followed a wave of fraud enforcement.
In October 2023, Massachusetts AG Andrea Joy Campbell announced $2.5 million in fraud settlements with two ABA providers — one for billing services provided by unqualified staff, the other for billing services that were never rendered. Both were required to fund independent compliance monitoring programs for three years.
Then in June 2025, the AG’s office indicted another Medicaid-enrolled ABA provider for allegedly fabricating documentation to support over $1 million in false claims.
MassHealth’s own investigations found that its managed care entities lacked “robust program integrity measures.” The accreditation mandate is the state’s answer: if you want Medicaid dollars, prove you meet a third-party standard.
Massachusetts Isn’t Alone in Finding Problems
Federal auditors are finding the same issues everywhere:
| State | Finding |
|---|---|
| Indiana | HHS OIG found at least $56 million in improper Medicaid payments for ABA (2019–2020). The state’s ABA Medicaid spending has grown to a projected $574 million/year — a 2,800% increase. Auditors found providers billing excessive hours, including “during nap time.” |
| Wisconsin | Federal audit identified at least $18.5 million in improper Medicaid payments (2021–2022). |
| Minnesota | 85 open investigations into autism providers as of summer 2025. The FBI raided two providers. A woman was charged with wire fraud in a $14 million Medicaid scheme. |
| North Carolina | ABA Medicaid spending surged from $122 million (FY2022) to a projected $639 million (FY2026) — a 423% increase. |
| Nebraska | Implemented a 30-hour/week cap and cut payments by nearly 50% after a 1,700% spending jump. |
The pattern is clear: explosive spending growth draws scrutiny, scrutiny uncovers fraud, and fraud triggers regulation. Massachusetts just reached the “regulation” step first.
One Accreditation Body to Rule Them All
Until recently, ABA practices had two accreditation options: the Autism Commission on Quality (ACQ), run by the Council of Autism Service Providers (CASP), and the Behavioral Health Center of Excellence (BHCOE), which rebranded to Jade Health in 2024.
That changed in December 2025 when CASP acquired Jade Health — including BHCOE’s approximately 1,500 accredited clinics.
CASP plans to merge the best elements of both programs into a single unified standard under the ACQ name. Existing BHCOE accreditations will be honored during the transition.
This consolidation matters for two reasons:
- It simplifies the path. One accreditation body means one set of standards to prepare for, one application process, one relationship to manage.
- It accelerates the mandate. A fragmented accreditation landscape was one argument against mandating it. That argument is gone.
CASP CEO Lorri Unumb has noted “an increasing number of states and health plans are mandating accreditation as a condition of participation in clinical networks” — and expects that number to “exponentially increase.”
Other States Are Watching
No other state has formally mandated accreditation yet. But the pressure is building from multiple directions.
Legislators and regulators “tend to copy or borrow concepts from other states,” and Massachusetts’ model provides a ready-made template. Indiana’s Governor has already created a working group to address ABA oversight. New York has a bill proposing hour caps. North Carolina nearly implemented rate cuts before the governor intervened.
CASP VP of Government Affairs Mariel Fernandez put it bluntly: “State Medicaid agencies communicate with each other. Issues in Indiana have already impacted other states.”
The question isn’t whether more states will follow. It’s when — and whether your practice is ready when they do.
What Accreditation Actually Requires
ACQ/BHCOE accreditation evaluates four broad areas:
- Clinical quality — Evidence-based practices, individualized treatment plans, measurable outcomes, and structured data collection
- Staff qualifications — Proper credentialing for BCBAs and RBTs, ongoing supervision documentation
- Ethical practices — Client confidentiality, informed consent, incident reporting
- Client and family satisfaction — Communication quality, family involvement, treatment outcomes
The process involves an internal self-assessment, application submission with supporting documentation, an onsite review with staff interviews and client observation, an outcome report, and ongoing monitoring. Accreditation cycles last two years.
The most common obstacles practices face? Incomplete documentation systems, inconsistent data collection, and credential tracking gaps — the exact operational problems that compound during staff turnover.
How to Start Preparing Now
You don’t need to wait for your state to issue a mandate. Practices that prepare early will have a significant advantage — both in the accreditation process itself and in payer negotiations.
Audit your documentation. Do you have standardized templates for assessments, treatment plans, progress reports, and discharge summaries? BHCOE Standard 101 requires a standard clinical assessment report template. If your documentation is inconsistent across clinicians, that’s your first fix.
Formalize your data collection. Accreditation bodies want to see prescribed procedures for what data you collect, how you collect it, how often, and how you ensure accuracy and reliability. Ad hoc data collection won’t pass review.
Get credential tracking airtight. Every staff member’s credentials, supervision hours, and training records need to be current, centralized, and auditable. Manual spreadsheets break down at scale.
Review your policies. Incident reporting, informed consent, confidentiality, supervision protocols — these need to be documented, not just practiced.
Consider the timeline. If you’re a center-based Massachusetts provider, January 2027 is 11 months away. Even outside Massachusetts, starting now gives you a 12–18 month runway to address gaps before mandates reach your state.
The Bigger Picture
Accreditation mandates are part of a broader trend: the ABA industry is growing up. After years of explosive growth — fueled by expanded insurance mandates and Medicaid coverage — the regulatory environment is catching up.
That’s a good thing for practices that do quality work. Accreditation distinguishes you from providers cutting corners. It strengthens payer relationships. And as Cortica COO Cathy Lopez put it, it demonstrates your ability to “withstand the scrutiny of an external audit” — which is increasingly becoming “table stakes.”
The practices that treat accreditation as an opportunity rather than a burden will come out ahead.
Have questions about how to prepare your practice for accreditation? Reach out at [email protected] — we’re happy to help you plan.
