Twenty Hours in Washington, Six in Tallahassee
On August 31, Florida’s Applied Behavior Analysis Task Force sat through a six-hour meeting in Tallahassee. One of the presenters was Dr. Caprice Knapp, Principal Deputy Director of the Center for Medicaid and CHIP Services, walking the panel through the ABA toolkit CMS released on August 4.
Two things she said should be on every Florida BCBA’s desk.
First, per Acuity News, experts and parents told CMS that the process of reaching an individualized treatment plan “can take up to 20 hours.”
Second: “We always have soft limits at CMCS. We do not have hard limits.”
Now open Florida’s 2026 Behavior Analysis Fee Schedule. Next to 97151: “Medicaid reimburses a maximum of 24 units per behavior assessment.” That’s six hours. Next to 97151-TS, the reassessment: a maximum of 18 units, or 4.5 hours. Supporting assessment by a technician (97152) gets 8 units. The 0362T add-on, used for assessing severe destructive behavior, gets 16 units, and only with prior authorization.
The Task Force’s third meeting is scheduled for today. A fourth is set for October 5. Recommendations go to the Governor, the Senate President, and the House Speaker by December 31, 2026. If the gap between the federal description of this work and what Florida reimburses is going to show up in that report, providers have about three months to put it there.
Who Is Deciding This
The Task Force was created by Section 40 of House Bill 5003-E during the 2026E legislative session and sits inside the Agency for Health Care Administration. AHCA Secretary Shevaun Harris chairs it as a nonvoting member. Its authority expires July 1, 2027.
The statute tells it to evaluate clinical care models, care transitions, quality metrics, utilization limits and authorization periods, potential caps on months of service per enrollee, and provider enrollment and billing standards. Read that list twice. Most of it is about spending less.
That fits the numbers AHCA opened with in August: $6.57 billion in Florida Medicaid ABA spending across 2023 through 2025, roughly four times Indiana, the next-highest state. The CMS toolkit adds a sharper one: between 2021 and 2025, Florida paid over $2.1 billion for ABA delivered to beneficiaries without an autism diagnosis on the claim. Colorado was second at about $375 million.
The panel includes the current and immediate past presidents of the Florida Association for Behavior Analysis, a developmental-behavioral pediatrician, a provider CEO, two appointees from Florida Community Care and one from Molina Healthcare, and a family services leader. As of this writing, the seat reserved for a family member of an ABA enrollee is still listed as vacant on AHCA’s roster.
So the room is not hostile to ABA. It is under pressure to produce a cost-control recommendation, and it is deciding what counts as reasonable. Your data can help it decide.
Quote CMS Correctly, or It Gets Thrown Back at You
Before you paste “CMS says an assessment takes 20 hours” into an appeal, read the source.
The toolkit’s written 20-hour language sits in its section on diagnosis. It says that because of “the comprehensive nature of the multi-method and multi-informant assessment process, it may require 20 hours or more to complete the evaluation,” and that the evaluation should be completed in person whenever possible. That’s the diagnostic evaluation. Knapp’s framing to the Task Force, as reported, covered the whole path from evaluation to individualized treatment plan.
Florida splits that path. The Comprehensive Diagnostic Evaluation is led by a licensed practitioner and billed outside the ABA codes. The behavior assessment that follows is the piece capped at 24 units.
If you claim CMS set 20 hours as the 97151 benchmark, a plan reviewer or an AHCA analyst will find the page and dismiss the rest of your argument with it. Here is the version that holds up:
- CMS describes the evaluation-to-plan pathway as work that can run 20 hours or more, and says it should be done in person.
- Florida reimburses six hours of Lead Analyst time for the behavior-assessment portion of that pathway, with no exception process written into the fee schedule line for 97151.
- The toolkit states that states may not apply hard limits, meaning limits that can never be exceeded, to 1905(a) services for EPSDT-eligible children. Soft limits that can be exceeded with prior authorization or medical necessity review are permitted.
That third point is the one with legal weight. The toolkit is guidance. Knapp said so herself: “A toolkit is not a rule.” But the EPSDT prohibition on hard limits comes from the Social Security Act, and the toolkit is simply restating it. The practical question for Florida is whether 24 units is a soft limit with a path to exceed it for a child under 21, and if so, what that path is.
What Six Hours Has to Cover
Florida’s coverage policy (the December 2024 version incorporated into Rule 59G-4.125) is specific about what goes into an initial behavior assessment. It must include administration, scoring, and reporting of two core instruments:
- The Vineland-3 Comprehensive Parent Interview Form, plus the Maladaptive Behavior Domain for recipients 3 and older
- The BASC-3 Parenting Relationship Questionnaire for recipients ages 2 through 18
The complete scoring report goes in with the prior authorization request. Then the documentation section lists what every assessment and behavior plan must contain: reason for referral, medical and developmental history, relevant family history, a clinical interview, a file review, assessment procedures and results, and a behavior plan with operational definitions, direct observation and measurement procedures, and a baseline for every target. Add caregiver training goals, the number of units requested per code with medical necessity for each, a supervision plan, care coordination, a transition plan, a crisis plan, and a discharge plan. The plan and assessment must be signed by the Lead Analyst and the parent or guardian.
That’s before any skill assessment of your choosing, and before a functional behavior assessment if the child has behavior worth reducing. The policy explicitly allows “additional assessment tools” at the Lead Analyst’s discretion. It does not add hours for them.
In practice, a six-hour cap forces cuts in the places reviewers can’t see:
Direct observation shrinks to one visit. Baselines built on one session in one setting are thin, and thin baselines make the six-month progress graphs at reassessment harder to defend.
The FBA gets abbreviated or skipped. Indirect measures and a caregiver report stand in for descriptive analysis. For a child with severe behavior, that’s where 0362T is supposed to help, and it requires its own prior authorization.
Skill assessments get sampled. A full VB-MAPP or ABLLS-R administration competes with the required instruments for the same 24 units.
Report writing happens off the clock. In many practices it’s the biggest unbilled line. The BCBA finishes the interview and observation inside the cap and writes the plan at night.
None of that shows up in claims data. The cap looks like it works, because nobody bills a 25th unit.
How to Document Inside the Cap
You can’t change the fee schedule this quarter. You can make every unit you do bill defensible and make the unbilled work visible.
Budget the 24 units before the first visit. An illustrative split: about 1.5 hours for the caregiver interview and Vineland-3, 0.5 for the BASC-3 PRQ and file review, 2 hours of direct observation across at least two settings, 1.5 for skills probes, and 0.5 for caregiver feedback and plan signing. Use 97152 for technician-administered probes where your plan allows it. Treat that as a starting point you adjust per child.
Log time you spend but can’t bill. Keep a simple internal record of assessment minutes past unit 24 by activity: scoring, observation, writing. Six months of that across your caseload becomes the most useful exhibit you can hand the Task Force: “Our median initial assessment took X hours of Lead Analyst time. Florida reimbursed six.”
Write the baseline limitation into the plan. If observation was limited by the cap, say so in the assessment procedures section and state when additional baseline data will be collected during treatment. A reviewer at reassessment will read the graph more generously if the plan told them why the first data point is thin.
Protect the reassessment. Florida requires a reassessment and updated plan at least every six months, with the core instruments every 12 months, and each targeted behavior needs its own data table and graph plus a narrative justifying the intensity requested. That work is capped at 18 units. The practices that survive it build those graphs continuously during the authorization, not in the last two weeks.
Ask your plan for its exception process in writing. 98.9% of Florida’s ABA recipients are in Statewide Medicaid Managed Care. For a child with a complex presentation, request additional 97151 units with a medical necessity justification and, if denied, ask the plan to identify how the limit can be exceeded for an EPSDT-eligible child. Keep the answer. Either you get the units, or you get documentation that the limit functions as a hard one.
We made a similar argument about treatment hours in defending ABA hours with CASP and outcomes research: payers respond to evidence tied to the specific child, not to general appeals. And your delivered-versus-authorized history matters here too. As we covered in why payers cut hours at renewal, your own claims are the first thing a reviewer reads.
How to Engage Before December 31
The Task Force takes written comments at [email protected]. AHCA posts agendas and materials on its task force page, and the Florida Channel has archived the August 31 meeting. Here’s how to use the window:
- Send data, not adjectives. One page: your median assessment hours versus the 24-unit cap, the share of reassessments where you wrote reports off the clock, and one de-identified case where the cap cost baseline quality. Numbers from a real practice carry more weight than an advocacy letter.
- Quote the toolkit accurately. Cite the 20-hour evaluation language as CMS’s description of the pathway, and cite the EPSDT hard-limit prohibition as the legal point. Ask the Task Force to recommend a documented exception path for 97151 and 97151-TS.
- Point at the toolkit’s bundling discussion. Stakeholders told CMS they support bundling the assessment phase (97151 and related codes) into a single flat-rate payment. If Florida wants cost control on assessment, a bundle priced to the actual work is a better recommendation than a unit cap that pushes the work off the clock.
- Watch October 5. It’s the last scheduled meeting before the report. If you comment, get it in before then.
- Coordinate with FABA. Its leadership testified at the first meeting and says it’s attending every session. Individual provider data strengthens its hand.
Remember what else is on the statutory list: caps on months of service and authorization periods. The assessment cap is the smaller fight. Practices that show up now with clean data will have credibility when the larger recommendations land.
Where Software Fits
No system changes the 24-unit cap. What it can do is keep you from wasting units and give you the records to argue with.
StreamABA tracks authorizations with approved units against delivered units by service code, and payer service-code rules can carry per-authorization unit limits, so a 97151 cap is visible before the assessment visit is scheduled, not discovered on a denial. Session data feeds goal progress continuously through the authorization, so the six-month reassessment starts from data you already have rather than a scramble. And progress reports pull mastery data straight from sessions, which is what a medical necessity justification needs.
The unbilled-minutes log above is a spreadsheet you can start tomorrow. The session data behind it is what makes it persuasive.
Working through Florida’s assessment cap or preparing comments for the Task Force? Reach out at [email protected].
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Sources
- Acuity News: Florida ABA Task Force Hears the Federal Case for Soft Limits on Therapy Hours (September 24, 2026)
- Acuity News: Florida ABA Task Force Opens Its Medicaid Review With a $6.57 Billion Spending Figure (August 25, 2026)
- Florida AHCA: Applied Behavior Analysis Task Force
- Florida AHCA: Behavior Analysis Fee Schedule 2026 (PDF)
- Florida AHCA: Florida Medicaid Behavior Analysis Services Coverage Policy, December 2024 (PDF)
- CMS: State Medicaid & CHIP Applied Behavior Analysis Toolkit (August 2026, PDF)
- CMS: CMS Launches New State Toolkit to Protect Children with Autism, Strengthen Oversight of Applied Behavior Analysis Services (August 4, 2026)
- The Florida Channel: Florida AHCA Applied Behavior Analysis Task Force, August 31 meeting (video)
- Florida Association for Behavior Analysis: AHCA ABA Task Force Updates
