MassHealth requires ABA accreditation by January 2027, but a six to eight month review backlog is blocking new clinics and threatening children’s treatment.
By Nichole Daher, Founder and Chief Executive Officer of Success On The Spectrum
Disclosure: Success On The Spectrum is a Founding Member Organization of the National Society of Autism Professionals, a designation it received following donations to NSAP in June 2026. NSAP was launched with founding support from The Catalight Group and is developing a Commission on Accreditation led by Michelle Befi, Senior Vice President of Sustainable Program Design at the Catalight Foundation. Success On The Spectrum has volunteered to serve as pilot clinics for that accreditation program when it launches. The author holds no role on the Commission. Success On The Spectrum locations in Massachusetts are not currently accredited and would be directly affected by the policy changes described here.
Medicaid fraud and waste harm everyone. They divert limited public resources, undermine trust in healthcare providers and threaten the long-term sustainability of programs serving vulnerable children.
As the founder of the first autism treatment franchise in the US, I support appropriate and regular payor audits. I applaud federal and state officials who investigate fraudulent billing, medically unnecessary services, falsified documentation and organizations that place profit ahead of patients. Honest providers do not fear reasonable oversight. We welcome it.
Accreditation can be a valuable tool for setting minimum clinical, safety, operational and ethical standards. The objective is not the problem. The problem is requiring accreditation on a timeline the accreditation system may not have the capacity to support. A policy meant to eliminate bad providers becomes harmful when it also prevents qualified providers from opening clinics and forces compliant ones to discharge clients.
What the Massachusetts ABA Accreditation Deadline Actually Requires
That danger is emerging as states and insurers impose new accreditation and licensing requirements on applied behavior analysis providers.
MassHealth now requires ABA providers in its managed care networks to be accredited by a nationally recognized body specializing in ABA. Center-based providers must be accredited by January 1, 2027. Every other provider has until January 1, 2028. The requirement reaches providers through MassHealth’s managed care entities and their behavioral health vendors, including MBHP/Carelon, WellSense, Fallon Health and the Tufts Health Together accountable care plans.
The deadline is not the part that is closing the door. Since January 1, 2025, MassHealth’s managed care entities have not been permitted to contract with new ABA providers that are not already accredited. In June, a credentialing manager at Point32Health told one of our Massachusetts franchisees precisely that: the plan is prohibited from contracting with new ABA groups that are not accredited, and it cited the MassHealth requirement as the reason. My franchisee had asked about commercial coverage, not Medicaid.
Point32Health, the parent of Harvard Pilgrim Health Care and Tufts Health Plan, applies the same framework across its service area, and says so in its own published provider guidance. Center-based providers in Massachusetts and Rhode Island must be accredited by January 1, 2027, and all others, including center-based providers in New Hampshire, Maine and Vermont, by January 1, 2028. The plan has said it expanded the requirement to all Harvard Pilgrim and Tufts Health Plan products across every state in its service area.
Blue Cross Blue Shield of Massachusetts does not credential ABA providers itself. It contracts that work to Carelon, which is not allowing new clinics to apply to join the network without ACQ accreditation first. That is a commercial plan, not Medicaid.
Other states are moving the same way. Indiana Medicaid requires ABA agencies to apply for accreditation by August 1, 2026 and to be fully accredited by October 1, 2027 or lose enrollment. North Carolina gives providers already enrolled in an affected behavioral health service until April 20, 2027 to report national accreditation. Pennsylvania, through a licensing regime rather than accreditation, has barred unlicensed organizations from providing services since 2020 and publishes no guaranteed review timeline.
Why the ABA Accreditation Bottleneck Blocks New Clinics
The Autism Commission on Quality (ACQ) is the body MassHealth and its payers point providers toward, and it is the accreditor Massachusetts plans consistently name. The Council of Autism Service Providers acquired the Behavioral Health Center of Excellence and is folding it into ACQ’s framework. Existing BHCOE accreditations are honored, but new applicants go to ACQ.
ACQ is not, strictly speaking, the only option. Global Autism Accreditation also accepts applications. But an accreditation is worth little unless every major payer will accept it, and no small provider can afford to run two review processes at once to find out which one counts.
ACQ told my franchisee in July that the accreditation process takes, on average, six to eight months. When we applied for our Worcester location, the application waitlist ahead of that was roughly three weeks.
Compounding the problem, a provider must already be treating at least one patient before ACQ will begin the process. Because most payers will not issue a contract or authorize services until accreditation is complete, that provider is delivering medically necessary ABA therapy for free while paying therapists, supervisors, rent, utilities, software, liability insurance and every other operating expense. Only after accreditation is awarded can a provider apply to become in-network, which took us another six months in Worcester. Only then can a clinic obtain prior authorization and begin billing for services already rendered.
That is not a minor inconvenience. It is an economic barrier to entry.
A locally owned business cannot finance 14 months or more of rent, payroll and overhead without operating revenue. Few independent healthcare businesses can clear that hurdle. SOS franchisees in Massachusetts are facing it now. Their clinics are small businesses funded through personal savings, SBA loans and personal guarantees, not by the deep pockets of institutional investors.
Government policymakers should not be creating a system under which only large corporations can afford to enter the market. That result is anti-competitive, contrary to free-market principles and fundamentally un-American. It reduces consumer choice, blocks small-business ownership and accelerates consolidation in a sector already short of providers. Private-equity-backed organizations can absorb months without reimbursement. Independent providers cannot. A rule that requires providers to operate without revenue does not create higher-quality healthcare. It simply limits market participation to those with the deepest pockets.
The most immediate victims are children. A clinic that reaches a deadline before its review is complete can be dropped from a payer network or lose the ability to bill Medicaid, forcing it to discharge children who are actively in treatment. New clinics cannot afford to open while families continue waiting for treatment.
A Provisional Path Would Protect Patients and Providers
ACQ has said it is in communication with MassHealth about implementation, and that waivers and grace periods are under consideration for organizations demonstrating a good-faith effort. It has also said any such flexibility would be at the discretion of the payor. That is not something a business can plan around. A provider who has signed a lease, hired staff and enrolled a child cannot budget against an unpublished exception.
There is a reasonable solution.
On July 23, I met with MassHealth officials, along with two of our Massachusetts franchise owners, to make this case directly. We asked for two things. First, a provisional enrollment status that would let providers actively pursuing accreditation join networks while their reviews are underway. Second, permission for providers in the ACQ process to be reimbursed for a limited number of clients during the evaluation period, so that the clinical record accreditation requires can be built without months of uncompensated care.
Neither is an extraordinary request. States and Medicaid managed-care organizations should allow providers that submitted complete, timely applications to keep serving patients under provisional status while awaiting evaluation. New providers could operate after passing background checks, enrollment screening, credential verification and an initial readiness review, reimbursed at a temporarily reduced rate until accreditation or licensure is final.
Existing providers that miss a deadline solely because the accreditor or licensing agency has not completed its review should receive an automatic extension. No clinic should lose its network status, and no child should lose treatment, because a third-party reviewer lacks sufficient capacity.
What providers need now is a written answer, published far enough ahead of January 1 that a small business can still plan around it.
Audits and accreditation should protect patients. They should identify misconduct, enforce meaningful standards and preserve public funds. They should not become artificial barriers that close responsible clinics, discourage small-business investment and deepen autism-treatment waitlists.
We can fight fraud without fighting access. Policymakers must do both.
Nichole Daher is the Founder and Chief Executive Officer of Success On The Spectrum and SOS Franchising, the first autism treatment franchise in the United States.
