Alabama Medicaid issued three Provider ALERTs in early 2026: a February 5 standalone Applied Behavior Analysis Fee Schedule, a February 24 physical-facility-and-signage requirement, and a May 18 restriction limiting ABA-qualifying diagnoses to licensed psychologists, psychiatrists, and pediatricians. Rates on the core CPT codes have been stable since at least October 2023 and remain the lowest in the Southeast neighbor set.
Key Takeaways
- Three 2026 alerts tightened the ABA program in sequence. Alabama Medicaid issued a standalone ABA Fee Schedule on February 5, required ABA enrollment at a physical facility with visible business signage effective February 24, and on May 18 limited ABA-qualifying diagnoses to licensed psychologists, psychiatrists, and pediatricians. A program-expectations Webex is scheduled for June 15.
- The new fee schedule consolidates ABA codes and adds two for multi-technician services. The February 2026 schedule pulled CPT codes 97151 through 97158 out of the broader physician fee schedule into a dedicated ABA Fee Schedule, and added 0362T at $30 and 0373T at $20 per 15-minute unit for assessments and treatment delivered by two or more technicians.
- Rates have been stable since at least October 2023 and sit at the Southeast floor. Alabama’s 97153 at $10.00 per 15-minute unit and 97155 at $15.00 are unchanged from the October 2023 Alabama Medicaid Physician Fee Schedule. Both are the lowest in the Southeast neighbor set on MediRate’s regional comparison.
- A parallel ADMH rehabilitative pipeline is under stress. The Alabama Department of Mental Health ended its agreement with Key Autism Services on January 31, 2026, citing a billing dispute involving more than $138,000 in claims for services it said were not authorized in advance under contract. ADMH directed affected families to seek services through Medicaid or transition to other providers.
Alabama Medicaid’s Applied Behavior Analysis program looks meaningfully different in mid-2026 than it did at the end of last year, even though the published rates on the core ABA codes are exactly where they have been since at least October 2023. In three Provider ALERTs over fourteen weeks, the agency issued a new standalone ABA Fee Schedule that pulled CPT-coded ABA out of the broader physician fee schedule, required ABA providers to operate from a physical facility with visible signage, and narrowed the diagnostic gateway to three licensed provider types. None of the three actions moved rates on 97153 or 97155. All three changed who can deliver services, where they can deliver them, and which providers can establish ABA eligibility.
The state did not frame the sequence as a single program update. Providers received three ALERTs, an updated Provider Billing Manual chapter, and a June 15 Webex on program expectations and updates. The cumulative shift is one of provider screening and infrastructure, not reimbursement.
What the February 5 Fee Schedule Actually Does
Before February 5, 2026, Alabama Medicaid reimbursed CPT codes 97151 through 97158 under the broader Physician Fee Schedule. Verified against the October 1, 2023 Physician Fee Schedule on file, those codes priced at $25.00 for 97151, $12.50 for 97152, $10.00 for 97153, $4.00 for 97154, $15.00 for 97155, $30.00 for 97156, $2.50 for 97157, and $5.00 for 97158, all per 15-minute unit. Every one of those rates appears on the February 5, 2026 ABA Fee Schedule unchanged.
What is new in the standalone schedule is the structure and two additional codes. Pulling ABA out of the physician schedule into a dedicated document aligns with Alabama Medicaid’s broader 2026 program-integrity posture, anchored by Provider Type 17 (Therapy) and Specialty 175 (Applied Behavior Analysis Therapy) under Chapter 37 of the Provider Billing Manual. The schedule also adds 0362T (Behavior ID Support Assessment, two or more technicians) at $30.00 and 0373T (Adaptive Behavior Treatment with Protocol Modification, two or more technicians) at $20.00 per 15-minute unit. Both Category III codes are designed for members exhibiting destructive or aggressive behavior whose care requires two or more technicians on site, with a BCBA-D, BCBA, or BCaBA physically present and directing treatment. Neither code appeared on the October 2023 Physician Fee Schedule.
Every code on the new schedule other than 97151 requires prior authorization, consistent with Chapter 37’s authorization framework. Behavior analyst services may be delivered by a licensed Board Certified Behavior Analyst (BCBA), a licensed Board Certified Assistant Behavior Analyst (BCaBA) under BCBA supervision, or a Registered Behavior Technician (RBT) under BCBA or BCaBA supervision. Claims must be submitted by the BCBA, and BCaBAs and RBTs must be employed by a BCBA who assumes professional responsibility for the services. Telemedicine is allowable under Specialty 931 enrollment with the GT modifier, limited to office (POS 11) and home (POS 12) settings.
Alabama’s Rates Are the Southeast Floor, and Have Been for Years
Alabama’s published rates compare unfavorably with every Southeast neighbor in MediRate’s regional data, and the gap is not a new development. On 97153, Alabama’s $10.00 per 15-minute unit is the lowest in the neighbor set. The next-lowest rate, Florida’s $12.26, is more than 22 percent higher. Louisiana ($12.50), Mississippi ($15.08), Georgia in-clinic ($15.58), and Georgia out-of-clinic ($18.69) all sit further above.
State Rate Comparison: Medicaid ABA Reimbursement, CPT 97153 (Adaptive Behavior Treatment by Protocol), per 15-minute unit. Source: MediRate. Georgia’s fee schedule differentiates by delivery setting; the first Georgia bar reflects in-clinic delivery ($15.58) and the second reflects out-of-clinic delivery ($18.69).
The 97155 picture is comparably wide. Alabama’s $15.00 per 15-minute unit for BCBA protocol modification is again the lowest in the neighbor set, below Florida ($15.37), Louisiana LBA ($17.50), Louisiana SCABA ($22.50), Mississippi ($24.35), Georgia in-clinic ($30.91), and Georgia out-of-clinic ($37.78). The gap between Alabama and Georgia’s out-of-clinic 97155 rate is roughly 60 percent.
State Rate Comparison: Medicaid ABA Reimbursement, CPT 97155 (Adaptive Behavior Treatment with Protocol Modification), per 15-minute unit. Source: MediRate. Georgia’s fee schedule differentiates by delivery setting; the first Georgia bar reflects in-clinic delivery ($30.91) and the second reflects out-of-clinic delivery ($37.78). Louisiana’s fee schedule differentiates by provider credential; the LBA bar reflects the Licensed Behavior Analyst rate ($17.50) and the SCABA bar reflects the State-Certified Assistant Behavior Analyst rate ($22.50). For granular state-by-state rate detail across the full ABA code set, MediRate maintains the underlying datasets.
Two Parallel Autism Services Pipelines
Alabama Medicaid’s coverage of services for children with autism runs on two separate pipelines. Chapter 37 of the Provider Billing Manual covers ABA Therapy under Provider Type 17, Specialty 175, billed through the CPT codes on the new February 5 Fee Schedule. Chapter 110 covers Rehabilitative Services (ASD) administered through the Alabama Department of Mental Health, billed through H-codes for services including Self-Help/Peer Support (H0038), Therapeutic Mentoring (H2014), Behavior Support (H2019), Psychoeducational Services (H2027), and In-Home Therapy (T1027). The two pipelines have different administrative oversight, different provider qualifications, and different rate structures.
Chapter 110 explicitly directs providers seeking to render ABA Therapy to Chapter 37, drawing a clear administrative line between the two service categories. For the modern ABA industry organized around CPT-coded services and Behavior Analyst Certification Board credentialing, Chapter 37 is the operative document. The 2021 Rehabilitative Services (ASD) Fee Schedule, which pays the H-codes referenced above, governs the ADMH-administered pipeline and is not the ABA benefit.
Facility, Signage, and Diagnostic Tightening
The February 24, 2026 Provider ALERT (ID 16713) added a structural enrollment requirement: ABA providers (Type 17) must operate from a physical facility with visible signage bearing the name of the business. Home residences, cubicles inside an office space, and shaped spaces inside another business are explicitly excluded. Existing providers were given 30 days from February 24 to comply, and unannounced site visits are part of the enrollment process. The rule mirrors a similar requirement that applies to Behavioral Health providers more broadly under Chapter 34, and aligns Alabama Medicaid with the provider-screening posture CMS has emphasized in its 2025 and 2026 federal Medicaid integrity actions.
The May 18, 2026 Provider ALERT narrowed the diagnostic gateway. Under the bulletin, members must be evaluated and diagnosed with an ABA-eligible diagnosis by a qualified practitioner before receiving ABA services. Qualified practitioners are limited to licensed psychologists, licensed psychiatrists, and licensed pediatricians. The bulletin is more restrictive than the broader "physician or non-physician practitioner" ordering language carried in Chapter 37, and excludes nurse practitioners and physician assistants from the diagnostic role.
In a state where pediatric subspecialty supply is concentrated in metropolitan areas, restricting diagnosis to three provider types has access implications for rural families. The June 15 Webex on program expectations is scheduled to walk providers through these and related updates.
The Key Autism Services Termination Hit the ADMH Pipeline
Alabama’s ABA tightening is unfolding alongside stress in the parallel ADMH-administered pipeline. On January 31, 2026, the Alabama Department of Mental Health ended a contract with Key Autism Services, a multi-state provider that had been serving families across Huntsville, Montgomery, Birmingham, and the Mobile-Gulf Shores area through the ADMH agreement. ADMH said the termination was related to billing procedures, not funding constraints, and public records show concerns about more than $138,000 in claims for services the department said were not authorized in advance under contract.
Key Autism Services disputed ADMH’s account, telling local broadcaster WSFA that company representatives were told in January that services had to stop because funding was no longer available. Key said it had a recording of the conversation but did not have permission from ADMH to release it. The company also said it had historically started services for children in crisis while awaiting retroactive authorizations that had been routinely approved, and that the practice only became an issue once it was directed to stop.
ADMH directed affected families to seek services through Medicaid or transition to another provider. That direction effectively pointed families from the Chapter 110 ADMH pipeline toward the Chapter 37 Medicaid ABA pipeline, where the new fee schedule, facility rule, and diagnostic restriction are taking shape. Families described two- to three-year waitlists at alternate providers, and Key’s regional director said the termination left 30 to 40 behavioral therapists without clients to serve. David Garofalo, Chief Executive of Early Autism Services, told WSFA that demand outpaces capacity across the Alabama market.
Federal and Regional Context
Alabama’s tightening is consistent with a national pattern Acuity has documented across the ABA industry through the first half of 2026. The U.S. Department of Health and Human Services Office of Inspector General has recommended more than $123 million in federal recoupments across four state ABA audits (Indiana, Wisconsin, Maine, and Colorado), with three additional state audits pending. On April 21, 2026, CMS directed all 50 state Medicaid programs to submit provider revalidation plans within 30 days. Alabama’s facility-and-signage rule and diagnostic restriction reflect the same federal pressure that has driven similar moves elsewhere.
Regionally, Indiana’s February 2026 Bulletin BT202627 set a 4,000-hour lifetime cap on comprehensive ABA, Georgia Governor Brian Kemp vetoed $15.86 million in autism rate parity funding on May 12, CareSource Georgia cut Medicaid ABA rates by 20 percent on May 11, and North Carolina restored a 10 percent ABA rate cut after a court injunction before passing oversight legislation. Florida carved ABA into its Statewide Medicaid Managed Care program on February 1, 2025 and refreshed its Coverage Policy with a new Comprehensive Diagnostic Evaluation requirement. Alabama is moving on a parallel provider-tightening track at the lowest published rates in the regional band.
What Providers Should Watch
Three near-term items will shape ABA operations in Alabama through the second half of 2026. First, the June 15 Webex on program expectations: providers should expect implementation detail on the May 18 diagnostic restriction, the February 24 facility rule, and the operational rhythm of the new standalone fee schedule. Second, the workforce response to rates that have not moved in at least two and a half years: $10 per 15-minute unit on 97153 translates to $40 per hour, well below most state Medicaid programs and likely to limit how many BCBA-owned practices and multi-state ABA platforms find the Alabama market viable in the long run. Third, the relationship between the two autism services pipelines: the Key Autism Services termination directed families toward Medicaid, and how Chapter 37 absorbs displaced demand from the Chapter 110 ADMH pipeline is one of the most operationally consequential questions for 2026.
Alabama did not announce a single program restructure. It issued three Provider ALERTs, updated a Provider Billing Manual chapter, and scheduled a Webex. The cumulative effect is a more tightly screened ABA benefit, delivered at rates that have been the floor of the Southeast for at least two and a half years.
