Alabama Medicaid paused its Specialty 175 rule for pediatrician ABA referrals in June. No new date has been set, and existing ABA billing rules still apply.
Key Takeaways
- A one-letter requirement, paused within three days. A June 15 ALERT would have required pediatricians to hold ABA Specialty 175 for autism diagnoses to support ABA referrals starting July 1; a June 18 follow-up paused it.
- The pause left the rest of the program standing. The May 18 limit on who may diagnose, the February facility rule, and prior authorization for every ABA code except the 97151 assessment all remain in effect.
- Clinicians described waits that already run long. Huntsville nurse practitioners told WAFF that diagnosis alone can take three months to a year, followed by a separate search for an ABA provider.
- No replacement date has been published. Because the designation cannot be backdated, the length of any future runway will decide how many pediatricians can keep referring on day one.
On June 15, the Alabama Medicaid Agency sent pediatricians a one-page notice with a short deadline. Beginning July 1, the ALERT said, an autism diagnosis from a pediatrician would support a referral for applied behavior analysis only if that pediatrician’s Medicaid enrollment carried a designation called ABA Specialty 175. Obtaining it took a letter on official letterhead. Obtaining it late carried a cost, because the agency said the designation could not be backdated and referrals from pediatricians without it would be denied.
Three days later, the agency paused it. A June 18 follow-up told providers that Medicaid was pausing implementation tied to the July 1 deadline and would issue additional guidance. More than three months later, the requirement sits where that notice left it: not withdrawn, not rescheduled, and not in force. As of October 6, Alabama Medicaid’s public ALERT index listed no subsequent guidance on the requirement.
The pause did not loosen anything else. The June 18 notice said providers must still bill in accordance with Medicaid’s rules, regulations, and billing manual, and the three Provider ALERTs Alabama issued earlier this year on fee schedules, facility standards, and diagnostic authority remain in place. What the pause leaves unsettled is the step that comes before all of them: whose diagnoses will open the door to treatment.
What Alabama Medicaid’s ABA Specialty 175 Requirement Would Change
The June 15 ALERT was addressed to physicians enrolled as Provider Type 31 with Specialty 345, Alabama Medicaid’s classification for pediatricians. To add Specialty 175, a pediatrician would submit a written request listing the provider’s name, National Provider Identifier, Alabama Medicaid provider number, and service location address. The designation would take effect on the date it was approved and added to the provider’s enrollment file, with no retroactive date.
Specialty 175 is not new to the program. It is the specialty under which ABA therapy is enrolled and billed through Chapter 37 of the Provider Billing Manual, and the April 2026 version of that chapter already allowed a licensed psychologist or psychiatrist to request it. The June notice would have extended the same mechanism to pediatricians and made it a condition of their referrals.
The notice also stated that Certified Registered Nurse Practitioners are not authorized to diagnose autism-related conditions for Medicaid ABA referrals. That limit did not originate in June. A May 18 ALERT to all providers had already defined qualified diagnosing practitioners as licensed psychologists, licensed psychiatrists, and licensed pediatricians, a list that does not include nurse practitioners. The April edition of Chapter 37 still describes the diagnosing professional more broadly, as a licensed physician, psychologist, or other qualified professional, so providers are working from guidance issued in layers. The June 18 pause addressed the July 1 deadline and did not mention the May 18 notice.
Pediatricians had 16 days between the first ALERT and the original effective date. The agency has not publicly explained why it paused the requirement. Melanie Cleveland, Communications Director for the Alabama Medicaid Agency, told CBS 42 on June 18 that the agency would issue additional guidance and clarity, and the follow-up ALERT directed questions to the program’s ABA mailbox.
How Alabama Pediatricians and Nurse Practitioners Responded to the ABA Referral Rule
The requirement reached practices at different speeds. Dr. Derrol Dawkins, Founder of Metro Pediatrics, told CBS 42 that his office had already sent its request, and described the process as a letter listing the practice’s designations and location. Dr. Albert Holloway, a general pediatrician with Payne & Holloway Pediatrics in the Montgomery area, told WSFA that families should still be able to reach services, while noting that a definitive autism evaluation can already involve delays. His advice to concerned parents was to start with the child’s primary care provider.
In Huntsville, nurse practitioners described a different exposure. Teariah Wilder told WAFF that patients had already called her office worried that children receiving therapy might need to be diagnosed again. Kristi Krueger described two waits in sequence: a diagnosis, which she said can take three months to a year depending on a child’s age and insurance, and then a referral and an ABA provider, a second wait she put at “anywhere from months to years.”
Those accounts trace the sequence the rule would have touched. A child’s path into Medicaid-funded ABA in Alabama runs through a qualifying diagnosis, a referral, a provider enrolled at a qualifying facility, and prior authorization. Chapter 37 asks providers to allow 14 days for each authorization to be processed, and services must stop if a renewal is not approved before the current period expires. Each document along that path is also what auditors check: the federal audits that have reshaped ABA oversight repeatedly counted missing diagnostic evaluations and referrals as grounds for improper payment findings.
Alabama Medicaid ABA Rates and the Program Changes Around the Pause
Alabama’s ABA program has changed more in 2026 than its rates have. The agency issued a standalone ABA Fee Schedule on February 5, required ABA providers to operate from a physical facility with visible business signage beginning February 24, and narrowed diagnostic authority on May 18. On June 30, it announced off-cycle provider revalidations in response to a request from the Centers for Medicare & Medicaid Services.
Rates on the core codes did not move. The February 5 fee schedule, which lists itself as current for 2026, pays $10.00 per 15-minute unit for CPT 97153, the technician-delivered treatment code, and $15.00 for 97155, the same rates Acuity found on the October 2023 Physician Fee Schedule. Across the 47 states and jurisdictions MediRate tracks for 97153, only West Virginia, at $9.90, and New York, which cut its rate to $9.63 on October 1, now pay less, according to Acuity’s comparisons.
In July, Glenwood, an Alabama autism services organization, launched the Alabama Autism Coalition to press lawmakers for higher ABA reimbursement. The organization said Alabama ranks 49th nationally on Medicaid ABA rates and that those rates have not increased in more than five years. Christy Castleberry, Glenwood’s President and Chief Executive, said in a statement that providers need the resources to keep delivering services.
The referral rule would have sat upstream of all of it. Fee schedules determine what a provider is paid once a child is authorized; facility rules determine who may enroll to deliver care; the diagnostic and referral requirements determine which children reach a provider in the first place.
How Other State Medicaid Programs Are Handling ABA Diagnosis and Eligibility
Alabama is not the only program reconsidering who can open the door to ABA, or the only one to reverse course after a tightening. At the federal level, CMS released a 173-page State Medicaid and CHIP ABA Toolkit on August 4. The guidance is not binding, but in a passage marked as best practice it says states should “tie sustained ABA coverage to a confirmed ASD diagnosis,” while allowing limited, time-bound services when an evaluation is pending. The same document reports that Medicaid and CHIP paid $1.47 billion in 2025 for ABA delivered for conditions other than autism, a figure Acuity examined last month. Virginia has already written an autism diagnosis requirement into its 2026 Appropriation Act, according to a Department of Medical Assistance Services bulletin, with an effective date pending federal approval.
Other states are adjusting the diagnostic gate from the plan side. In North Carolina, Partners Health Management, one of the state’s Tailored Plans, told providers in August that where an existing autism diagnosis was not established with a validated tool named in state policy, its utilization management staff would recommend updated diagnostic testing at the next authorization review, a step that appears nowhere in the state’s own bulletins. Georgia moved the other way on a separate requirement, dropping a 50-mile residency rule for ABA enrollment four months after tightening it.
What Alabama ABA Providers Are Still Waiting to Learn About Specialty 175
The open questions are practical. The agency has not said whether a new effective date is planned, how much notice pediatricians would receive, or whether the no-retroactivity provision would survive a revised version. That last point carries weight. A designation that cannot be backdated turns the length of the runway into the main variable: a pediatrician who has not filed by a future effective date would be unable to support referrals until the request is approved.
It is also unclear what happened to requests submitted in June. Practices such as Metro Pediatrics filed before the pause, and the agency has not said publicly whether those requests were processed, held, or will need to be resubmitted under future guidance.
Acuity requested comment from the Alabama Medicaid Agency on whether a new implementation date is planned, why implementation was paused, and the status of Specialty 175 requests already filed.
For now, the working rule in Alabama is the one that existed before June 15. Licensed psychologists, psychiatrists, and pediatricians may diagnose; ABA services run through prior authorization; and providers must operate from a qualifying facility. The Specialty 175 requirement exists on paper, attached to a date that has already passed.
