Governor Brian Kemp struck $15.86 million in autism rate parity funding from the FY 2027 budget on May 12. Anna Bullard says the bigger problem is what comes next: a managed care system that is already pushing children with autism back a decade.
Key Takeaways
- Governor Kemp vetoed the $15.86 million ABA rate parity line item on May 12, 2026. The cut, structured as $8.74 million from the Indigent Care Trust Fund and $7.13 million from Medicaid, was one of 157 disregards and line-item vetoes Kemp used to offset a $1.3 billion revenue shortfall created by income tax cuts, per the Governor’s Office of Planning and Budget.
- Georgia’s Medicaid managed care organizations are operating with effectively no rate floor. CareSource Georgia’s 20 percent cut took effect May 11. Authorization denial rates have climbed from under 5 percent to over 30 percent at some Georgia ABA providers, Autism Providers of Georgia board member Anna Bullard told Acuity.
- Network adequacy rules written for primary care do not fit a daily therapeutic service. Bullard told Acuity that Georgia’s adequacy standard defines an adequate network as the presence of one provider within a 60-mile radius. ABA, delivered as much as 40 hours a week, was never contemplated in that framework, leaving families displaced when providers exit MCO networks.
- Georgia’s current Medicaid managed care contracts contain no ABA rate floor. The current CMO contracts, signed under the prior procurement and set to expire June 30, 2026, were written without rate-floor language tying ABA reimbursement to the published fee schedule. APG is now pushing for that floor to be written into the next procurement, alongside contract language requiring the incoming Humana, Molina, and UnitedHealthcare networks to honor the published fee schedule.
Anna Bullard had been preparing for a different conversation. When she first reached out to Acuity in April, the central thread of Georgia’s 2026 autism story was the $15.86 million the General Assembly had appropriated to equalize clinic-based and home-based Medicaid reimbursement, the result of a two-year campaign by Autism Providers of Georgia (APG), Apollo Behavior CEO Kim Dean, and a coalition of parent advocates. On May 12, Governor Brian Kemp signed the FY 2027 budget and vetoed that appropriation along with 156 other items, citing a $1.3 billion revenue shortfall produced by an income tax cut passed in the final hours of the legislative session. The clinic rate parity money was gone before it ever reached a fee schedule.
“The governor took a position around just wanting to be conservative with revenue for the state for next year,” Bullard said in an interview last week. “He took out a lot of line items. But I guess there’s still a possibility of things that could occur that would help providers who are really trying to provide clinic-based services here in Georgia.”
What was supposed to be a story about a hard-won appropriation has become a story about something more structural. Bullard, who passed Ava’s Law in 2015 after a seven-year campaign and is the founder of Alinea Autism Services, a clinic in Lyons in rural Toombs County, said the veto is no longer the issue keeping her up at night. The issue is that the three managed care organizations administering Georgia’s Medicaid program, CareSource, Peach State, and Amerigroup, are reshaping the network so quickly that families with children in active ABA treatment are being displaced from providers they have worked with for years.
A Managed Care System Operating Without a Floor
CareSource Georgia’s Notice of Material Amendment, first reported by Acuity in April, reduced reimbursement for all covered services to 80 percent of the Georgia Medicaid fee schedule effective May 11, 2026. CareSource has described the change as part of an effort to support sustainable program operations. The structural problem APG identified after meeting with the Georgia Department of Community Health (DCH) in April is that no statute or regulation requires CMOs to pay at the published fee schedule in the first place.
“When we established the ABA benefit back in 2018, nobody comes to you and says, oh, by the way, these are all the things you need to make sure you also do,” Bullard said. “One of those would be putting a floor in place for the Medicaid reimbursement. So we didn’t do that.”
Bullard told Acuity she is hopeful about the recent appointment of Stuart Portman as executive director of DCH’s Medical Assistance Plans Division. Portman, who was also elected president of the National Association of Medicaid Directors in April 2026, came to DCH in February 2024 from the U.S. Senate Committee on Finance, where he served as senior health policy advisor on Medicaid and CHIP. Bullard described him as knowledgeable and willing to make meaningful changes to the benefit. The constraint, she said, is contractual: the current MCO contracts, which have been operating since 2017 and are scheduled to expire June 30, 2026, contain no language tying ABA reimbursement to any percentage of the state fee schedule.
The CareSource cut is only one part of what providers are experiencing. Bullard said authorization denial rates at several Georgia ABA providers have climbed from below 5 percent to more than 30 percent over recent months. The pattern, she said, has nothing to do with clinical quality and everything to do with administrative throughput: each denial delays a child’s start date and, in some cases, drives provider exits that ripple through the network. Peach State and Amerigroup have also pursued contract terminations and rate actions affecting clinic-based providers, though neither move has been as broadly publicized as the CareSource amendment. The result, in aggregate, is a network being reshaped by payer action rather than by any DCH determination of capacity or quality. Acuity has documented similar patterns in its reporting on behavioral health reimbursement falling behind the underlying clinical evidence.
Network Adequacy Rules That Were Never Written for ABA
The harder problem Bullard described is one of definitional fit. Georgia’s Medicaid network adequacy standard, used to evaluate whether a CMO’s network is sufficient, defines adequacy as the presence of one provider within a 60-mile radius, Bullard told Acuity. That definition was built for primary care, a service most members access a handful of times a year. ABA, by contrast, is often delivered five days a week, sometimes for as many as 40 hours, with the same therapist team building rapport with a child over months and years. A 60-mile drive to a 40-hour-a-week service is not a network. It is a wall.
“If a family is taking their kid to a provider that’s providing home-based service and they leave the network, that family is left very likely to go and get services that are not the same as what they were getting,” Bullard said. “Maybe now they have to get telehealth services when they were getting in-person because that’s all that’s available.”
Bullard, who is not opposed to telehealth ABA as a modality, said the operational reality is that telehealth-heavy providers have more capacity than in-person clinics, which means a network of “adequate” providers can drift toward modalities a particular child may not be able to use. “These families are being displaced,” she said. “They’re being forced to go find another provider, to build relationships all over again with therapists. That is a real, real strain on these families. And that is what I think is being missed.”
The exposure is sharpest for rural and clinic-based providers, the same operators the vetoed parity funding was designed to support. Bullard told Acuity that Georgia’s Adaptive Behavior Services rates have moved only about three percent since the benefit launched in 2018, an adjustment authorized through the FY 2026 budget (HB 68) and operationalized via State Plan Amendment 25-0008, which CMS approved on October 7, 2025, with an effective date of July 1, 2025. The home-based rate, historically 20 percent higher than the clinic rate, has set the going wage for Registered Behavior Technicians in many rural counties, and clinic operators have been competing for staff at home-based wage levels while billing at the lower clinic rate. Acuity’s analysis of pediatric therapy practice valuation has shown how BCBA-owned single-site clinics struggle to absorb sole-payer rate actions in a way that multi-state, private-equity-backed platforms can. Bullard’s clinic in Toombs County, nearly two years old and the only clinic-based ABA provider in her area, sits at the most exposed end of the spectrum.
The labor-market math was meant to be solved by parity. Closing the rate gap between home and clinic settings would have given clinics, particularly small and rural ones, the headroom to compete for staff and remain open. With the appropriation vetoed, that headroom does not exist. With the CareSource cut applied, the math gets worse. Bullard said APG continues to encourage providers to document the operational impact through an anonymous survey the organization launched in April, consult legal counsel, and coordinate before responding to the 45-day objection window. A separate group of providers, she said, is in the early stages of exploring legal action grounded in the argument that Georgia’s administration of the ABA benefit effectively discriminates against children with autism. Acuity will report on that effort separately as it develops.
What Bullard Says Georgia Keeps Getting Wrong About ABA
Bullard has been advocating in the Georgia autism space for more than 15 years. She passed Ava’s Law in 2015 after a seven-year campaign, helped operationalize the Medicaid Adaptive Behavior Services benefit in 2018, and helped secure the FY 2027 parity appropriation that was vetoed last week. Each step, she said, has been followed by an administrative or payer action that recaptured part of the gain.
The legislative and administrative pattern she describes is one in which ABA, despite being a federally required Early and Periodic Screening, Diagnostic, and Treatment benefit under CMS, is treated by state-level decision-makers as discretionary in a way that primary care and other physician services are not. The mechanism is not stated opposition. It is structural neglect: network adequacy rules built for primary care, MCO contracts without rate floors, fee schedules that have moved only marginally since 2018, and authorization processes that bottleneck access without ever appearing on a budget line. The cost shows up in displaced families, not in cuts. The story that emerges, she said, is the one she would most like Georgia’s policymakers to understand.
“It would be so nice for families if for once we could just get benefits like everybody else does for our kids with autism without everything having to be so hard,” Bullard said. “The diagnosis is hard. Then getting ABA is hard. And then keeping ABA is hard.”
APG’s near-term advocacy, Bullard said, has shifted accordingly. The organization is pushing for explicit contract language requiring the three incoming CMOs, Humana, Molina, and UnitedHealthcare, to honor the published Adaptive Behavior Services fee schedule when they launch July 1, 2026, alongside a Medicaid managed care rate floor written into the next DCH procurement. North Carolina’s recent experience offers a precedent for after-the-fact rate restoration: a Wake County preliminary injunction in November 2025 blocked a 10 percent ABA cut, and Governor Josh Stein’s December 2025 directive restored rates to pre-cut levels. Whether Georgia’s next governor, or its current Medicaid leadership, will pursue a similar correction is the question Bullard and APG are now testing. The CareSource cut is one of several payer and oversight pressures reshaping Medicaid ABA in 2026, alongside accelerating federal OIG audits and reimbursement actions in Maryland, North Carolina, and Indiana. The pattern Bullard sees in Georgia, in which a benefit ostensibly required by federal law is constrained by state administrative architecture, is one Acuity has covered in its reporting on Georgia’s mental health parity enforcement record as well.
Acuity will update this story as APG completes its provider survey, the new CMO contracts launch on July 1, and any legal action by Georgia ABA providers moves forward.
Frequently Asked Questions
What did Governor Kemp veto from the Georgia FY 2027 budget, and what was the $15.8 million for?
Governor Brian Kemp signed Georgia’s FY 2027 budget (HB 974) on May 12, 2026, and issued 157 line-item vetoes and budget disregards totaling more than $344 million. Among them was $8,736,136 from the Indigent Care Trust Fund and $7,125,390 from Medicaid, totaling $15.86 million, that the General Assembly had appropriated to create parity between in-home and in-office reimbursement rates for autism services. The appropriation was the result of a multi-year effort by Autism Providers of Georgia, Apollo Behavior CEO Kim Dean, and a coalition of parent advocates to eliminate the 20 percent reimbursement differential between clinic-based and home-based Adaptive Behavior Services under Georgia Medicaid. Kemp said the cuts were necessary to address a $1.3 billion revenue shortfall created by an income tax cut bill, HB 463, that he signed the day before the budget.
Does Georgia Medicaid require its managed care organizations to pay at the state ABA fee schedule?
No. DCH publishes a fee schedule for Adaptive Behavior Services, but there is no statutory or regulatory floor requiring CareSource, Peach State, Amerigroup, or any other CMO to reimburse at or above that level. Provider rates are negotiated through individual MCO network contracts. The current generation of contracts, which has been in place since 2017 and is scheduled to expire June 30, 2026, was signed without rate-floor language. APG told Acuity this gap is the mechanism that allowed CareSource Georgia to unilaterally reduce reimbursement to 80 percent of the fee schedule effective May 11, 2026.
Why is “network adequacy” not protecting families with children in ABA treatment?
Anna Bullard told Acuity that Georgia’s network adequacy standard defines adequacy as the presence of one provider within a 60-mile radius. The standard was built for primary care, which most Medicaid members access a small number of times per year. ABA is often delivered five days a week, for as many as 40 hours, with a single therapist team. A single provider within 60 miles, particularly one that may only have telehealth capacity, is not a meaningful substitute when a family’s in-person clinic provider exits the network. Bullard said families displaced by CareSource’s rate amendment are being forced onto wait lists, into telehealth, or into provider switches that can take six months or more to complete. The displacement is occurring in a market where ABA visit volumes have grown 309 percent nationally since 2019, meaning even providers with capacity to absorb new patients often have months-long wait lists of their own.
What did APG learn from its recent meeting with Georgia Medicaid leadership?
Autism Providers of Georgia has been engaging with DCH on rate-setting and contract issues, and Bullard told Acuity she is hopeful about the recent appointment of Stuart Portman as executive director of DCH’s Medical Assistance Plans Division. Portman was elected president of the National Association of Medicaid Directors in April 2026 and joined DCH in February 2024 from the U.S. Senate Committee on Finance. Bullard described him as knowledgeable and willing to make meaningful changes to the benefit. APG’s near-term advocacy is focused on writing a rate floor and explicit fee schedule language into the next procurement, alongside contract terms requiring the incoming Humana, Molina, and UnitedHealthcare networks to honor the published Adaptive Behavior Services fee schedule when they launch July 1, 2026.
Who is Anna Bullard, and what is her role in Georgia autism advocacy?
Anna Bullard is the parent of Ava Bullard, the namesake of Ava’s Law, the Georgia statute passed in 2015 (House Bill 429) that established the state’s first private insurance mandate for autism treatment, including ABA therapy. Bullard advocated for the legislation for seven years before its passage. She subsequently founded Alinea Autism Services, a clinic-based ABA provider in Lyons, Georgia, in rural Toombs County. She is a board member of Autism Providers of Georgia and was a participant in the multi-organization coalition that secured the FY 2027 clinic rate parity appropriation that was vetoed in May 2026. Bullard reached out to Acuity in April 2026 in response to its coverage of the CareSource rate amendment and again in May to discuss the veto and the broader MCO situation.
