KMAP Bulletin 26140 drops master’s-level clinicians, Nurse Practitioners and Physician Assistants from the diagnostic path to ABA for members 20 and younger.
Key Takeaways
- A narrower front door: From November 1, KanCare pays for ABA for members 20 and younger only when a doctoral psychologist or qualified physician made the autism diagnosis.
- What the bulletin requires: Evaluations must document DSM criteria and severity with a validated tool such as the ADOS or CARS; members already in treatment get two years to obtain a confirming diagnosis.
- Where capacity is thin: Kansas law lets several master’s-level clinical licensees diagnose mental disorders, and providers say doctoral evaluators who accept Medicaid are scarce.
- What to do before the deadline: Audit active caseloads and waitlists for diagnostician credentials now, and confirm each KanCare plan’s enforcement date, which may differ from the state’s.
Starting November 1, Kansas Medicaid will narrow the list of clinicians whose autism diagnoses can open the door to applied behavior analysis. Under KMAP General Bulletin 26140, members 20 and younger must be diagnosed by a clinical psychologist licensed by the Kansas Behavioral Sciences Regulatory Board (BSRB) or by a qualified physician before KanCare will cover ABA. The Kansas Department of Health and Environment (KDHE), which administers the Kansas Medical Assistance Program, first set the rule to take effect September 1, then moved it back two months in an updated bulletin dated August 31.
The psychologist path requires a doctoral degree. The bulletin’s list of qualified diagnosticians leaves out master’s-level clinicians, including Licensed Clinical Professional Counselors, Licensed Specialist Clinical Social Workers and Licensed Clinical Marriage and Family Therapists, all of whom Kansas law authorizes to diagnose and treat mental disorders. It also leaves out Nurse Practitioners and Physician Assistants. For a child already in treatment whose diagnosis came from one of those clinicians, the bulletin sets a two-year window to obtain a confirming diagnosis from someone who qualifies.
The change lands in a state whose Medicaid ABA rates have barely moved. Acuity reported in August that Kansas Medicaid ABA rates have not changed since 2019 on every code but one, and that the July 2026 KMAP fee schedule reissued them unchanged. Providers working inside those rates now face a second constraint at intake: a family cannot start ABA after November 1, or keep it past the transition window, without an evaluation from a smaller pool of evaluators.
What KMAP Bulletin 26140 Requires for an Autism Diagnosis
The bulletin applies to dates of service on or after November 1 and covers KanCare members 20 and younger with autism spectrum disorder. It states a preference for a multidisciplinary diagnostic approach and sets two requirements for the evaluation itself. The diagnosis must document diagnostic criteria and symptom severity level under the current edition of the Diagnostic and Statistical Manual of Mental Disorders, and it must rest on a validated autism diagnostic tool, with the Autism Diagnostic Observation Schedule (ADOS) and the Childhood Autism Rating Scale (CARS) named as examples.
Two further elements are recommended rather than required. One is a cognitive evaluation using a validated instrument such as the Mullen Scales of Early Learning or the Bayley Scales of Infant Development; a school district’s cognitive evaluation can be included if it used a validated tool. The other is an adaptive behavior measure such as the Vineland Adaptive Behavior Scales or the Adaptive Behavior Assessment System.
Once a qualified diagnostician makes the diagnosis, the bulletin says the member is eligible for autism treatment, including ABA, without re-evaluation of the diagnosis and with no time limit on how soon treatment must begin. KDHE also cautions that KanCare managed care organizations may implement the policy on dates that differ from the one in the bulletin, and it points providers to the KanCare Open Claims Resolution Log on the KMAP bulletins page to track each plan’s system status. The matching manual changes appear on pages 8-47 and 8-48 of the Mental Health Provider Manual and pages 8-11 and 8-12 of the Professional Provider Manual.
Who Qualifies to Diagnose Autism Under the Kansas Medicaid Rule
The updated bulletin lists seven KMAP provider type and specialty combinations as qualified: psychologists, family practitioners, general practitioners, neurologists, psychiatrists, general pediatricians with a developmental designation, and Indian Health Services. Psychologists must hold a doctoral degree in psychology or equivalent training and have two years of supervised experience delivering BSRB-approved psychological services.
The August 31 revision changed the physician side of the rule in three ways. It dropped exempt-license physicians, who appeared on the original list. It added the developmental designation to the general pediatrician entry. And it replaced a blanket requirement that every listed physician document additional training in autism diagnosis with a list of qualified physicians: developmental-behavioral pediatricians, psychiatrists and neurologists, plus primary care physicians who can document that additional training.
What the list leaves out is the larger story. Kansas licenses master’s-level clinicians to diagnose. K.S.A. 65-5802 defines a Licensed Clinical Professional Counselor’s independent practice as including the diagnosis and treatment of mental disorders specified in the DSM edition the BSRB designates. K.S.A. 65-6402 says the same of Licensed Clinical Marriage and Family Therapists, and K.S.A. 65-6319 authorizes diagnosis and treatment of mental disorders by certain licensed social workers. The bulletin does not change what those clinicians are licensed to do. It changes whether Kansas Medicaid will pay for ABA on the strength of their diagnosis.
Ali Wilbert, Founder of Born to Blossom, an ABA provider with a location in Baxter Springs, told KOAM News Now in September that the doctoral evaluators the rule requires are hard to find inside Medicaid. A comprehensive autism assessment can take 12 to 20 hours depending on the child, she said, while Medicaid typically reimburses about eight, which she described as the reason few doctoral-level evaluators take Kansas Medicaid for the work. After the bulletin first came out, she told the station, providers began referring their waitlists elsewhere, and her own review found that a significant share of her current clients and waitlist “all require rediagnosis.”
The Two-Year Transition for Kansas Members Already in ABA
Children already approved for and receiving ABA are not cut off on November 1. If the original diagnosis came from someone who does not meet the new standard, the member has two years to obtain an updated diagnosis from a qualified diagnostician. The bulletin says the update does not need to involve a complete diagnostic evaluation, as long as the diagnostic criteria are met and a qualified diagnostician confirms the diagnosis.
One condition carries over intact. A validated autism diagnostic tool, administered either in the original evaluation or in the re-evaluation, remains an essential element. A confirmation can lean on a prior evaluation only if that evaluation used a validated instrument. A child diagnosed without one will need a validated tool administered at re-evaluation, which places that child in the same evaluation queue as new referrals.
The transition language covers members who are already approved and receiving treatment. A family that holds a diagnosis from a non-qualifying clinician and is still waiting for an ABA opening falls outside it, and would need a qualifying diagnosis before services begin on or after November 1.
Why Kansas Is Narrowing Who Can Diagnose Autism
The bulletin does not explain the change, and Acuity has requested comment from KDHE. It arrived eight days after CMS released its State Medicaid and CHIP Applied Behavior Analysis Toolkit on August 4. In announcing the toolkit, CMS cited a 421 percent increase in Medicaid and CHIP ABA spending between 2021 and 2025, against 67 percent growth in the number of children with an autism diagnosis receiving services, and described the toolkit as not a restriction on autism services.
The toolkit itself is guidance, not a mandate. It describes best practice as starting comprehensive ABA only after a qualified, independent clinician has confirmed the diagnosis, and says diagnosis should be completed by qualified and licensed medical providers.
Kansas observers have drawn the connection in public. Stephanie Coleman, Autism Family Outreach Manager with Kansas LEND at the University of Kansas Medical Center, raised the KDHE announcement during a September 9 webinar hosted by the Kansas Children’s Cabinet, calling it “really disappointing to hear.” She said KDHE had attributed the change to CMS, that advocates argue other states are not reading the federal guidance that way, and that the agency moved the start date to November after hearing from those advocates.
Coleman said waits for autism evaluations in Kansas can already run a year or more, and that under the new standard the work would currently fall to the University of Kansas Health System and Children’s Mercy. Much of the evaluation capacity outside clinical psychologists comes from master’s-level clinicians, she said, and they matter most in rural areas, where local evaluators spare families in places like Dodge City or Garden City a trip of up to eight hours.
The state’s licensing board started moving before the bulletin was published. At its July 20 meeting, the BSRB approved by consensus a working group of advisory committee members. Executive Director David Fye told Acuity in an email that the board’s brief discussion that day “did focus on authorizing a working group to begin meeting concerning what we were hearing about the autism diagnosis requirement that would later appear in the bulletin.” The board’s Behavior Analyst Advisory Committee noted the group’s creation at its August 14 meeting.
The group, formally the Subcommittee on Behavior Analyst Services and KDHE Policy Changes, held its first meeting on October 22 and reached consensus on two recommendations to the full board: that the board ask KDHE to hold implementation while the subcommittee collects data and develops further recommendations, and that the board state publicly that it is not changing what its licensees may legally do. Fye said he would brief KDHE on the recommendations before the full board meets on November 9, eight days after the rule’s start date. The subcommittee is aiming to meet again on October 29 or 30 if it can reach a quorum, Fye told Acuity.
In framing the discussion, Fye told members that the BSRB regulates licensure, not Medicaid reimbursement. He said KDHE had earlier asked the board about K.S.A. 65-7502, which defines treatment for autism spectrum disorder as care prescribed or ordered by a licensed physician or licensed psychologist, and that the board pointed KDHE to the exemption in the same act for other BSRB licensees practicing within their scope. The board’s September 2026 licensing report counts 1,063 Licensed Psychologists at the doctoral level. It also counts 642 permanent master’s-level psychology licensees (359 Licensed Master’s Level Psychologists and 283 Licensed Clinical Psychotherapists), along with 1,905 Licensed Clinical Professional Counselors, 3,746 Licensed Specialist Clinical Social Workers and 976 Licensed Clinical Marriage and Family Therapists, independent-level licensees whose scope can include diagnosis. Fye noted that some clinicians hold more than one license, and told the subcommittee the board does not have data on how many of its licensees evaluate for autism.
Other States Are Drawing the Diagnostic Line Differently
Not every state is drawing the line where Kansas did. Alabama Medicaid told pediatricians in June that an autism diagnosis would support an ABA referral only if the pediatrician added a new ABA specialty designation, and said Certified Registered Nurse Practitioners could not make the diagnosis for that purpose. As Acuity reported this month, the Alabama referral rule remains paused with no new date.
Virginia is moving the opposite way on who can diagnose. Its 2026 Appropriation Act directs the Department of Medical Assistance Services (DMAS) to require an autism diagnosis before authorizing ABA, and the Mental Health Services Manual changes DMAS proposed to carry that out would accept a diagnosis from a Licensed Mental Health Professional acting within their scope of practice. Under Virginia’s regulatory definition, that category includes Licensed Professional Counselors and Licensed Clinical Social Workers, the kinds of master’s-level clinicians Kansas is leaving out. Like Kansas, the Virginia proposal calls for a validated tool such as the ADOS or CARS. Unlike Kansas, it lets children 5 and younger begin ABA on a provisional diagnosis while they wait for a full evaluation. DMAS listed a planned effective date of October 22; the public comment period closed October 21 with 62 comments, and DMAS had not posted a final version as of October 22.
Texas widened its own list this summer for the state-funded Children’s Autism Program, which Acuity reported this month faces elimination in HHSC’s 2028-29 budget request. Rules effective August 25 added Nurse Practitioners and Physician Assistants to the clinicians who can make a qualifying diagnosis, after commenters, including Texas Nurse Practitioners, told HHSC that limiting diagnosis to physicians and psychologists conflicted with nurse practitioners’ scope of practice under state law.
Michigan also kept its door wide. Bulletin MMP 26-18, issued October 1, keeps a broad list of clinicians who may make the diagnosis while adding six-month progress reviews and barring discharge on a set timeline.
Diagnostic rules are one layer of a wider oversight build-out in Medicaid ABA. North Carolina’s health plans have formed a joint fraud task force with closed networks and unannounced site visits, federal auditors have produced a run of findings Acuity has tracked in its review of OIG Medicaid ABA audits, and Florida has credited utilization controls and enforcement for a projected ABA spend nearly $1 billion below forecast.
What the Kansas Diagnosis Rule Means for ABA Providers
For Kansas ABA organizations, the practical work starts with the chart. Every active KanCare client 20 or younger needs a record of who made the diagnosis, under what license, and with which instrument. Clients diagnosed by a doctoral psychologist or a listed physician with a validated tool are unaffected. Clients diagnosed by a master’s-level clinician, a Nurse Practitioner or a Physician Assistant need a confirming diagnosis before the two-year window closes, and those whose original evaluation lacked a validated tool need one administered at re-evaluation.
Waitlists need the same audit, and sooner. Families who are not yet in treatment do not get the two-year cushion, so a non-qualifying diagnosis on the intake file is a reason to start the referral for a new evaluation now rather than when an ABA slot opens.
Timing will differ by payer. Because KDHE warns that managed care implementation may not match the bulletin date, providers should confirm with each KanCare plan (Healthy Blue, Sunflower Health Plan and UnitedHealthcare Community Plan) when its claims system will begin enforcing the rule, and watch the Open Claims Resolution Log for reprocessing notes.
The open question is capacity. The bulletin does not say how many enrolled KMAP providers meet the new standard, and KDHE has not published how many current members were diagnosed by clinicians who do not. Those two numbers will decide whether two years is a comfortable runway or a tight one, and whether new referrals after November 1 wait weeks or, as Wilbert described, far longer.
