MassHealth proposes to re-adopt its ABA fee schedule unchanged on December 1, 2026, keeping 97153 at $16.37 and 97155 at $30.73 as providers press for rate reviews.
Key Takeaways
- Flat rates under fire. MassHealth reimburses roughly $65 an hour for direct ABA, a figure providers told lawmakers trails Arizona ($88) and Maryland ($83). Advocates argue the rates have not kept pace with inflation or labor costs, narrowing provider participation.
- A proposed rate freeze. EOHHS filed a proposed regulation on May 22, 2026, that re-adopts 101 CMR 358.00 effective December 1, 2026, with the fee schedule unchanged from October 2024. The agency states it reviewed the rates and proposes to maintain them, projecting no change in aggregate MassHealth spending.
- A statutory adequacy test. State law requires MassHealth rates to be adequate for efficiently and economically operated providers and to be reviewed at least biennially for non-institutional services. Bills H4353 and S2587 would add a dedicated, data-driven ABA rate-review requirement.
- An open comment window. EOHHS will hold a remote public hearing on June 17, 2026, and accept written testimony through 5:00 p.m. that day, specifically inviting comment on access effects. The decision lands against the backdrop of a contested 2024 recoupment audit.
Massachusetts is on track to hold its Medicaid reimbursement for applied behavior analysis (ABA) flat through 2026, even as the providers who deliver autism care argue the rates are already too low to sustain. On May 22, 2026, the Executive Office of Health and Human Services (EOHHS) filed a proposed regulation that would re-adopt the state’s ABA fee schedule, 101 CMR 358.00, effective December 1, 2026, with every payment figure unchanged from the version that took effect in October 2024. EOHHS will take public testimony on the proposal at a remote public hearing on June 17, 2026, and will accept written comments through 5:00 p.m. that day. The agency has specifically invited comment on whether the unchanged rates would affect access to services, signaling that testimony could still influence the final rule.
For a benefit under steady financial and political pressure, the proposal is notable for what it does not do. The agency states plainly that it reviewed the rates and proposes to maintain them, and it projects no change in aggregate MassHealth spending as a result. That decision arrives while providers face a contested recoupment audit, a workforce squeeze, and a newly expanded population of eligible children.
Inside MassHealth’s Proposed ABA Fee Schedule: What 101 CMR 358.00 Pays in 2026
The proposed schedule carries seven payment lines, each priced per 15-minute unit and reimbursed at the lower of the provider’s usual charge or the listed rate. Behavior identification assessment (97151) pays $30.73; technician-delivered treatment (97153) pays $16.37; group treatment (97154) pays $13.91; analyst-delivered treatment with protocol modification (97155) pays $30.73; family guidance (97156) pays $30.73; multiple-family guidance (97157) pays $26.12; and a home-services assessment line (H0031-U2) pays $30.73. At $16.37 per unit, 97153 works out to roughly $65 an hour, the precise figure providers have cited to lawmakers.
CPT 97153 (technician-delivered adaptive behavior treatment), base rate per 15-minute unit. Source: MediRate.
CPT 97155 (analyst-delivered adaptive behavior treatment), base rate per 15-minute unit. Source: MediRate.
Against its neighbors, Massachusetts sits in the upper-middle of this group for technician treatment and at the top for analyst treatment. Its $16.37 for 97153 trails New Hampshire ($17.79) but leads Connecticut ($14.00) and New York ($14.45), the latter having cut its technician rate effective April 2026. For analyst-delivered 97155, the state’s $30.73 outpaces New Hampshire ($16.43) and New York ($19.26); Connecticut was excluded because it does not bill the code.
The benefit reaches MassHealth members under 21 with a diagnosis of autism spectrum disorder or, as of January 1, 2026, Down syndrome, an expansion that broadens demand even as the unit price holds steady. Providers that bill the program must file annual audited financial statements, and the purchasing agency may impose a penalty of up to fifteen percent of payments on providers that fail to report.
The benefit rests on a layered legal foundation. Massachusetts first required commercial autism coverage through its 2010 insurance mandate, and MassHealth’s coverage of ABA for members under 21 with autism is codified in Chapter 118E, with treatment supervised by a board-certified behavior analyst. The rate regulation itself is set under the same chapter and, by its terms, pays the lower of a provider’s usual charge or the listed fee, language that caps but does not floor what a provider can collect.
In practice, the ABA benefit is administered through managed care: six health plans run it, and the rate regulation sets the schedule those plans and the fee-for-service program work from. That structure matters when the state changes course, because payment and enforcement decisions reach providers through the plans rather than directly, a dynamic at the center of the recoupment fight described below.
Why Massachusetts ABA Providers Say the Rates Fall Short
The case against the freeze rests on both comparison and statute. Testifying before the Joint Committee on Health Care Financing, Dr. Maria McClain of the Massachusetts Association for Applied Behavior Analysis told lawmakers that Massachusetts reimburses roughly $65 an hour for direct ABA, against about $88 in Arizona and $83 in Maryland, and that rates have not kept pace with inflation or labor costs, thinning provider participation. The comparison figures are advocacy testimony rather than a single standardized benchmark, but they track the direction of the state’s own published schedule.
Two bills, H4353 and S2587, would require MassHealth to conduct regular, data-driven ABA rate reviews weighing cost-of-living comparisons and recruitment and retention trends; their backers stress the measures would not mandate automatic increases. The push intersects with existing law: under Chapter 118E, MassHealth rates must be adequate to meet the costs of efficiently and economically operated providers, and rates for non-institutional services are to be reviewed at least biennially. The freeze tests how much that adequacy standard requires when providers and the state disagree on what adequate means.
Two pressures compound the math. The eligible population is growing, with Down syndrome added to the benefit at the start of 2026, even as the analyst pipeline tightens: the first-time pass rate on the national certification exam has fallen to a record low, according to data from the credentialing board, and, as Acuity has reported, providers cover cases with clinicians who hold the credential but await payer enrollment. Flat unit prices, a wider mandate, and a thinner workforce are hard to reconcile, which is the crux of the providers’ argument that the schedule should at least be reviewed on a fixed cadence.
ABA Rates Meet the Audit: Massachusetts’s Program-Integrity Crackdown and the Path Ahead
The rate proposal cannot be read apart from the enforcement climate around it. As Acuity reported, MassHealth conducted a retrospective audit of 2024 ABA claims and directed Carelon Behavioral Health to issue recoupment letters in early 2026, demanding repayment from providers whose billed analyst supervision fell below a ratio the state had not codified as a payment condition. Providers, a managed care plan, and trade associations disputed the methodology, and the dispute has escalated toward litigation.
The substance of that dispute bears on the rate debate because it turns on the same supervision economics. MassHealth measured supervision solely by paid units of 97155 against direct-service units of 97153, a ratio providers say ignores supervision bundled into other codes or delivered in non-billable forms, and that the health plan Point32Health called potentially flawed in a formal objection. The Massachusetts Office of the Inspector General, in its 2024 annual report, described the performance specifications underlying the audit as contractual expectations rather than regulations, a distinction the providers’ attorneys have pressed because state law limits retroactive claim denials after twelve months to narrow grounds such as fraud or regulatory noncompliance.
Providers have urged the state to lean on an accreditation-first model instead. The MassHealth vendor contract already requires ABA providers to obtain accreditation through nationally recognized bodies, with deadlines of January 1, 2027 for center-based providers and January 1, 2028 for others, and advocates argue that direct review of supervision and treatment quality is a fairer measure than a billing ratio. That argument is part of a broader shift toward objective quality measurement across autism care.
Providers also point to history. In 2018, MassHealth ordered its managed care entities to pause behavioral-health audit activity after concluding the reviews had moved forward with insufficient engagement with providers, a precedent the current coalition invokes in arguing that the 2024 recoupment repeated the pattern. It is one reason providers contend the rate-setting and the audit should be weighed together rather than on separate tracks.
Massachusetts is hardly alone in tightening the screws. Its posture sits alongside rate cuts in Indiana, managed care reductions elsewhere, and audits in neighboring states, even as states at the higher end of the national range, such as Arizona, show how far apart Medicaid ABA pricing can be. For Massachusetts families on waitlists and the providers who serve them, the June 17 hearing is the near-term pressure point: EOHHS has specifically invited comment on how the unchanged rates would affect access, and it has said it may revise the proposal in response. Whether testimony moves a schedule the agency has already proposed to keep flat is the question the comment window will answer.
