The October 1 bulletin rewrites Michigan’s autism treatment policy, easing two entry requirements while tightening how providers document progress.
Key Takeaways
- Michigan rewrote its Medicaid ABA policy in an October 1 bulletin. MMP 26-18 updates the Behavioral Health Treatment section of the state’s Medicaid Provider Manual for beneficiaries under 21 with an autism diagnosis.
- Two access requirements are gone or narrowed. Children no longer need a physical exam before starting services, and diagnostic re-evaluations are required only when medically necessary or requested by the family.
- Documentation standards are firmer. Interim progress assessments are due at least every six months, with standardized measurement and projected hours for each goal, under the direction of a Licensed Behavior Analyst.
- Discharge cannot follow a fixed calendar. The bulletin calls for gradual step-downs and bars denying or withholding treatment because of caregiver availability.
Michigan’s Medicaid agency has rewritten the rules that govern applied behavior analysis for children with autism. Bulletin MMP 26-18, issued October 1 by the Michigan Department of Health and Human Services and approved by Chief Deputy Director Meghan E. Groen, updates the Behavioral Health Treatment and Applied Behavior Analysis section of the department’s Medicaid Provider Manual. It is addressed to the Prepaid Inpatient Health Plans and Community Mental Health Services Programs that administer the benefit, and it applies to Medicaid beneficiaries under 21 with a diagnosis of autism spectrum disorder at any level of severity.
The bulletin moves in two directions at once. It removes or narrows two requirements families have had to meet, and it adds structure to how providers document progress and plan discharge. MDHHS says the language is consistent with recommendations from the Behavior Analyst Certification Board, the Association of Professional Behavior Analysts, Autism Speaks, and the Council of Autism Service Providers. The Michigan Health and Hospital Association flagged the final bulletin to its members on October 8. Acuity requested comment from MDHHS.
Michigan Medicaid ABA Access: The Physical Exam and Re-Evaluation Changes
The most immediate change for families is the end of the requirement that a child receive a physical examination before accessing Behavioral Health Treatment services. The pathway now runs from screening, by a primary care provider or by the PIHP or CMHSP, to a comprehensive diagnostic evaluation, a behavioral assessment by a licensed provider, and prior authorization by the PIHP. Screening itself requires no prior authorization.
The second change concerns re-evaluation. Under the bulletin, diagnostic re-evaluations for autism are not required unless a physician or other qualified licensed practitioner determines one is medically necessary, or the family or legal guardian requests one. The bulletin ties that provision to Public Act 111 of 2021, codified at MCL 400.109n. In that respect, it brings the provider manual into line with a statute that has been on the books for five years.
The list of who may make the diagnosis is broad. It includes physicians in psychiatry, neurology, developmental pediatrics, and general pediatrics with autism expertise, along with psychologists, advanced practice registered nurses, physician assistants, and master’s-level, fully licensed clinical social workers. Each must have at least two years of experience diagnosing developmental disorders, plus a year of supervised didactic learning, participation in a collaborative team model, or both. That breadth contrasts with states that have added steps at the front end of the benefit, such as Alabama’s referral rule, which remains paused.
Licensure and Supervision Under the Michigan ABA Bulletin
The bulletin updates provider qualifications to reflect Michigan’s behavior analyst licensure law, which it cites as Public Act 403 of 2016. Behavioral Health Treatment must be provided under the direction of a Licensed Behavior Analyst. The eligible team includes Board Certified Behavior Analysts with Michigan licensure, Board Certified Assistant Behavior Analysts licensed as assistant behavior analysts and supervised by an LBA, licensed psychologists with specified ABA training, and Registered Behavior Technicians or behavior technicians supervised by an LBA or a Licensed Assistant Behavior Analyst.
For psychologists, the bulletin sets a defined bar: at least two years working directly with people diagnosed with autism, completion of at least three of the academic courses the BACB requires, and a year of experience developing behavior treatment plans based on ABA. Initial assessments may be performed by an LBA, by a supervised LABA, or by a qualified psychologist working with an LBA. The LBA is responsible for supervising technicians and assistant analysts, training parents and guardians to deliver interventions, and reporting progress on goals to families at least every three to six months.
Six-Month Progress Reviews and Standardized Measurement
The documentation requirements are where providers will feel the bulletin most directly. Every behavior plan submitted for prior authorization must follow current, evidence-based, generally accepted ABA standards; measure each goal with a standardized system, for which the bulletin names the VB-MAPP and the ABLLS-R as examples; project the timeline and treatment hours needed to meet each goal; and document that a Michigan-licensed provider will deliver the services. The same elements apply to interim progress assessments, which must be submitted at least every six months. PIHPs may require them more often when individual circumstances warrant.
Projecting hours goal by goal gives PIHPs a basis for weighing authorized intensity against documented progress at each review. Documentation has been the lever of choice for ABA oversight this year, from North Carolina’s joint health plan fraud task force to Georgia’s shift from fixed supervision ratios to audits and Florida’s utilization controls. Michigan’s bulletin frames its requirements in clinical terms, citing generally accepted standards of care rather than program integrity.
The bulletin also defines two service levels. Focused ABA targets a limited number of behaviors and is not restricted by age, cognitive level, diagnosis, or co-occurring conditions. Comprehensive ABA addresses multiple domains, such as communication, social skills, and self-care, and may begin one-to-one before moving to small groups as appropriate.
Michigan ABA Discharge Criteria: No Fixed Timelines and No Caregiver-Availability Denials
The discharge section contains the bulletin’s most consequential protections for families. Discharge “should generally involve a gradual step-down in services and cannot be based on a set timeline,” with one-year and three-year limits given as examples. Treatment “should not be denied or withheld based on caregiver availability.” Goals and discharge criteria are to be set when services begin and refined as treatment proceeds, with family members and other caregivers involved in transition planning.
The LBA, with the treatment team, reviews discharge when a beneficiary loses Medicaid eligibility or Michigan residency, when the family wants to stop, when the LBA documents no measurable progress, when the family and provider cannot reconcile differences over treatment, or when goals have been met and less intensive services are appropriate.
That framework sits apart from the direction one neighbor has taken. Indiana Medicaid introduced a lifetime limit on comprehensive ABA hours on April 1, 2026, alongside a 6 percent rate cut. Michigan’s bulletin sets no hour limits and rules out calendar-based discharge, leaving duration to clinical progress as documented at each six-month review.
What Michigan ABA Providers Should Watch Next
MMP 26-18 directs providers to retain it until its contents are incorporated into the Medicaid Provider Manual. It lists its effective date as “as indicated” and does not set a separate transition schedule in its text. The practical questions now sit with the PIHPs and CMHSPs that authorize services: how quickly they update authorization forms and review templates to require goal-level hour projections, whether any will require progress assessments more often than every six months, and how they apply the bar on fixed-timeline discharge to treatment plans already in place.
The bulletin also arrives ahead of a separate federal change. The 2027 ABA CPT code set, including 97180, will require billing updates across every state program, Michigan’s included. That work runs on its own track from the clinical policy in MMP 26-18, but providers will be absorbing both in the same stretch of months.
