Key Takeaways
- The FY2026 enacted budget already authorized two Medicaid rate reductions for CPT code 97153, the primary billing code for one-to-one ABA therapy: the first brought the rate to $16.85 per 15-minute unit on October 1, 2025; the second will reduce it to $14.45 per unit on April 1, 2026, per the New York State Department of Health.
- Part M of the FY2027 Health and Mental Hygiene Article VII bill would add a new coverage condition for ABA: services would only be covered under Medicaid when recommended by a health care practitioner who has been designated as an applied behavior analysis center of excellence provider by the commissioner of health. That designation requirement does not exist in current law, and its criteria are not defined in the bill.
- The state’s multi-year financial plan projects further ABA reimbursement reductions beyond the April 1 cut. CASP estimates that a cumulative 50 percent reduction from the original base rate would bring 97153 to approximately $9.63 per unit, against a 2024 national average of $15.70 per unit. CASP characterizes that endpoint as the lowest publicly available Medicaid rate for the code in the country.
- CPT 97153 accounts for an estimated 80 to 90 percent of billable charges at most ABA practices, per CASP. Approximately 30,000 New York Medicaid beneficiaries are currently eligible for the ABA benefit.
- CASP has launched a Voter Voice campaign urging New York families and providers to contact legislators ahead of the April 1 budget deadline. The organization coordinated with NYSABA last year on the push to phase the FY2026 reductions rather than implement them immediately.
Somewhere in the middle of last year’s budget negotiations, New York’s applied behavior analysis providers made a calculation. Governor Hochul had proposed a 50 percent cut to the state’s Medicaid reimbursement for one-to-one ABA therapy, and after weeks of coordinated pressure from the Council of Autism Service Providers (CASP), the New York State Association for Behavior Analysis, and a coalition of provider organizations, the governor’s office agreed to a phasedown instead: two reductions of 12.5 percent each, spread over the coming fiscal year.
The first took effect October 1, 2025, bringing the reimbursement rate for CPT code 97153 to $16.85 per 15-minute unit. The second is scheduled for April 1 and is already on the books, authorized in the FY2026 enacted budget and confirmed by the New York State Department of Health: $14.45 per unit.
That cut arrives in April, regardless of what happens in Albany between now and then. But before providers and advocates have had time to assess its impact, Governor Hochul’s FY2027 executive budget has introduced a separate proposal that has drawn its own wave of opposition, one with a different mechanism and potentially farther-reaching consequences for how families access care.
What Part M Would Do
Part M of the Health and Mental Hygiene Article VII bill filed with the FY2027 executive budget would amend the Social Services Law to impose a new coverage condition on Medicaid ABA services. Under the bill language, ABA would only be covered when services have been recommended by a health care or mental health care practitioner who has been designated as an applied behavior analysis center of excellence provider by the commissioner of health.
That language matters because a referral requirement for ABA already exists. Under current New York Medicaid policy, ABA services must be ordered by a licensed, Medicaid-enrolled physician, psychologist, psychiatric nurse practitioner, pediatric nurse practitioner, or physician assistant before a provider can bill Medicaid. Part M would not eliminate that requirement. It would add an additional layer: the referring clinician must also hold a separate DOH-issued center of excellence designation. Without it, a referral from an otherwise qualified physician or psychologist would no longer be sufficient to trigger Medicaid coverage.
The criteria for earning that designation do not appear in the bill. They would be determined later, by the Department of Health, through an administrative process. That ambiguity is among the central concerns advocates have raised. New York’s ABA provider landscape includes large, multi-site organizations with established referral networks and compliance infrastructure, and it includes small, community-based practices serving the Bronx, Staten Island, and rural counties where alternative providers are limited or nonexistent. A designation framework with undefined criteria could, in practice, restrict referrals to providers served by a subset of designated clinicians, without those effects being explicitly authorized by the legislature. The bill language specifies that the provision does not modify any licensure, certification, or scope of practice provision under the education law, meaning the change affects the coverage condition, not who may legally practice.
The state’s framing for the ABA provisions in the FY2027 executive budget briefing book is “Standardize Applied Behavioral Analysis,” positioning the changes as policy rationalization rather than cost-cutting alone. During Senate budget hearings earlier this year, CASP said it learned from the state that the financial plan’s rate reductions would primarily target direct one-to-one services.
CASP’s Voter Voice campaign, launched this week, describes the governor’s budget as proposing rate cuts, additional rate reduction authority, and the center of excellence model, attributing all three to Part M. The Article VII bill as filed contains the center of excellence provision; the April 1 rate reduction and the longer downward trajectory are embedded in the FY2026 enacted budget and the state’s multi-year financial plan. CASP is using the FY2027 budget process as the pressure point to challenge both.
The Rate Trajectory
The April 1 cut will bring CPT 97153 below the 2024 national average for the first time. CASP’s data puts that average at $62.80 per hour, or $15.70 per 15-minute unit. The April 1 rate of $14.45 lands beneath it, and the financial plan’s trajectory points lower still.
According to CASP’s advocacy materials, a cumulative 50 percent reduction from the original base rate would bring 97153 to approximately $9.63 per unit. CASP has described that endpoint as the lowest publicly available Medicaid reimbursement for the code in the country, a characterization the state has not publicly disputed. The state cuts are calibrated against a 2021 benefit that, by NYSABA’s own accounting, was not widely utilized until 2023, when most implementation barriers had been resolved. The provider community that built up to serve Medicaid patients during those years did so at reimbursement levels the state now appears committed to reducing.
New York was among the last states in the country to implement a Medicaid ABA benefit, according to NYSABA testimony submitted to the legislature during last year’s budget cycle, which placed it 49th. The benefit launched in August 2021 for fee-for-service Medicaid and was extended to Medicaid managed care in October of that year. Managed care carved ABA in as a covered benefit effective January 1, 2023, completing the full rollout. The rate reductions began before that rollout had time to fully stabilize.
CPT code 97153 covers adaptive behavior treatment delivered by a registered behavior technician under clinical supervision. CASP estimates it accounts for 80 to 90 percent of charges at most ABA practices, which means its reimbursement rate functions as a rough proxy for the financial viability of ABA services broadly. Approximately 30,000 New York Medicaid beneficiaries are currently eligible for the benefit.
Before the Gavel
New York’s budget is constitutionally due April 1, the same morning the second tranche of the rate phasedown takes effect. The Assembly and Senate each typically release their own one-house budget proposals in mid-March, and it is in that narrow window, before the final closed-door conference negotiations begin, that outside advocacy tends to find its purchase. CASP’s Voter Voice campaign is timed precisely for this interval, designed to make both the rate trajectory and the Part M gating provision politically inconvenient before legislative leaders are asked to defend them at the negotiating table.
The organization is coordinating with NYSABA and other advocacy partners on outreach to the Assembly Ways and Means Committee and the Senate Finance Committee, chaired respectively by J. Gary Pretlow and Liz Krueger, whose committees will hold significant influence over what survives into the final conference agreement. Neither has publicly signaled a position on the ABA provisions. This year, budget watchers have noted, Krueger has expressed optimism about an on-time budget, which could shorten the window advocates typically count on.
The federal oversight environment adds a layer of context the state has not publicly acknowledged. The HHS Office of Inspector General has completed a series of audits of Medicaid ABA programs, finding at least $56 million in improper fee-for-service payments in Indiana (covering 2019 and 2020), at least $18.5 million in Wisconsin (2021 and 2022), and at least $45.6 million in Maine, in a report released in January 2026. The OIG has indicated additional state audits are forthcoming. New York has not cited those findings as a rationale for either the rate cuts or the center of excellence proposal. The state’s own framing, centered on standardization, suggests the goal is policy uniformity as much as expenditure control, though the net effect on provider finances is consequential either way.
The Quiet Exits
What the April 1 cut means for a given practice depends on its cost structure, and in New York, those costs run high. Registered behavior technicians, who deliver the bulk of 97153 services, command wages shaped by the state’s minimum wage trajectory and a competitive labor market. The margin between what Medicaid reimburses and what it costs to employ and supervise a technician has been narrowing for several years.
Providers and advocates have noted that Medicaid disenrollment rarely announces itself. A practice stops accepting new Medicaid referrals. A location in a lower-reimbursing zip code closes. A caseload that was half Medicaid becomes a third, then a smaller fraction. The shift tends to be gradual and difficult to trace directly to any single policy change, which is part of what makes rate cuts difficult to argue against on access grounds until the effects are already visible. The center of excellence gating provision, if enacted, could accelerate that dynamic by narrowing the pool of clinicians whose referrals trigger coverage before a family even reaches a provider.
In testimony submitted to the legislature last year, NYSABA warned that the cuts would force providers to evaluate whether they could continue operating in New York at all. The organization argued that children who lose ABA access are at heightened risk of hospitalization or institutionalization, and that delaying early intervention tends to produce more expensive placements in more restrictive settings as those children age.
That framing, which grounds access concerns in long-run Medicaid cost logic rather than advocacy alone, has become the core of the provider community’s counter-argument to the state’s cost-containment rationale.
CASP has said it intends to monitor both the rate trajectory and the center of excellence provision through the budget process, and will escalate if the language survives the legislative negotiations intact. The budget is due in less than a month. The second rate cut arrives on the same morning.
