New York Medicaid froze new ABA provider enrollments and change of ownership processing for six months. What the moratorium covers and whose deals stall.
Key Takeaways
- New York froze new Medicaid provider enrollments effective July 30: Medicaid Director Amir Bassiri announced the six-month moratorium during the State of the State of New York Medicaid presentation at the United Hospital Fund’s 2026 Medicaid Conference. The Department of Health has said it will not process applications during the moratorium regardless of what stage they have reached.
- ABA is the newcomer on a list of traditional fraud-risk categories: The freeze covers laboratory, durable medical equipment, Applied Behavior Analysis, Licensed Home Care Services Agencies, pharmacy, and Managed Long Term Care plans. Five of the six are provider types states and CMS have restricted before.
- Change of ownership processing stops alongside new enrollments: Equity transactions typically require an update to the acquired provider’s Medicaid enrollment, so pending deals in the six categories are likely to stall. Structures that require neither a new enrollment nor an enrollment update may not be impacted.
- The state frames the pause as temporary infrastructure work: DOH has been phasing enrollment onto its Provider Services Portal since September 2025 and has not yet shipped the release handling revalidation and change of ownership online. The moratorium pauses the transactions that release is being built to carry.
New York State has stopped accepting new Medicaid provider enrollments in six provider categories, including Applied Behavior Analysis, for at least six months. Medicaid Director Amir Bassiri announced the moratorium on July 30, 2026 during the State of the State of New York Medicaid presentation at the United Hospital Fund’s 2026 Medicaid Conference. The pause took effect immediately.
The freeze applies to new enrollment applications and to the processing of affected change of ownership (CHOW) applications. The New York State Department of Health has said it will not process applications during the moratorium regardless of the stage an application has reached, catching files already in review.
What the New York Medicaid Enrollment Moratorium Covers
The moratorium covers six categories: laboratory, durable medical equipment (DMEPOS), Applied Behavior Analysis, Licensed Home Care Services Agencies (LHCSAs), pharmacy, and Managed Long Term Care plans. Five are the traditional fraud-risk provider types that states and CMS have restricted before. ABA is the newcomer. DOH identified the six by reference to the “high” categorical risk tier, and under 42 CFR 455.450 those tiers are set by each state, so the designation is New York’s own. It follows the screening posture behind Alabama Medicaid’s facility and signage requirement for ABA enrollment and South Carolina’s alignment of its ASD provider manual with federal high-risk screening rules.
Change of Ownership Processing and ABA M&A Deal Timing
Equity deals commonly require an update to the acquired provider’s Medicaid enrollment, so pending and planned transactions in the six categories are likely to be halted. Structure decides exposure. When an Oklahoma ABA provider changed hands through a membership interest purchase, the enrolled entity and its provider numbers stayed the same even though control changed completely. Whether DOH will also pause other CHOW approval steps, including the Schedule 1 process for LHCSA transactions, is unresolved. The timing is awkward for a sector in motion: Mergium Advisors counted 22 pediatric therapy transactions in the first half of 2026, and several large ABA platforms have been positioning for sale.
CMS Medicaid Provider Revalidation and New York’s Enrollment Portal Rebuild
On April 23, 2026, CMS Administrator Mehmet Oz asked every state Medicaid director for a comprehensive two-year provider revalidation strategy within 30 days. The letter set no deadline for revalidating every enrolled provider. It urged states to adopt off-cycle intervals shorter than the five-year federal minimum for provider types they designate high risk. CMS has also run its own moratoria this year, pausing new DMEPOS suppliers in February and home health agencies in May, while leaving the parallel Medicaid decision to states. New York went further than the federal template, which exempts most ownership changes.
New York is absorbing that request mid-rebuild. The Department has been phasing enrollment onto its Provider Services Portal since September 2025, opened the portal to organizational provider types this spring, and discontinued paper enrollment applications in July. The release that will let existing providers handle revalidation, changes of ownership, and reinstatement online has not shipped. The moratorium pauses the transactions that release is being built to carry, a sequencing problem showing up wherever state Medicaid systems are being modernized at once.
For ABA providers, the freeze lands on an already narrow benefit. New York completed a 25 percent cut to its technician-delivered ABA rate on April 1, 2026, bringing CPT code 97153 to $14.45 per 15-minute unit, after a joint survey by the New York State Association for Behavior Analysis (NYSABA) and the Council of Autism Service Providers found 74 percent of responding Medicaid ABA providers would consider leaving if the reduction took effect. Enrollment friction carries its own cost: an Indianapolis ABA provider that shut down in June cited Medicaid payment holds and credentialing backlogs among the reasons it never recovered.
DOH had not published written guidance as of July 31. Acuity has requested comment from the Department and NYSABA, and will update this article.
