The video is grainy but the scheme is clear. A woman sits at a computer, ostensibly taking a certification exam to become a registered behavior technician. Off-camera, a man’s voice coaches her through the answers. At one point, he leans into the frame. She had paid two thousand dollars for this service: someone to walk her through the test, or really, to take it for her.

What the woman, Grisel Farinas, didn’t know was that the testing center was recording. The footage would become federal evidence. Within months of obtaining her fraudulent credential, investigators say, Farinas billed Medicaid more than a hundred and twenty-eight thousand dollars for therapy she never provided to two boys with autism. She claimed ten hours a day, five days a week, holidays included. Surveillance showed her spending an hour or two at the home, then leaving.

She pleaded guilty to healthcare fraud in 2022 and served a month in prison. But her case was not an aberration. It was a symptom.

Applied behavior analysis, or ABA, has become one of the fastest-growing line items in state Medicaid budgets. It has also become one of the most vulnerable to fraud. In South Florida, the problem manifested as credential mills and phantom billing. In Minnesota, it metastasized into something more elaborate: an organized network of sham providers with ties to Feeding Our Future, the $250 million child nutrition fraud scheme that became one of the largest pandemic-era theft schemes prosecuted to date.

The mechanics differ, but the underlying math is the same. ABA therapy can bill fifty to a hundred and fifty dollars per hour. A single child might be authorized for thirty or forty hours a week. Multiply that across a caseload, and you have a business model. For the unscrupulous, a jackpot.

The South Florida Problem

Miami-Dade County now has more registered behavior technicians than does the entire state of California. That statistic, cited by the Florida Association for Behavior Analysis in its 2024 Annual Report, captures the peculiar geography of ABA fraud. Of the $1.5 billion Florida Medicaid paid for ABA services in 2023-2024, more than half flowed to providers in Miami-Dade alone.

The cheating was so widespread that testing companies ended remote certification exams in March 2021. By then, the damage was done. Florida has no state licensure requirement for individual behavior analysts, relying instead on certification. In 2018, the state’s Agency for Health Care Administration imposed a moratorium on new ABA provider enrollment in Miami-Dade and Broward counties. The agency also rolled out a GPS tracking pilot program, requiring therapists to verify their location via smartphone when billing for services. The message was unmistakable.

For families who depend on ABA, the crackdown has created collateral damage. Wait lists have grown. Some providers have stopped accepting Medicaid altogether. “You’re cheating families, you’re cheating kids, vulnerable kids,” one Miami mother told NBC6. “And it’s just not fair.”

Minnesota’s Web

If South Florida’s fraud was opportunistic, Minnesota’s was industrial.

In December 2024, FBI agents raided two autism treatment centers: Smart Therapy in Minneapolis and Star Autism Center in St. Cloud. The search warrants revealed something investigators had suspected for months. The same networks that had orchestrated Feeding Our Future, the $250 million child nutrition fraud scheme, had moved into autism services. While Feeding Our Future represented a staggering sum, it was far from the largest pandemic-era fraud; the Government Accountability Office has estimated that $135 billion in unemployment benefits were likely claimed illegally between 2020 and 2023, and the Small Business Administration’s inspector general put pandemic loan fraud at more than $200 billion. Minnesota’s fraud schemes, though significant, operated on a smaller scale.

At least twelve defendants charged in the Feeding Our Future case owned or were associated with autism centers receiving state funds. The playbook was similar: create a provider, bill for services that don’t exist, pocket the difference. But the autism scheme had refinements. Parents were paid monthly kickbacks, ranging from three hundred to fifteen hundred dollars per child, to enroll their kids. Some parents shopped around for higher payments, threatening to leave for competitors who offered better terms.

The first defendant charged, Asha Farhan Hassan, pleaded guilty in December 2025 to stealing $14 million through Smart Therapy. Prosecutors say she employed unqualified teenagers as “behavioral technicians,” submitted claims for services never provided, and sent hundreds of thousands of dollars to Kenya, where she purchased real estate. She had also participated in the Feeding Our Future scheme, pocketing an additional $465,000 by claiming Smart Therapy was serving 1,200 meals a day to children.

Dr. Eric Larsson has spent twenty years building Minnesota’s autism treatment infrastructure. As the executive director of clinical services at the Lovaas Institute Midwest and immediate past president of the Association for Science in Autism Treatment, he had helped shape a system he considered a model: rigorous but flexible, accountable but not bureaucratically suffocating. Then the headlines came. “Of course, we were all shocked when these large numbers of fraud started coming out,” Larsson said. What he didn’t expect was that the state’s response would threaten to destroy the good providers along with the bad.

Following political pressure, including from a federal government eager to make an example of the state, Governor Tim Walz ordered a ninety-day pause on payments to high-risk Medicaid programs while the state hired Optum to scrutinize claims. For small providers operating on thin margins, that timeline is existential. “None of us have the reserves to make payroll for three months,” Larsson said. “They’re throwing the baby out with the bathwater because the vast majority of the providers are already providing highly regulated services and providing them in a very legitimate way.”

The payment disruptions have already begun. Fourteen designated high-risk Medicaid programs, including autism services, received no payments on December 30th. A partial catch-up arrived on January 13th, but providers remain in the dark about what happens next. The Optum system, an AI-driven claims review, is a black box. “We have no assurance how well this new system is going to work,” Larsson said. “None of us have any idea about how many claims are going to come through.”

The numbers tell a story of a program that grew faster than anyone could monitor. Minnesota’s EIDBI program, Early Intensive Developmental and Behavioral Intervention, paid out $1.7 million in 2017. By 2023, that figure had ballooned to roughly $400 million. From 2018 through 2025, autism providers billed a cumulative $1.6 billion across the state’s Medicaid programs.

Acting U.S. Attorney Joseph Thompson has called the situation unprecedented. “What we see in Minnesota is not a handful of bad actors committing crimes,” he said at a December 2025 press conference announcing the first autism fraud charges. “It’s a staggering, industrial-scale fraud. It’s swamping Minnesota.” Thompson estimated that half or more of the $18 billion billed through the state’s fourteen high-risk Medicaid programs may be tied to fraud—though that figure encompasses Department of Education fraud and business fraud in addition to Medicaid, and some experts consider the estimate inflated given that Minnesota spends roughly $18 billion annually on all Medicaid services combined.

The Shared Vulnerability

What made ABA such an attractive target? The answer lies in how the benefit is structured.

In July 2014, the Centers for Medicare and Medicaid Services issued guidance clarifying that all state Medicaid programs were already required, under existing Early and Periodic Screening, Diagnostic, and Treatment rules, to cover medically necessary autism services for children. States scrambled to build provider networks. Reimbursement rates were often generous, necessary to attract qualified clinicians to a labor-intensive field. But the same rates that made ABA viable for legitimate providers made it irresistible to fraudsters.

The therapy itself is hard to audit. ABA happens in homes, in schools, in the community, anywhere a child might need to practice skills. Documentation requirements vary by state. Supervision models differ. And the sheer volume of hours authorized for intensive treatment means that even small-scale billing fraud can add up quickly.

But is ABA inherently more vulnerable to fraud than other therapies? Daniel Unumb, an attorney who has spent years fighting to expand autism coverage and a former Department of Justice lawyer, pushes back on that narrative. “I don’t see anything inherently [about] why this would lend itself to fraud if you are actually overseeing it,” he said. In fact, he argues, ABA has more guardrails than many comparable services. “Almost in every case, unlike so many other therapies in the Medicaid sphere, this is all pre-authorized,” Unumb said. “Some utilization review management person takes a look at the treatment plan, takes a look to see that there’s a diagnostic requirement that’s been met, takes a look at assessments. There’s a lot more eyes on ABA treatment than there are for many other types of treatment.”

What Florida and Minnesota may have shared, Unumb said, was looser credentialing for who could deliver services, not limiting providers to Board Certified Behavior Analysts or those supervised by them. “You didn’t have the same kind of level of controls,” he said. “The program itself wasn’t set up” the way most states structured their ABA Medicaid benefits.

In Minnesota, the legitimate providers had seen the problem coming. Larsson and his colleagues lobbied for a new licensing law two years ago requiring credentials for individual practitioners; last year, they got a second law mandating that agencies themselves be licensed. The Behavior Analyst Certification Board, where Larsson once served, had already spent years securing its testing process against fraud and hacking. The Council of Autism Service Providers had launched a national accreditation program. “We’ve been doing a lot to make sure that any family that seeks services, if they’re getting services from a certified behavior analyst or a licensed behavior analyst, they have that protection,” Larsson said. What he hadn’t anticipated was that all these controls would prove insufficient to stem the political fallout.

Federal audits have flagged ABA payments elsewhere: at least $56 million in Indiana, according to a December 2024 HHS Office of Inspector General report, and $18.5 million in Wisconsin, per a July 2025 audit. Minnesota had 85 open investigations into autism providers as of mid-2024, before the FBI raids, before the first charges. The HHS Office of Inspector General has made ABA a national audit priority. It is worth noting, however, that “improper” payments identified in these audits are not synonymous with fraud; in many cases, the resulting recommendations focused on clarifying billing procedures rather than pursuing criminal charges.

The question now is whether states can root out the fraud without destroying access to care. In Florida, the moratorium and GPS tracking have made it harder for new providers to enter the market, including the good ones. In Minnesota, the state shut down its Housing Stabilization Services program entirely on October 31, 2025, after fraud overtook legitimate claims. Could EIDBI be next?

The Families in the Middle

For parents of children with autism, the fraud epidemic is an abstraction until it isn’t. The therapist who doesn’t show up. The provider who closes suddenly. The wait list that never seems to move.

In Minnesota, Larsson said, families are living with a fear that has become immediate and concrete: that the services their children depend on could simply vanish. “We’re not just talking about young children in preschool or school age,” he said. “We’re also talking about adults who are dependent on personal care visits to their home in order even just to stay alive.” The uncertainty spans the entire continuum of care. “Families are worried now they’re losing their access to the early intervention they know their child needs, or they’re losing their access to integrated services in schools, or they’re losing their access to safe help in the community or in group homes,” Larsson said. “And right now there’s no answer.”

The collateral damage extends beyond access. Unumb, who also co-founded the Autism Academy of South Carolina, worries that fraud scandals will poison the well for families who have never encountered ABA. “New families who are trying to investigate, well, what therapies are available for my child? They may forego what is essentially the gold standard, most effective therapy,” he said. “They’re saying, ‘Oh, geez, I’ve seen ABA in the news and it sounds like it’s just a bunch of fraud going on. I don’t want to get wrapped up in that with my kids.’”

The deeper irony, Unumb noted, is that ABA was never a field that attracted grifters. “It’s a do-gooder profession,” he said. “These people are not making scads of money.” The fraudsters came later, once ABA had grown large enough to attract their attention. “I just think nobody was anticipating,” Unumb said, “and now it’s just kind of the reality check that, like everything else, this can happen.”

The prosecutions will continue. Thompson’s office has charged roughly a hundred people across Minnesota’s various fraud schemes, with more than sixty convictions to date. Florida’s HHS-OIG office continues to investigate. But the deeper problem—a benefit structure that invites exploitation, a workforce pipeline that can’t keep pace with demand, a regulatory apparatus built for a smaller world—remains unresolved.

In the meantime, Medicaid programs are learning a hard lesson about the gap between good intentions and good design. ABA coverage was supposed to give children with autism a chance at a better life. For some families, it has. For others, it has become one more thing to fight for, and one more thing that might be taken away.

Unumb’s message to families caught in the middle: “Don’t lose your faith in the therapy or those who provide it. The vast majority are dedicated people who are working in incredibly difficult circumstances to make sure that your child can access the most effective therapy available.”

Larsson, for his part, mourns what Minnesota had built and fears what it might lose. Before the fraud headlines, before the payment freeze, the state had developed something rare: an autism benefit flexible enough to give each child the right level of treatment, accountable enough to track outcomes, and efficient enough to avoid the rigid, one-size-fits-all models that plagued other states. “We’d already gotten to a place where the Minnesota system was very flexible, but also had that high level of accountability,” Larsson said. Now, the state is layering on additional controls—what Larsson calls a “meat cleaver approach”—that may set back years of progress. Whether that progress can survive the political storm remains to be seen.