New NC Medicaid ABA Requirements for 2026: What Families Need to Know

North Carolina Medicaid updated its requirements for Research-Based Behavioral Health Treatment, which includes Applied Behavior Analysis services for individuals with autism spectrum disorder. The updated Clinical Coverage Policy 8F became effective August 1, 2026, and applies to both NC Medicaid Direct and NC Medicaid Managed Care.

If your child currently receives ABA therapy—or your family is preparing to begin services—these changes may affect treatment authorization, caregiver training, staff qualifications, supervision, telehealth, and documentation.

The changes do not mean that NC Medicaid has stopped covering ABA therapy. ABA remains a covered treatment when it is medically necessary and included in an authorized, individualized treatment plan.

Treatment Plans Must Be Individualized

Under the updated policy, every ABA treatment plan must be based on an appropriate
behavioral, adaptive, or functional assessment. Treatment plans must reflect the individual’s:

  • ​Strengths and abilities
  • Communication needs
  • Functional limitations
  • Adaptive skill levels
  • Developmental profile
  • Behavioral needs
  • Family priorities
  • Treatment goals

The number of ABA hours recommended must be based on the individual’s clinical needs. Providers must also consider the person’s school schedule and other ongoing services, such as speech therapy, occupational therapy, physical therapy, respite, social-skills services, and other Medicaid-funded supports.

This means ABA hours should not be based on a standard schedule that is applied to every child. Treatment intensity must be clinically appropriate and individualized.

Treatment Plans Over 16 Hours Per Week May Require More Frequent Authorization

One of the most significant changes involves treatment plans authorizing more than 16 hours of services per week.

When a treatment plan includes more than 16 hours of Research-Based Behavioral Health Treatment per week, it must be reviewed, updated, and submitted for reauthorization at least once every 90 calendar days.

All covered Research-Based Behavioral Health Treatment services count toward the 16-hour total.

Families with existing authorizations do not need to take immediate action solely because of this change. NC Medicaid stated that “existing authorization periods will not automatically be shortened.” The more frequent review requirement will be applied when the services are submitted for reauthorization.

A more frequent review does not necessarily mean that a child’s hours will be reduced. It means the provider must submit current documentation showing the child’s progress, continued clinical needs, treatment goals, and medical necessity.

Caregiver Participation Is an Important Part of ABA Treatment

The updated policy places additional emphasis on caregiver involvement. Caregivers should participate in assessment, treatment planning, and treatment delivery unless there is a documented clinical reason that participation is not appropriate.

Treatment plans are expected to include:

  • At least one individualized caregiver goal
  • A plan for caregiver participation
  • Training connected to the child’s treatment goals
  • Strategies caregivers can use outside therapy sessions
  • A schedule for caregiver-training sessions

The policy generally requires a minimum of six caregiver-training sessions during each 180-day authorization period. If caregiver training cannot be completed, the ABA provider must document the reason and explain how the treatment team will address the barrier.

Caregiver training is not intended to judge a parent’s skills. Its purpose is to help families understand treatment strategies, support communication, respond consistently to behavior, and help children use newly learned skills at home and in the community.

Direct-Care Staff Must Obtain an Approved Certification

Paraprofessionals delivering direct Research-Based Behavioral Health Treatment must obtain an approved certification for their services to remain reimbursable by NC Medicaid.

The qualifying certifications currently identified by NC Medicaid are:

●​ Registered Behavior Technician, or RBT, through the Behavior Analyst Certification Board
●​ Applied Behavior Analysis Technician, or ABAT, through the Qualified Applied Behavior Analysis Credentialing Board

Existing paraprofessionals who did not hold one of these certifications on August 1, 2026, received a 120-day grace period to obtain certification. Newly hired paraprofessionals must obtain an approved certification within 120 days of their hire date.

Until an uncertified paraprofessional obtains the required certification, a qualified licensed provider must provide direct oversight whenever that employee delivers covered services.

For families, these requirements are intended to ensure that direct-care staff meet appropriate training and competency standards.

Increased BCBA and Licensed-Provider Oversight

The updated policy requires at least 10% of services delivered by a paraprofessional to involve observation and clinical direction by a Licensed Qualified Autism Service Provider.

Depending on the provider’s professional role and qualifications, this may include a licensed BCBA or another eligible licensed professional.

During these observations, the supervising provider may:

●​ Observe the child and therapist
●​ Evaluate the effectiveness of teaching procedures
●​ Review treatment data
●​ Model treatment strategies
●​ Provide clinical direction to staff
●​ Modify treatment protocols
●​ Assess progress toward treatment goals
●​ Determine whether prompting or reinforcement procedures should change

Families may therefore notice the BCBA or another licensed provider participating in or observing treatment more consistently.

Changes to Telehealth Services

NC Medicaid removed telehealth as an option for paraprofessional services billed under CPT codes 97152, 97153, and 97154. Direct treatment delivered by an RBT or other paraprofessional must therefore be provided in person.

Certain BCBA-led services may continue through telehealth when the service is clinically appropriate and all NC Medicaid requirements are met. Telehealth cannot be selected solely for convenience.

When telehealth is used, the provider must consider whether:

  • The service can be delivered safely and effectively
  • The child and caregiver can participate meaningfully
  • Privacy and confidentiality can be protected
  • Telehealth is appropriate for the treatment goal
  • In-person treatment would better meet the family’s needs

Families retain the right to request access to in-person services when those services are available and clinically appropriate.

ABA May Be Provided in Different Settings

The updated policy recognizes that ABA treatment may occur in several settings, including:

●​ An ABA clinic
●​ The family’s home
●​ A school or preschool
●​ A community setting
●​ A combination of appropriate settings

The selected setting must be connected to the child’s individualized treatment goals. Decisions about where treatment occurs should be made collaboratively with the family.

School-based ABA services must address medically necessary treatment goals. Medicaid-funded ABA cannot replace teaching, tutoring, classroom assistance, or services that are the responsibility of the child’s educational program.

Some Activities Are Not Covered as ABA Services

NC Medicaid clarified that ABA coverage does not include:

●​ Childcare or babysitting
●​ Respite or custodial care
●​ Transportation
●​ Nap time or break time
●​ Academic tutoring
●​ Teaching school subjects
●​ Staff-only meetings
●​ Administrative work
●​ Recreational activities that are not connected to an authorized treatment goal
●​ Services that duplicate or replace educational services

Children may still participate in play, movement, community activities, and preferred activities during ABA sessions. However, these activities must be clinically connected to individualized goals such as communication, social interaction, safety, independence, tolerance, or daily living skills.

Autism Diagnosis Requirements

Individuals receiving these services must have an autism spectrum disorder diagnosis completed by a qualified licensed provider using clinically appropriate and scientifically validated diagnostic tools.

A provisional diagnosis may be accepted for a child younger than three years old. A final, non-provisional diagnosis must be obtained within six months for the child to maintain eligibility for covered services.

Families should keep copies of diagnostic evaluations and provide updated records when requested during the intake or reauthorization process.

What Should Families Do Now?

Most families do not need to take immediate action. However, families can help prevent treatment interruptions by:

●​ Participating in scheduled caregiver-training sessions
●​ Attending treatment-plan reviews
●​ Informing the ABA provider about changes in school or other therapy schedules
●​ Providing updated diagnostic and medical records when requested
●​ Communicating changes in insurance coverage
●​ Discussing concerns about treatment hours or service settings with the BCBA
●​ Keeping scheduled assessment and reauthorization appointments
●​ Asking questions when treatment recommendations are unclear

Families should contact their ABA provider or Medicaid health plan if they receive a notice concerning service authorization, denial, reduction, or termination.

Lifespan ABA’s Commitment to Fayetteville Families

Lifespan ABA Inc. is committed to providing compassionate, ethical, individualized, and family-centered ABA services. We are updating our clinical, supervision, caregiver-training, documentation, and authorization procedures to remain aligned with North Carolina Medicaid requirements.

Our team works collaboratively with families to develop meaningful goals that support communication, social development, emotional regulation, safety, daily living skills, and greater independence.

Lifespan ABA serves families in Fayetteville and throughout Cumberland County, including Hope Mills, Spring Lake, Stedman, Eastover, and the Fort Liberty community.

To learn more about beginning ABA therapy or transferring services to Lifespan ABA Inc., contact our office or complete our online referral form.

Lifespan ABA Inc.​
6985 Nexus Court, Suite 107​
Fayetteville, NC 28304​
Telephone: 910-493-3999​
Website: www.lifespanabanc.org

This article is provided for general educational purposes and is not legal advice or a guarantee of Medicaid eligibility, authorization, or payment. Coverage decisions depend on the individual’s eligibility, medical necessity, authorized treatment plan, Medicaid program, and health-plan requirements. Families should contact their Medicaid health plan or NC Medicaid for information about their individual coverage.

Official Sources

  • NC Medicaid: Updated Requirements for Research-Based Behavioral Health Treatment Service Delivery
  • NC Medicaid Clinical Coverage Policy 8F