Kansas Law Lets Some Master’s-Level Clinicians Diagnose Autism. Kansas Medicaid Says Not for ABA.

Kansas Law Lets Some Master’s-Level Clinicians Diagnose Autism. Kansas Medicaid Says Not for ABA.

The Nov. 1 policy limits whose diagnoses qualify for treatment coverage, including ABA, with a two-year transition for certain members already receiving care.

TOPEKA, KANSAS – A Kansas Medicaid policy scheduled to take effect Nov. 1 will require members 20 and younger to have an autism spectrum disorder (ASD) diagnosis from a qualifying psychologist or physician to receive treatment coverage, including applied behavior analysis (ABA). The state’s original August bulletin set a Sept. 1 start date; an updated policy posted Aug. 31 by Sunflower Health Plan moved it to Nov. 1.

The approved-provider list excludes licensed clinical psychotherapists and licensed specialist clinical social workers, two professions that include master’s-level clinicians. Kansas law authorizes both to diagnose mental disorders listed in the Diagnostic and Statistical Manual of Mental Disorders (DSM), including autism. Nurse practitioners and physician assistants are also absent from the list.

Qualifying physicians include developmental-behavioral pediatricians, psychiatrists, neurologists, and primary care physicians with documented additional training in diagnosing autism. The bulletin also lists an Indian Health Services provider category. Psychologists must be licensed by the Kansas Behavioral Sciences Regulatory Board (BSRB), have a doctorate in psychology or equivalent training, and have two years of supervised experience delivering board-approved psychological services. Evaluations must document current DSM criteria and symptom severity and use a validated tool, such as the Autism Diagnostic Observation Schedule (ADOS) or the Childhood Autism Rating Scale (CARS).

The June 2026 version of the state’s fee-for-service mental health manual required a recommendation from “a physician or other licensed practitioner,” and prior authorization for behavioral intervention services, but that section did not specify autism diagnostician qualifications. Sunflower Health Plan’s ABA policy document, marked as last reviewed in June 2019, calls for an evaluation by an “MD or licensed psychologist.”

Members already approved for and receiving autism treatment whose diagnostician or evaluation does not meet the new requirements have two years to obtain confirmation from a qualifying clinician. A complete new evaluation is not required if the policy’s criteria are met; a validated diagnostic tool must have been used in the original evaluation or the reassessment. The bulletin does not specify what happens when the two years expire. Once the diagnosis meets the policy, no repeat autism diagnosis is required before treatment, and there is no deadline to begin care. KanCare managed care organizations may implement the policy on different dates, the bulletin notes.

What the CMS Toolkit Says About Diagnosis

The Kansas bulletin does not explain the restriction or cite the CMS toolkit released Aug. 4. The Centers for Medicare & Medicaid Services presented that guidance as a way to improve ABA oversight and combat fraud, citing its analysis showing a 421% increase in Medicaid and Children’s Health Insurance Program payments for ABA from 2021 to 2025. The toolkit creates no new federal requirements and does not direct states to limit medically necessary care.

The toolkit recommends beginning comprehensive ABA “only after a qualified, independent clinician has confirmed an ASD diagnosis.” It lists developmental pediatricians, pediatricians comfortable using the DSM-5-TR, pediatric neurologists, child psychologists, and psychiatrists, along with other clinical providers specified by a state. It also recognizes that states may authorize limited, time-bound ABA while a full evaluation is pending when clinical suspicion is strong, and impairment is significant.

CMS acknowledges the access problem. It also relays stakeholder reports that evaluator shortages leave some families waiting two years between screening and diagnosis, and recommends addressing the causes of those delays.

Provider Warns of Longer Waits

Ali Wilbert, co-founder of Born to Blossom Behavioral Therapy in Baxter Springs, told KOAM News Now that she had heard of providers referring people on their waitlists elsewhere after the bulletin appeared. Families were struggling to find doctoral-level evaluators who accepted Medicaid, and some encountered waits of years, she said.

The Kansas Association for Behavior Analysis posted about the bulletin on its Facebook page on Aug. 25, while the Sept. 1 start date still stood, and pointed readers to a Facebook group called Kansas Grassroots ABA for advocacy.

KanCare Hearing Scheduled Before Nov. 1 Start

The Legislature’s KanCare oversight committee, known as the Bethell Committee, is scheduled to take public testimony on the program at 9 a.m. Oct. 6 in Room 548-S at the Statehouse in Topeka. Its tentative agenda also calls for the Kansas Department of Health and Environment to discuss prior authorization, provider credentialing and limitations that afternoon. The agenda’s Sept. 17 deadline for written testimony has passed. It does not specifically list the autism diagnosis policy. The bulletin’s effective date is Nov. 1, 2026.

AT A GLANCE

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