Michigan Tells Medicaid Plans: ABA Discharge Can’t Run on a Clock

LANSING, MICHIGAN – Michigan’s Medicaid program has told the regional plans that manage autism care that they cannot end a child’s ABA because a set amount of time has passed. Under a bulletin the Michigan Department of Health and Human Services issued October 1, discharge “cannot be based on a set timeline (e.g., one year, three years, etc.)” and should generally be a gradual step-down in services.

The bulletin, MMP 26-18, rewrites the rules for the Medicaid benefit that pays for ABA for beneficiaries under 21 with an autism diagnosis. It goes to the regional plans and community mental health programs that authorize and pay for that care. Alongside the timeline ban, it ends routine re-diagnosis, drops the physical exam once required before treatment, and leaves documented progress as the clinical test of whether treatment continues.

What Changed, and What Did Not

Michigan already reviewed progress twice a year. The October 2025 version of its Medicaid Provider Manual required providers to re-determine the level of service “minimally every six months” based on measurable improvement. The bulletin keeps that rhythm: providers submit an interim progress assessment “at least every six months based on clinical progress toward treatment plan goals,” and the regional plan may require one more often when a child’s circumstances warrant it.

The bigger change is in the reasons to consider ending treatment. The 2025 manual listed seven. One was a lack of measurable progress, tied to gains that did not hold “through the successive authorization periods.” Others covered symptoms that grew persistently worse over time and a finding, through valid evaluation tools, that services were no longer medically necessary.

The bulletin lists five. A child’s case comes up for discharge review when the child loses Medicaid eligibility or Michigan residency; the family wants to stop; the family and provider cannot settle a disagreement over treatment; goals are met, and less intensive care fits; or the child “has not demonstrated measurable improvement and progress toward goals as documented by the LBA,” the licensed behavior analyst running the case. The progress test survives. The language tying it to successive authorization periods, the worsening-symptoms ground, and the evaluation-tools ground do not.

Discharge criteria are to be set when services begin, monitored throughout, and refined as needed. The bulletin adds a separate rule: treatment “should not be denied or withheld based on caregiver availability.”

Treatment plans submitted for prior authorization must measure each goal with a standardized system, such as the VB-MAPP or ABLLS-R skills assessments, and estimate the timeline and hours each goal will take. Read with the discharge rule, those estimates are planning figures, not exit dates. A draft the department circulated for comment in April said comprehensive programs “often involve 30-40 hours of treatment per week.” The final bulletin dropped that figure and says only that programs vary in intensity and duration.

Re-Diagnosis Only When Needed

Families no longer have to return for a new autism diagnosis to keep services. Re-evaluations are “not required unless determined medically necessary” by a physician or other qualified licensed practitioner, or requested by the family or guardian.

That has been state law for years. Public Act 111, signed in November 2021 and in effect since March 2022, provides that a child with a confirmed diagnosis does not need a re-evaluation to stay eligible unless one is medically necessary. Michigan’s provider manual still called for periodic comprehensive re-evaluations, set at “no more than once every three years” in a 2021 bulletin, and carried that language as of October 2025. The new bulletin cites the 2021 law.

The department’s April draft said the changes were meant in part to remove barriers that cause waitlists. A change to Michigan’s Medicaid state plan, approved by CMS in February and effective June 1, had already written the no-routine-re-evaluation rule into the plan.

Guidelines, Research, and Federal Policy

“Decisions should not be based on the length of time receiving treatment and/or the age of the individual receiving care.” – Council of Autism Service Providers, ABA Practice Guidelines, 3rd ed. (2024)

The field’s own guidance makes the same call. The Council of Autism Service Providers’ 2024 practice guidelines say “there is no specific limit on the duration of a course of treatment,” which depends on each patient’s needs and response.

Outcome research suggests treatment duration matters. A 2017 study of 1,468 children in Translational Psychiatry found that both intensity (hours per week) and duration (months in treatment) predicted how many learning objectives children mastered, in all eight skill areas measured; academic and language skills responded most strongly. A 2022 study of children referred for ABA in a commercially insured Southern California health system found that 46% stayed in services for 24 months and only 28% received a full dose.

In a May 2026 guide to Medicaid’s benefit for children under 21, known as EPSDT, CMS said flat, fixed, hard, or arbitrary limits “are not consistent with the EPSDT requirements.” The same guide says services that maintain a child’s condition rather than improve it can qualify, a standard Michigan’s improvement-based discharge ground does not mirror.

Indiana went the other way. On April 1, 2026, it imposed a 4,000-hour lifetime cap on ABA for everyone in treatment, regardless of hours already received, with up to 15 additional hours a week afterward if medically necessary.

What Plans and Providers Must Do

Michigan’s plans still authorize services for no more than 365 days at a time, renewable each year on a licensed professional’s finding of medical necessity. Under the bulletin, time in treatment cannot be the reason to stop. Behavior analysts must report progress to parents at least every three to six months. The Michigan Health & Hospital Association has encouraged providers involved in autism screening, diagnosis, or referral to review the bulletin and coordinate with their regional plan.

Each authorization still has an end date. Under MMP 26-18, the calendar alone cannot end a child’s treatment.

AT A GLANCE

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