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Provider Notice Issued 10/30/2020

Date:    October 30, 2020
To:       All Medical Assistance Program Providers
Re:      Coverage for Applied Behavioral Analysis (ABA) Services for Children 0 through 20 Years – Provider Enrollment
This notice announces coverage for applied behavioral analysis (ABA) services for dates of service on or after November 1, 2020. These services will be covered for children age 0 through 20 years diagnosed with an autism spectrum disorder under both Medicaid fee-for-service and Medicaid managed care plans, subject to prior authorization. 
Per Public Act 101-10, treatment of autism spectrum disorder through applied behavior analysis shall be covered under the medical assistance program for children with a diagnosis of autism spectrum disorder when ordered by a physician licensed to practice medicine in all its branches and rendered by a licensed or certified health care professional with expertise in applied behavior analysis.
Applied behavior analysis (ABA) is the design, implementation, and evaluation of environmental modifications, using behavioral stimuli and consequences, to produce socially significant improvement in human behavior, including the use of direct observation, measurement, and functional analysis of the relationships between environment and behavior.
The following details provide the necessary information for individuals interested in becoming a provider of ABA services to understand the provider qualifications and enrollment process. Additional policy and information regarding ABA services prior approval process, covered services, and claim submittal, is forthcoming.
Provider Qualifications
For the purpose of ABA services, the Department shall recognize Board Certified Behavior Analysts (BCBA) and Registered Behavior Technicians (RBT) as detailed below. Qualified individuals may only provide services within their scope of practice, as defined by federal or state law, regulation, policy, or national practice standards.
Board Certified Behavior Analyst (BCBA). A BCBA has been credentialed by the Behavior Analyst Certification Board (BACB) and is either:
1.    A clinical psychologist who holds a valid license in the state of practice and is legally authorized under state law or rule to practice as a clinical psychologist, so long as that practice is not in conflict with the Clinical Psychologist Licensing Act [225 ILCS 15] and implementing rules (68 Ill. Adm. Code 1400); or
2.    A clinical social worker possessing a master's or doctoral degree who holds a valid license in the state of practice and is legally authorized under state law or rule to practice as a

social worker, so long as that practice is not in conflict with the Clinical Social Work and Social Work Practice Act [225 ILCS 20] and implementing rules (68 Ill. Adm. Code 1470).
Registered Behavior Technician (RBT). An RBT has been credentialed by the Behavior Analyst Certification Board (BACB), has a high school diploma or GED, and a written collaborative agreement with a clinical supervising BCBA
Written Collaborative Agreement.  The written collaborative agreement between the clinically supervising BCBA and the RBT shall describe
·         The professional relationship between the professionals (e.g. employee, contracted employee, etc.);
·         The services and treatment that the RBT may provide; and
·         The arrangement for direct supervision between the BCBA and the RBT.
BCBAs shall not maintain a written collaborative agreement with more than eight (8) RBTs at any given time.
Direct Supervision. BCBAs are required to provide, as a minimum, five percent (5%) direct supervision per month to each RBT that holds a written collaborative agreement with the BCBA.  Direct supervision activities shall include, at a minimum, two face-to-face, real-time contacts per month in the form of the following activities:
1.    Observing, providing behavioral skills training, and delivering performance feedback to the RBT;
2.    Modeling clinical, technical, and professional skills and behavior;
3.    Guiding the development of problem-solving and decision-making with the RBT;
4.    Reviewing clinical documentation (e.g., daily progress notes, data sheets) with the RBT; and
5.    Overseeing and evaluating the effects of behavior analytic service delivery.
Enrollment to Provide ABA Services
Any provider seeking reimbursement for ABA services must be enrolled for participation in the Department’s Medical Programs via the web-based system known as Illinois Medicaid Program Advanced Cloud Technology (IMPACT). The IMPACT system uses Specialties and Subspecialties, when enrolling, to allow individuals or entity-based providers to specify the types of services they provide.  Table 1 IMPACT Enrollment Guide – ABA Services Provider Options has been provided below to assist individuals with their enrollment process.
Individuals seeking enrollment as a provider of ABA services may not seek reimbursement until their IMPACT application has been approved. Provisional licensed individuals are not eligible to enroll.
Licensed Clinical Psychologists and Licensed Clinical Social Workers enrolled in IMPACT with no subspecialty or a primary specialty will need to complete a modification of their current IMPACT enrollment to add the Board Certified Behavioral Analysts (BCBA) credential before being eligible to provide ABA services.

Table 1. IMPACT Enrollment Guide – ABA Services Provider Options
Enrollment Type
Applicant Type
Claim Type
Sole Proprietor
Regular Individual/ Sole Proprietor*
Licensed Clinical Psychologist
No Subspecialty
Primary Specialty
Board Certified Behavior Analysts
Behavioral Health Services
Licensed Clinical Social Worker (LCSW)
No Subspecialty
Primary Specialty
Board Certified Behavior Analysts
Rendering/ Servicing Provider
Behavioral Health Services
Registered Behavior Technician
No Subspecialty
*Only those providers who have a certified W-9 may select the Applicant Type of Individual/Sole Proprietor
Individuals seeking additional information regarding provider enrollment can visit the IMPACT website. Questions regarding enrollment may be directed to Provider Enrollment Services in the Bureau of Professional and Ancillary Services at 877-782-5565, option sequence 1, 2, 1. Other questions regarding this notice may be directed to
Kelly Cunningham
Interim Medicaid Administrator


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