MiBAP Position Statement on
Medicaid-Covered ABA Services During Traditional School Hours

Long before COVID-19, there has been ongoing confusion regarding the delivery of ABA services to students during traditional school hours. Although Section 18.10 of the Medicaid Manual discourages ABA services when the child would typically be in school, MDHHS has made it clear that ABA services can be scheduled during typical school hours, when medically necessary and when in support of and not overlapping with educational services. With the advent of COVID-19, this exception has become the rule, as thousands of autism-diagnosed and/or special education students are forced (or choose) to attend school from home – very often without the necessary technology or other supports available to them in a school setting. During these unprecedented times, it is crucial that families, schools, and medical professionals be empowered and given the flexibility to develop an Individual Plan of Service (IPOS) that best meets the combined educational and medical needs of the child. Failure or even delays in authorization of complementary and coordinated ABA services to this extremely vulnerable population will exacerbate the looming, COVID-induced mental health crisis, and likely be in violation of the Mental Health Parity & Addition Equity Act (MHPAEA). MiBAP strongly supports a parent’s right to request and receive non-overlapping ABA services for their child during times that have traditionally been considered “school hours,” as deemed medically necessary by the supervising medical professional, and in collaboration with caregiver(s), educators and the treatment team.