Compliance Overview
Improper
$120.1M
$80.4M Federal
Potential
$193.0M
Under review
Findings
22
3 audits
Recs
2/15
Implemented
OIG Work Plan Series
Autism can cause significant social, communication, and behavioral challenges for children. According to the CDC, research has shown that early intervention and therapy can improve social and behavioral development in children diagnosed with autism. A common therapy for autism is Applied Behavior Analysis (ABA). We will audit Medicaid claims for ABA services provided to children diagnosed with autism to determine whether State Medicaid agencies' ABA payments complied with Federal and State requirements.
Completed Audit Reports
Data current as of February 4, 2026
Key Documentation Issues Across Audits
Found in 100% of audits. Session notes lacking required elements, signatures, detailed descriptions, or proper formatting.
Found in 100% of audits. Services provided by staff without appropriate credentials or credentials not on file.
Found in 100% of audits. Billing for time that may not constitute direct therapeutic intervention.
Found in 100% of audits. Session notes indicating potentially unallowable recreational or academic activities billed as therapy.
Missing parent/guardian signatures, incomplete plans, or outdated treatment referrals affecting compliance.
Documentation not supporting billed CPT codes, incorrect rendering providers, or units not matching service time.