Webinars

HHS OIG Audits of the Applied Behavior Analysis Medicaid Benefit: Information to help ABA Organizations prepare for an OIG Audit

Monday, November 17, 2025

2:00 PM - 3:00 PM (EST)

Hosted on Zoom

Event Details

Abstract

This webinar will examine the recent federal oversight of Medicaid-funded applied behavior analysis (ABA) services for children with autism through audits conducted by the U.S. Department of Health & Human Services Office of Inspector General (OIG). We will first review the key findings from the OIG’s audit of Indiana’s fee-for-service Medicaid ABA program, which found at least $56 million in improper payments and identified documentation, credentialing and oversight deficiencies.
We then turn to the state of Wisconsin, whose audit identified at least $18.5 million in improper payments tied to Medicaid ABA claims.

Finally, we discuss the broader implications for states as Medicaid oversight intensifies, the compliance bar rises, and risks for providers and state agencies grow. The enforcement environment signals that states and providers must review their ABA documentation, billing, provider credentialing, and pre and post-claim submission processes.

Participants will learn:
Key trends and common deficiencies identified by the OIG in ABA-related Medicaid claims (e.g., missing or inadequate session notes, unqualified providers, ineligible beneficiaries).
How the audit findings in Indiana and Wisconsin may translate into compliance expectations, provider risk, and state agency responses.
Strategies for providers and state Medicaid program administrators to strengthen internal controls, documentation practices, and oversight to reduce improper payment risk.
Emerging state-level implications and the legislative/regulatory environment that may follow in the wake of such audits.

This session is designed for ABA providers, Medicaid program integrity professionals, state agency staff, compliance officers, and reimbursement specialists seeking to understand the evolving landscape of Medicaid ABA oversight and how to position their programs for greater resilience and compliance.

Learning Objectives

Attendees will explain the importance of reviewing and complying with state Medicaid policy- including ABA-specific program and general billing/operating requirements.
Attendees will identify the three key areas of concern identified through already completed HHS OIG audits.
Attendees will review clinical documentation requirements, in particular requirements for 97153 and 97155
Attendees will explain the importance of internal program integrity processes.

This webinar offers 1.5 BACB Ethics CEU.

Cost

CASP Members - free
non-members - $20

Presenters

Mariel Fernandez, MS, BCBA, LBA

Mariel began working in behavior analysis in 2001 and earned her master’s degree in applied behavior analysis at Auburn University in 2004. She has been board certified since 2004 and is licensed in Texas. Mariel has extensive experience in clinical, operations, compliance, and regulatory/public policy.

Mariel is Vice President of Government Affairs for The Council of Autism Service Providers (CASP). Before joining CASP, Mariel led the Regulatory Affairs department at Blue Sprig Pediatrics, focusing on advocacy, public policy, and legislative initiatives across 19 states. Mariel is the presiding officer of the Texas Department of Licensing and Regulation (TDLR) Behavior Analyst Advisory Board, Chair of the Metro-Care Services Public Advisory Committee, and President of the Texas Association of Behavior Analysis Public Policy Group (TxABA PPG). She also serves as a subject matter expert for the Policy Council on Children and Families, specific to the Autism Services benefit through Texas Medicaid.

Mariel was honored with the Blue Sprig CEO Award, in 2020, for her work preparing the organization to shift to telehealth during the COVID-19 pandemic. She was also the co-recipient of the 2022 Autism Law Summit "Implementation Award" for her work in Texas to pass behavior analyst licensure and secure access to ABA for beneficiaries of Texas Medicaid.

Rebecca Thompson, PhD, BCBA-D

Dr. Becky Thompson is the Senior Director for Advocacy with LEARN Behavioral. She's a licensed psychologist and behavior analyst at the doctoral level who has been in the field for 25 years.

Jenna Minton, CPT, Esq.

Jenna is licensed to practice law in Maryland and is a member of the Maryland State Bar Association. In her early career she spent 5 years in the metro DC area, working for medical non-profits learning the ins and outs of the regulatory process. Following that, she spent 10 years as the Director of Operations and Interim Executive Director for a large non-profit ABA organization in Michigan. In 2013, she founded Minton Healthcare Strategies, now known as Proactive Strategies, LLC (PS) who specializes in guiding clients through the development of Current Procedural Terminology (CPT) Codes which are used to report medical, surgical, diagnostic, and therapeutic procedures. We then support the subsequent valuation of those codes through the American Medical Association's process (the AMA Relative Update Committee). We also have extensive experience navigating the Medicare and Medicaid regulatory processes. Clients we work with include: applied behavior analysis provider organizations and coalitions, medical specialty societies, and virtual technology companies. Team Proactive provides assistance in the following areas: claims processing, audit, accreditation, contracting, and strategic / succession planning. In 2022, we grew our team to five and in 2025 we've added our first clinically trained team member! We look forward to what the future holds.

Julie Kornack

Julie Kornack is the chief government and payor relations officer for the Center for Autism and Related Disorders and the chair of the ABAI ABA Billing Codes Commission. Her day-to-day work focuses on ensuring families can access ABA that reflects the standard of care. She works with federal and state policymakers, regulators, payors, and advocates to improve access to ABA. In 2022, she conceived of and passed a law to speed up credentialing of mental health service providers in California. She has published multiple articles to promote best practices and increase awareness of her favorite law, the federal Mental Health Parity and Addiction Equity Act (MHPAEA), including Science Over Cynicism: The Race to Preserve Best-Practice Applied Behavior Analysis through Expanded Awareness, Advocacy, and Enforcement of the Mental Health Parity and Addiction Equity Act and Preventing Insurance Denials of Applied Behavior Analysis Treatment Based on Misuse of Medically Unlikely Edits (MUEs). She co-founded and serves on the board of directors of the National Coalition for Access to Autism Services and participates in multiple state
and national advisory committees and task forces. She is a co-author of the Democratic National Committee’s Disability Primer for Democratic Candidates, and she is an editor of Evidence-Based Treatment for Children with Autism: The CARD Model.

Chanti Waters, EdD, BCBA-D

Dr. Chanti Fritzsching Waters is a seasoned leader in the field of Applied Behavior Analysis, bringing over 30 years of experience spanning clinical practice, research, teaching, and policy development. She joined ABS Kids in 2020, where she currently serves as Vice President of Clinical and Regulatory Affairs. In this role—and previously as Vice President of Quality Assurance—Dr. Waters partners with executive leadership to implement clinical best practices, evaluate client outcomes, and oversee regulatory compliance to ensure high-quality, evidence-based care across the organization.

Her leadership extends beyond ABS Kids. Dr. Waters has served on the Board of Directors for the Association of Professional Behavior Analysts (APBA) since 2022 and currently holds the role of Secretary on its Executive Committee. She is also a member of the ABA Coding Coalition and actively contributes to several professional committees and special interest groups. Since 2019, she has supported the Behavior Analyst Certification Board (BACB) as a subject matter expert. Most recently, in 2024, she was appointed to the Standards Committee of the Autism Commission on Quality, where she helps shape national benchmarks for autism service providers seeking accreditation.

Dr. Waters has also contributed significantly to academia and research. She has taught graduate-level ABA coursework and presented at numerous professional conferences. Her 2020 publication—a clinical replication study of the Lovaas model—demonstrated the effectiveness of early intensive behavioral intervention (EIBI) in a community setting, following foundational work she supported in another EIBI replication in 2006. Her current research focuses on training new BCBAs in clinical interviewing techniques to strengthen family collaboration and engagement.

She earned her Master of Science in ABA Psychology from California State University, Stanislaus, and holds both an Education Specialist (Ed.S.) degree and a Doctor of Education (Ed.D.) in Curriculum and Instruction from the University of West Florida. Dr. Waters lives on California’s Central Coast with her family.