Illinois Medicaid has covered applied behavior analysis since November 1, 2020, for “children age 0 through 20 years diagnosed with an autism spectrum disorder under both Medicaid fee-for-service and Medicaid managed care plans.” Since October 1, 2021 HFS calls the benefit Adaptive Behavior Support (ABS): ABA is the core of it, alongside developmental models delivered by certified clinicians. The benefit has two halves, Behavioral Assessment and Treatment Planning (BATP) and Behavior Analytic Intervention (BAI), billed with the standard 97151–97158, 0362T and 0373T codes.
Most children are in one of the HealthChoice Illinois health plans, and each plan runs its own authorization; HFS’s own prior authorization only governs fee-for-service members. The first intake question is therefore which plan is on the card. The second is staffing: every person who renders ABS, including RBTs, must be enrolled in IMPACT, and since 2025 Illinois also licenses behavior analysts through IDFPR.
HFS announced ABA coverage “for dates of service on or after November 1, 2020” for children 0 through 20 with ASD “subject to prior authorization,” citing Public Act 101-10, under which ABA is covered “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.” On October 1, 2021 HFS broadened this into Adaptive Behavior Support, “inclusive of but not limited to the clinical treatment modality of ABA,” and that notice superseded the earlier ones.[2][4]
ABS has two services. The Behavioral Assessment and Treatment Plan (BATP) must be “Completed, reviewed, and updated as needed, minimally once every 180 days,” signed by the BCBA who developed it, and signed by and given to the family. Behavior Analytic Intervention (BAI) is the treatment, individual or group, in two modes: Comprehensive BAI “intended for individuals under the age of seven” with ASD and adaptive skill deficits, and Focused BAI “intended for individuals age seven through 20” whose behavior “significantly interferes with home or community activities” and which works “in tandem with other behavioral health … and therapeutic” services.[2][4]
HFS’s August 24, 2023 notice, issued under Public Act 103-0102, rewrote the provider rules. It “Removes the requirement for unlicensed ABS Clinicians and ABS Technicians to receive clinical supervision from a licensed practitioner of the healing arts,” “Eliminates all requirements for written collaborative agreements,” and makes ABS reimbursable “to enrolled Behavioral Health Clinics (BHCs) and independently enrolled ABS Clinicians.” An independently enrolled ABS Clinician “may bill only for services the ABS Clinician personally provides or that are provided, under the ABS Clinician’s supervision, by an ABS Technician with whom the ABS Clinician has an established employment, contractual, or similar relationship.” And: “All individuals rendering covered ABS services to Illinois Medical Assistance Program customers must be enrolled in the IMPACT system,” including BHC employees.[5][25]
ABS Clinicians are BCBAs “certified and in good standing” with the BACB (a BCBA who also holds a state practice license enrolls under that license with a BCBA subspecialty), or an ABS Developmental Clinician: a licensed clinical psychologist, LCSW, LCPC, LMFT, occupational therapist or speech-language pathologist with an approved certification (DIRFloortime Advanced or Expert, ESDM Certified Therapist or Parent Coach, Profectum Level 2, PLAY Project dual certification, or RDI Certified Consultant). ABS Technicians are RBTs, who “must receive supervision from a BCBA,” or ABS Developmental Technicians (18 or older, high school diploma or GED, Profectum Registered Developmental Technician), supervised by a Developmental Clinician. The written collaborative agreement template HFS published in 2022 is history: the 2023 notice eliminated the requirement.[5][25]
For fee-for-service members, “BATP services exceeding six hours (24 units) per a 180-day period and all BAI services require prior authorization,” on the HFS Prior Authorization for ABS Services form, emailed to HFS.ABS@illinois.gov. The packet: a physician order “required with the first submission … and is valid for one year,” showing the physician’s NPI, the child’s name and date of birth, primary diagnosis, treatment recommendation, and signature and date; the Comprehensive Diagnostic Evaluation by “a physician or a clinical psychologist,” with direct assessment resulting in an ADOS, GARS, ADI or CARS, developmental history, current verbal and nonverbal functioning, and a caregiver interview; current documentation of functional impairment if the CDE is more than 24 months old; a clinical narrative if BATP will exceed six hours; and, for BAI, the BATP “completed within 30 days prior to the request date.” The form itself asks for the BCBA-to-RBT ratio and the percentage of BCBA and RBT time requested.[4][9][21]
HFS cites 89 Ill. Adm. Code 140 Table E, Item 26: “prior authorization determinations shall be made within 30 days of submission,” and “If the notice of disposition is not sent within the applicable time limit, prior approval will be granted automatically.” Missing information stops the clock and must be remedied “within 2 business days,” after which a new 30-day window starts. Approvals are “not transferable, as they are specific to an individual, provider, and service allotment.” Federal rules have since tightened the state-agency standard: from January 1, 2026, a standard decision is due “in no case later than 7 calendar days” (72 hours expedited), so expect HFS to move faster than its notice says.[4][9][21]
Re-authorization. HFS sets no separate reauthorization form or graph requirement. Every BAI request, including a renewal, must be “accompanied by the individual BATP, completed within 30 days prior to the request date,” and the BATP itself must be “Completed, reviewed, and updated as needed, minimally once every 180 days.” The CDE goes in with the first submission and “upon request for all subsequent submissions,” and a CDE more than 24 months old needs current documentation of functional impairment. Neither the notice nor the PA form asks for graphed data specifically; the BATP is the progress document, and the form asks for the BCBA-to-RBT ratio and hours requested.[4][9][21]
HFS publishes one statewide ABS fee schedule (effective 01/15/2022, updated 05/14/2026) whose rates “do not vary by population group or geographical region,” and the same notice that raised the RBT base rate to $13.00 per quarter hour applied it “under both Medicaid fee-for-service (FFS) and the HealthChoice Illinois managed care plans.” Per 15-minute unit, with the daily maximum: 97151 $20.39 (Level 1, 8 units); 97152 $13.00 (Level 2, 8); 0362T $46.39 (team, 8); 97153 $13.00 (Level 2, 32); 97154 $5.72 (Level 2, 12); 97155 $20.39 (Level 1, 24); 97156 $20.39 (Level 1, 16); 97157 $9.00 (Level 1, 16); 97158 $9.00 (Level 1, 16); 0373T $46.39 (team, 24). Level 1 is an enrolled BCBA or ABS Developmental Clinician; Level 2 an enrolled RBT or Developmental Technician; team services need at least “1 BCBA + 2 RBTs” (or a Developmental Clinician and two DTs) and the HT modifier.[7][8][6][4]
“National Correct Coding Institute (NCCI) procedure-to-procedure and medically unlikely edits apply.” HFS also tells providers to roll multiple units of the same code on the same date into one claim line to avoid the duplicate edit, and that the daily maximum “is the maximum number of units reimbursable for an individual on a single date of service.”[7][8][6][4]
HFS’s 2021 ABS notice requires the billing provider to report the BCBA’s or RBT’s “name and NPI … in the Rendering/Servicing segment of the claim,” and “Claims that identify an RBT as the Rendering/Servicing Provider must also include the Supervising BCBA’s name and NPI in the Loop 2310D, segment NM1, Supervising Provider field.” Fee-for-service claims must be received “no later than 180 days from the date on which the services or items were provided”; when another payer is primary, the claim is due within 180 days after the primary payer’s final adjudication. Electronic Visit Verification does not reach ABS: HFS’s EVV page lists personal care services under the HCBS waivers and home health care services as the services in scope.[4][10][13][1]
Payment and payment timing. HFS’s general handbook says fee-for-service payment “will be made by a State warrant (check) issued through, and mailed by, the Illinois Office of the Comptroller, or via direct deposit/EFT,” with remittance advices mailed separately and the 835 available through MEDI; it publishes no clean-claim payment deadline and no weekly submission cutoff for fee-for-service claims, so the Comptroller’s warrant schedule is the only clock (ask the HFS billing consultants, 877-782-5565). Managed care is different: 305 ILCS 5/5-30.1(g) requires each MCO to “pay a claim within 30 days of receiving a claim that contains all the essential information needed to adjudicate the claim,” with an interest penalty for late payment.[4][10][13][1]
HFS’s January 1, 2026 managed care map lists five statewide HealthChoice Illinois plans (Aetna Better Health, Blue Cross Community Health Plans, Meridian, Molina HealthCare and YouthCare) and one Cook County plan, CountyCare. YouthCare, run by Meridian, serves “Illinois Department of Children & Family Services (DCFS) Youth In Care (YIC) and Former Youth In Care (FYIC) Enrollees only.” HFS’s ABS notices send every managed care question to the plan: “Questions regarding ABS service coverage, prior authorization, and billing requirements for managed care enrolled customers should be directed to the appropriate HealthChoice Illinois MCO.”[19][20][11][12][4][26][27][28][29][30][31]
Illinois Public Act 104-0028 (HB 3019) changed behavioral health utilization management from January 1, 2026, and each HealthChoice Illinois plan has read it differently for ABA. Molina says ABA “services are no longer eligible for prior authorization and require concurrent review only” (no authorization for the initial assessment or the first 48 units of therapy a calendar year). Aetna Better Health approves 97151/97152 without medical-necessity review if notified within one business day, then runs concurrent review. Blue Cross Community Health Plans and YouthCare ask for notification within 24 hours of starting ABA services or the initial assessment. Meridian requires notice within 24 hours of 97151/97152 from May 1, 2026 and keeps prior authorization on treatment. CountyCare removed PA from 97151/97152 only. The Act itself added subsection (w) to 215 ILCS 5/370c: from January 1, 2026 “No policy shall require prior authorization for outpatient or partial hospitalization services for treatment of mental, emotional, or nervous disorders or conditions,” such coverage “may be subject to concurrent and retrospective review,” and “A Medicaid managed care organization may set a deadline of 24 hours after the initiation of treatment” for notification (one more business day if it cannot accept the notice). It also lets HFS “adopt rules to implement the applicable provisions” for managed care organizations “and the medical assistance fee-for-service program” (new 305 ILCS 5/5-5.28). The statute does not name ABA, which is why the plans differ; this guide reports each plan’s own written rule.[19][20][11][12][4][26][27][28][29][30][31]
Illinois licenses behavior analysts. IDFPR lists two professions under the Behavior Analyst Licensing Act (225 ILCS 6), the Licensed Behavior Analyst and the Licensed Assistant Behavior Analyst, and says the Department “commenced licensing behavior analysts and assistant behavior analysts on January 15, 2025.” It gave applicants a grace period: IDFPR “will not begin enforcement actions for unlicensed practices provided by Behavior Analysts and Assistant Behavior Analysts until Monday, April 21, 2025,” so that date has passed and a BCBA practicing in Illinois now needs the Illinois license. A second deadline is still ahead. IDFPR quotes Section 150 of the Act: beginning 24 months after licensing began, no business may offer behavior analysis services “unless every member, partner, shareholder, director, officer, holder of any other ownership interest, agent, and employee who renders applied behavior analysis services holds a currently valid license,” and it reads that as: “By or before January 15, 2027 anyone who is not licensed as a behavior analyst or assistant behavior analyst … and who currently owns a business providing applied behavior analysis services must divest from the business.” The statute is blunter than IDFPR’s notice: Section 150 covers “every member, partner, shareholder, director, officer, holder of any other ownership interest, agent, and employee who renders applied behavior analysis services,” “Notwithstanding” the Section 20 exclusion for people implementing a plan under a licensed behavior analyst’s supervision, so ask IDFPR how it applies to RBT employees after January 15, 2027. The BACB’s licensure table lists Illinois (law enacted 2022) with IDFPR as the board. Out-of-state BCBAs and telehealth: no. Section 20 of the Act says an individual “shall not engage in the practice of applied behavior analysis unless licensed under this Act or covered by an exemption,” and its exemption list (family caregivers, staff implementing a plan under a licensed behavior analyst, listed licensed professions such as clinical psychologists, LCSWs, LCPCs, SLPs and OTs acting within their training, students and fellows, school-endorsed staff, QIDPs, DHS-designated providers, and people practicing on Medicaid when the Act took effect while working toward licensure) contains nothing for a behavior analyst licensed in another state. The Telehealth Act closes the remote route: “A health care professional treating a patient located in this State through telehealth services must be licensed or authorized to practice in Illinois” (225 ILCS 150/10). So a BCBA licensed elsewhere needs the Illinois license to treat or supervise a client located in Illinois, in person or by telehealth. HFS’s enrollment notices still key ABS Clinicians to BACB certification, so plan on both: the IDFPR license for the right to practice, and BCBA status plus IMPACT enrollment for Medicaid billing.[14][15][16][17][18][5]
The questions that decide whether a family can start with Illinois Medicaid (HFS), and what they have to bring. Each maps onto something intake should ask on the first call.
Ages 0 through 20. Comprehensive BAI is “intended for individuals under the age of seven,” Focused BAI for “individuals age seven through 20.”[2][4]
No expiry on the CDE itself, but “If the individual’s CDE was completed more than 24 months prior to the date of request for prior authorization, current individualized documentation of functional impairment by a physician or a clinical psychologist is required.” The BATP must be completed within 30 days before a BAI request.[4]
The Comprehensive Diagnostic Evaluation is “performed by a physician or a clinical psychologist.”[4]
The CDE must result in one of: Autism Diagnostic Observation Schedule (ADOS), Gilliam Autism Rating Scale (GARS), Autism Diagnostic Interview (ADI) or Childhood Autism Rating Scale (CARS). The HFS PA form has checkboxes for exactly those four.[4][9]
Yes. A physician order and referral is required with the first PA submission and “is valid for one year” (physician NPI, child’s name and DOB, primary diagnosis, recommendation, signature and date). Public Act 101-10, as HFS quotes it, covers ABA “when ordered by a physician licensed to practice medicine in all its branches.”[4][2]
HFS’s ABS fee schedule (updated 05/14/2026) marks four codes for remote delivery: 97151 (assessment), 97155 (protocol modification), 97156 (family guidance) and 97157 (multiple-family group). The footnote reads: “Only use the GT or 93 modifier when providing allowable service remotely as a distant site telehealth service along with Place of Service (POS) 02 or 10, as applicable, on the specific service line of the claim.” 97152, 97153, 97154, 97158, 0362T and 0373T carry no telehealth modifier, so technician-delivered treatment is billed as in-person.[7]
HFS’s ABS notice: determinations “within 30 days of submission” (89 Ill. Adm. Code 140 Table E, Item 26), automatically granted if no notice is sent in time; missing information must be supplied within 2 business days and restarts the 30 days. The federal floor is now faster: since January 1, 2026 a state agency must decide a standard request “in no case later than 7 calendar days” and an expedited one within 72 hours. Managed care members follow their plan’s clock (42 CFR 438.210(d): 7 calendar days for rating periods from January 1, 2026).[4][21][22]
HFS is “by federal and State Law, the payer of last resort,” and “where identifiable third party resources exist, claims must be submitted to and adjudicated by all liable third party payers before the Department will consider a claim.” HFS pays nothing when the third-party payment exceeds its rate. The TPL claim is due within 180 days after the primary payer’s final adjudication.[10][23]
Coverage decides whether Illinois Medicaid (HFS) pays. These decide whether the claim survives: how sessions must be staffed and supervised, what may be billed concurrently, the per-day ceilings, who signs the note, where the service is payable, and whose NPI the claim goes out under.
RBTs “must receive supervision from a BCBA” (2023). The 2021 notice set the floor still in HFS’s ABS guidance: RBTs “are expected to receive Case Leadership for 5%, or more, of all direct services,” with “at a minimum, two face-to-face, real-time contacts per month” of observation, modeling, problem-solving guidance and documentation review, the BCBA “present with the RBT.” The 2023 notice removed LPHA clinical supervision and written collaborative agreements but did not restate the 5% figure, so confirm it with HFS if your program relies on a lower rate.[5][4]
The fee schedule’s Daily Max Quantity per date of service: 97151, 97152, 0362T 8 units each; 97153 32; 97154 12; 97155 24; 97156, 97157, 97158 16 each; 0373T 24. HFS: the daily maximum “is the maximum number of units reimbursable for an individual on a single date of service,” and same-code units must be rolled into one claim line.[7][4]
HFS’s 2021 notice describes BAI by mode (individual or group; comprehensive or focused) and sets no setting restriction; the superseded January 2021 notice had allowed BAI “At all service locations and settings deemed appropriate for reimbursement, consistent with Department policy.” Remote delivery is limited to the four telehealth-eligible codes with POS 02 or 10.[4][3][7]
The billing provider is an enrolled BHC or an independently enrolled ABS Clinician. The rendering BCBA or RBT goes in the Rendering/Servicing segment by name and NPI, and when an RBT renders, “the Supervising BCBA’s name and NPI” goes in Loop 2310D, NM1. Every rendering individual must be enrolled in IMPACT.[4][5]
Not addressed in any HFS ABS notice or the fee schedule, beyond “National Correct Coding Institute (NCCI) procedure-to-procedure and medically unlikely edits apply.”[7][4]
Blocked on: HFS Bureau of Professional and Ancillary Services billing consultants, 877-782-5565, or ABS policy questions to omi.support@uillinois.edu: ask whether 97153 and 97155 may be billed for the same clock time.
The BATP must be “Reviewed, approved, and signed by the developing BCBA” and signed by the individual or parent or guardian, with a copy given to them. No HFS notice read says who signs each session note or by when.[4]
Blocked on: omi.support@uillinois.edu (ABS policy) or HFS Bureau of Professional and Ancillary Services, 877-782-5565.
Yes. Since November 1, 2020 HFS covers ABA, now called Adaptive Behavior Support (ABS), for children 0 through 20 with autism, in fee-for-service and in every HealthChoice Illinois plan.
HFS requires a physician order and referral with the first prior authorization request, and it "is valid for one year." It must contain the physician’s NPI, the child’s name and date of birth, the primary diagnosis, the physician’s treatment recommendation, and a signature and date.
The ABS fee schedule (updated 05/14/2026) pays per 15 minutes: 97153 and 97152 $13.00; 97151, 97155 and 97156 $20.39; 97154 $5.72; 97157 and 97158 $9.00; 0362T and 0373T $46.39. HFS applied the RBT rate to the managed care plans too.
Fee-for-service: only if BATP exceeds six hours (24 units) in 180 days. Each managed care plan has its own rule, and most loosened assessment authorization on January 1, 2026.
Yes for 97151, 97155, 97156 and 97157, billed with modifier GT or 93 and POS 02 (not home) or 10 (home). Technician codes such as 97153 are not marked for telehealth.
Yes. HFS requires every individual rendering ABS, including RBTs employed by a clinic, to be enrolled in IMPACT, and claims for RBT services must name the supervising BCBA in Loop 2310D.
For fee-for-service, a new PA request with the BATP completed within 30 days before the request (the BATP must be updated at least every 180 days), plus the CDE if the reviewer asks for it and a current functional-impairment note if the CDE is over 24 months old. HFS does not specifically require graphs. Managed care plans run their own reviews.
HFS publishes no fee-for-service payment deadline; the Comptroller pays by warrant or EFT. HealthChoice Illinois plans must pay a clean claim within 30 days under 305 ILCS 5/5-30.1(g), with interest if late.
No. HFS’s EVV page limits EVV to personal care services under the HCBS waivers and home health care services; ABS is not listed.
No, not without an Illinois license. The Behavior Analyst Licensing Act bars practicing ABA in Illinois unless licensed or exempt, and its exemptions include nothing for out-of-state licensees (225 ILCS 6/20); the Telehealth Act requires a professional treating a patient located in Illinois by telehealth to be “licensed or authorized to practice in Illinois” (225 ILCS 150/10). For Medicaid the clinician also needs IMPACT enrollment.
Payer policies change frequently and vary by plan, state, and funding type. This guide was compiled from the sources above and last reviewed October 2026; it is general information, not billing, legal, or clinical advice. Always verify current requirements against the payer's live policy and a benefits check for the specific member.
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