Minnesota Medical Assistance pays for applied behavior analysis through a benefit with a different name: EIDBI, Early Intensive Developmental and Behavioral Intervention (Minn. Stat. § 256B.0949). ABA is one of the approved EIDBI modalities, alongside DIR/Floortime, the Early Start Denver Model and RDI. The benefit covers people under 21 with autism spectrum disorder or a related condition who are enrolled in Medical Assistance, MinnesotaCare, TEFRA or another qualifying program, once a comprehensive multi-disciplinary evaluation (CMDE) establishes medical need.
For an agency, the program works in a fixed order. A CMDE provider evaluates the child and files the CMDE Medical Necessity Summary (DHS-7108); the agency’s qualified supervising professional (QSP) writes the Individual Treatment Plan (DHS-7109); then the plan is authorized, by Acentra Health for fee-for-service members or by the member’s managed care plan for everyone else. Most members are in one of eight health plans. Minnesota is also in the middle of a program-integrity overhaul: provisional EIDBI agency licensure (applications closed May 31, 2026), a statutory 1:16 supervision ratio, a 72-hour documentation rule enacted in 2026, and billing limits that start July 1, 2027 or on federal approval.
The statute authorizes EIDBI "to provide early intensive intervention to a person with an autism spectrum disorder or a related condition," covering "a comprehensive, multidisciplinary evaluation, ongoing progress monitoring, and medically necessary early intensive treatment." ABA is listed first among the modalities treatment must follow (§ 256B.0949, subd. 13(b)); DHS also requires every agency to employ a QSP or Level I provider with advanced certification in its modality, which for ABA means a BCBA, BCBA-D or BCaBA. Covered services are the CMDE, ITP development and progress monitoring, coordinated care conferences, individual, group and higher-intensity intervention, observation and direction, family/caregiver training and counseling, and travel time.[1][13][7][9][4][6][29]
Medical necessity follows DHS’s criteria page: symptoms present in the early developmental period (or masked until later), behaviors that persist across environments and either pose a health or safety risk or significantly disrupt home or community life, and a CMDE showing the person needs "10 or more hours per week of EIDBI services (unless there is a clinical rationale for an exception)." Recommendations should not exceed 20 hours a week for a person older than seven unless an exception applies (crisis, risk of out-of-home placement, a short intensive boost, late access, or a documented CMDE or QSP rationale). Reauthorization needs documented progress and a parent signature on the ITP; DHS may terminate when there is no measurable progress within 12 months of the initial ITP.[1][13][7][9][4][6][29]
EIDBI is not carved out of managed care. DHS’s MHCP manual sends providers to the plan: "If the person is enrolled in a prepaid health plan (PPHP), contact the appropriate managed care organization for authorization requirements," and Acentra Health "will reject requests submitted for members enrolled in an MCO." DHS’s October 2026 EIDBI MCO contact grid lists eight plans: Blue Cross and Blue Shield of Minnesota (Blue Plus), HealthPartners, Hennepin Health, IMCare, Medica, PrimeWest Health, South Country Health Alliance, and Medica One Health Plan (the former UCare Medical Assistance plans, which moved to Medica on October 1, 2026).[1][13][7][9][4][6][29]
For fee-for-service members, "MHCP’s current medical review agent is Acentra Health." The CMDE provider uploads DHS-7108 with its signature page to the Atrezzo portal; the QSP must have medical-necessity approval before submitting the ITP and must upload DHS-7109 "at least 30 days before the start date requested or the end date of the current service authorization period." Acentra does not take faxes or mail. Each authorization "cannot exceed a 180-day span"; the annual CMDE is due "at least 30 days, but no more than 60 calendar days, before the end date of the current service authorization period"; and Acentra "may retroactively approve up to 180 days," provided the ITP and CMDE were signed before services started.[4][20][21]
Acentra has seven calendar days from receipt of a CMDE, and seven from receipt of an ITP, to check completeness, pend for missing information, and decide. A pended provider has 10 calendar days to upload everything requested in one response, after which Acentra has three business days to decide; if the information does not arrive in time, the request is denied. Since January 1, 2026 the Minnesota Utilization Review Act also applies to Medical Assistance: § 62M.01, subd. 3(c) extends §§ 62M.05 (standard decisions within five business days) and 62M.07 to fee-for-service. Policy or clinical questions on an authorization go to ASD.DHS@state.mn.us; the Acentra provider call center is 866-433-3658.[4][20][21]
EIDBI has five provider types, set out in § 256B.0949, subd. 15. A QSP must be an agency employee who is "either a licensed mental health professional or a licensed behavior analyst" (or a developmental or behavioral pediatrician) with 2,000 hours of ASD experience or equivalent graduate coursework; DHS removed physicians and APRNs from its QSP page on 9/16/26. A BCBA (or QABA-credentialed qualified behavior analyst) qualifies as a Level I provider; an RBT or BCaBA qualifies as Level II with a bachelor’s degree; Level III staff need the DHS Level III training, be 18 or older, and have a diploma or one of the listed alternatives. Clinical supervision is at least one hour per 16 hours of direct treatment, with QSP observation and direction at least monthly, no more than two consecutive months by telehealth.[1][14][13][12][2][3]
Three changes matter for anyone entering the market now. All EIDBI agencies had to apply for a provisional license by May 31, 2026; DHS is to propose permanent licensing standards to the Legislature by January 1, 2027. Laws 2026, ch. 95 added § 256B.0949, subd. 19: documentation must be signed with full name, title and credentials, entered within 72 hours of service, and include a record of supervision; agencies that fail it can have payments withheld (subd. 18). Laws 2026, ch. 121 added subd. 20: effective July 1, 2027 or on federal approval, whichever is later, billing limits of 40 hours a week of intensive services, two hours a day of travel, 20 hours a week of observation and direction, and 300 units a year of individual treatment planning, with exceptions for medical necessity that are "final and not subject to appeal." Agencies must also keep an office in Minnesota or a border state (subd. 16(a)(7)).[1][14][13][12][2][3]
The CMS-approved state plan page (SPA MN-24-0010, Attachment 4.19-B, effective January 1, 2024) sets EIDBI payment at the lower of the submitted charge or these agency rates: CMDE by a CMDE provider $50.112 per 15-minute unit; coordinated care conference $112.678 per provider per session; intervention with two providers (0373T) $24.192 per unit; and, for services by a QSP or Level I provider, ITP development $94.280 per session, individual intervention $20.178, group intervention $6.72, observation and direction $20.178, family/caregiver training $20.178 and group family training $6.72 per unit. Those rates are "reduced 20% when provided by a Level II provider" and "reduced by 50% when provided by a Level III provider," which puts a Level II RBT at about $16.14 and a Level III technician at about $10.09 per unit of 97153. Travel time is the lower of charge or 52 cents a minute.[18][5][4]
DHS’s August 2026 billing grid restates the percentages (100% QSP and Level I, 80% Level II, 50% Level III on 97153 and 97154; 0373T at 100% for every level) and prints the H0032 rate as "$94.80/unit" and H0046 as "$0.52 per unit"; the H0032 figure differs from the SPA’s $94.280, so check the MHCP fee schedule (behind a CPT licence click-through on mn.gov/dhs) for the current number. Managed care plans pay contracted rates. Units bill only past the midpoint (eight minutes of a 15-minute unit), and DHS’s 2026 manual rules bar billing for provider breaks, idle time or note-writing.[18][5][4]
Fee-for-service claims go on the 837P through MN–ITS or a batch system, and "MHCP receives them no later than 12 months from the date of service"; replacement claims are due within six months of the incorrect payment or 12 months from service, whichever is later. Every EIDBI line carries the UB modifier. The claim must name the pay-to provider, the rendering provider’s UMPI or NPI, and "The supervising provider for any services that require the supervision of a QSP"; the grid adds that "The QSP must be on all other EIDBI claims as the supervising professional" (the CMDE needs none), and Level III claims always need the rendering provider. Bill each day on its own line, POS 12 for home and community and POS 11 for office or non-direct work, and never mix authorized and unauthorized services on one claim. Telehealth uses POS 02 or 10, with modifier 93 for audio-only.[16][4][5][15][19][17]
For managed care, the statute directs DHS to require plans to "use a six-month timely filing standard," and the plans we checked print 180 days. Members (or providers with written consent; none is needed to appeal a prior authorization or payment denial) must appeal to the MCO within 60 days of the notice and may then request a state appeal within 120 days of the MCO’s decision. None of the EIDBI manual pages, the MHCP EIDBI section or the billing grid mentions electronic visit verification.[16][4][5][15][19][17]
Other insurance and payment timing, from the Billing Policy Overview (revised July 30, 2026): third-party liability and Medicare crossover claims must also reach MHCP "no later than 12 months from the date of service," and crossovers that do not cross automatically get six months from Medicare’s determination if that is later. "MHCP is required to pay or deny clean claims within 30 days and complex claims within 90 days of receipt"; clean claims are MHCP-primary claims without attachments, and complex ones include replacements, third-party liability claims and claims "related to services that are at a high risk of fraud." EIDBI is on that list now: DHS is "suspending all fee-for-service claims" for EIDBI and 13 other benefits for enhanced pre-payment review every warrant cycle, and "will release unflagged claims for reimbursement in the following warrant cycle (two weeks later)." A warrant cycle "is the two weeks before the electronic funds transfer (EFT) or the payment date"; it runs from the day after one claim cut-off to the next, and the cut-off and payment dates are on DHS’s payment and claim cut-off calendar (MHCP billing resources page). Flagged claims are reviewed by hand and may need documentation.[16][4][5][15][19][17]
Minnesota now licenses behavior analysts. Laws 2024, ch. 127, art. 19 created a license under the Board of Psychology (Minn. Stat. §§ 148.9981–148.9995; the BACB’s licensure table lists Minnesota, 2024, MN Board of Psychology). Since January 1, 2025, "an individual must not engage in the practice of applied behavior analysis unless the individual is licensed … as a behavior analyst or is exempt"; licensed psychologists are exempt, and so are "unlicensed supervisee[s] or trainee[s]" working "under the authority and direction of a licensed behavior analyst," family members acting under that direction, school-district employees, and supervised students. The license requires "a current and active national certification as a board-certified behavior analyst" (or the equivalent requirements) plus a background check, and renews every two years. The exceptions list has no out-of-state or telehealth carve-out, so a BCBA licensed in another state should get a Minnesota license (or confirm an exemption with the Board of Psychology) before treating a Minnesota child, including remotely. For rates: commercial ABA rates are negotiated and unpublished; the public benchmark is Minnesota Medical Assistance’s EIDBI rate, $20.178 per 15-minute unit of intervention when delivered by a QSP or Level I provider (SPA MN-24-0010, effective January 1, 2024).[23][24][25][26][27][1][11][18]
EIDBI adds its own constraints. A QSP must be a licensed mental health professional or "a licensed behavior analyst," defined as "an individual licensed under sections 148.9981 to 148.9995" (§ 256B.0949, subd. 2(e)), so a BCBA licensed only in another state cannot be the QSP. Every qualified provider must be an employee of an enrolled agency with an office in Minnesota or a border state, and DHS’s telehealth page limits telehealth to providers "licensed or registered by the state." In practice an out-of-state BCBA serving a Minnesota EIDBI member needs a Minnesota license and an employing Minnesota-enrolled agency, whether the work is in person or remote.[23][24][25][26][27][1][11][18]
The questions that decide whether a family can start with Minnesota Medical Assistance (EIDBI), and what they have to bring. Each maps onto something intake should ask on the first call.
Under 21. The statute defines the covered "person" as "an individual under 21 years of age" (§ 256B.0949, subd. 2(q)), and DHS lists "Younger than age 21" among the eligibility criteria.[1][8]
No expiry on the diagnosis itself; the clock is the CMDE. DHS says the CMDE "must be completed to initiate services and updated at least once every three years" (or sooner when the condition, diagnosis, family, placement or setting changes), the CMDE provider must complete the direct observation within 60 days of the CMDE date, and to restart services after termination "If the person’s CMDE is more than 36 months old … the person must receive a new CMDE." The annual CMDE for reauthorization is due 30 to 60 days before the current service authorization ends.[10][9][4]
Set by statute: the diagnosis of ASD or a related condition must be "completed by either (i) a licensed physician, advanced practice registered nurse, or physician assistant, or (ii) a mental health professional," be based on current DSM criteria with direct observation and caregiver information, and meet the standard diagnostic assessment rules of § 245I.10, subd. 6 (§ 256B.0949, subd. 4). DHS’s eligibility page says assessors use the DC:0-5 for children five and younger and the DSM from age six. The CMDE provider (physician, APRN, PA, mental health professional, or qualified clinical trainee with 2,000 hours of ASD experience or equivalent coursework) then confirms medical necessity.[1][8]
No instrument is mandated for EIDBI itself: DHS "strongly encourages providers to use standardized assessment tools" but "does not require specific assessment tools." The exception is a CMDE submitted for other disability or benefit decisions (waiver enrollment, SSI): there DHS requires "A direct observational assessment (e.g., ADOS-2)" and "A structured caregiver interview (e.g., ADI-R)," and says developmental history or non-autism-specific screens alone are "insufficient."[8][10]
No physician referral or order; the gate is the CMDE, which must "include medical or assessment information from the person’s physician, advanced practice registered nurse, or physician assistant" (§ 256B.0949, subd. 5(c)). Families may request a CMDE at any time and choose the CMDE provider; DHS publishes an EIDBI referral form (DHS-6751S) for families looking for providers.[1][10][8]
Yes, for most EIDBI services. The statute says Medical Assistance "covers medically necessary EIDBI services and consultations delivered via telehealth … in the same manner as if the service or consultation was delivered in person" (§ 256B.0949, subd. 13(l)). DHS lists the CMDE (97151), coordinated care conference, family/caregiver training (97156/97157), ITP development and progress monitoring (H0032), individual and group intervention (97153/97154) and observation and direction (97155) as telehealth-eligible; higher-intensity intervention (0373T) "cannot occur via telehealth." Same thresholds, authorization and rates as in person; QSP observation and direction may be remote for at most two consecutive months. Bill POS 02 (not at home) or POS 10 (at home), modifier 93 for audio-only, and never use telehealth POS or modifiers for non-client-facing services. Providers enroll for telehealth on the Telehealth Provider Assurance Statement (DHS-6806).[1][11][4][15]
Acentra Health decides within seven calendar days of receiving a CMDE or ITP; a pended request gives the provider 10 calendar days to respond, then Acentra has three business days. DHS-3806 requests (services above grid thresholds) and DHS-7109A changes are also decided within seven calendar days. Since January 1, 2026, § 62M.05, subd. 3a (standard determinations within five business days) applies to fee-for-service under § 62M.01, subd. 3(c). Authorizations span up to 180 days and may be approved retroactively for up to 180 days. Submit at least 30 days before the start date.[4][20][21]
Medical Assistance is still the payer of last resort, but EIDBI is "pay and chase." DHS: "EIDBI providers are not required to bill a member’s commercial insurance before billing Medicaid. MHCP or the MCO will seek reimbursement from third parties … This ‘pay and chase’ process applies to both fee-for-service and managed care members," though a payment received from another source must still be reported. That matches the federal rule letting states pay EPSDT claims and recover later (42 CFR 433.139(b)(3)(i)). For authorization, DHS tells providers with privately insured members to "follow the primary insurance’s authorization procedures."[4][28]
Coverage decides whether Minnesota Medical Assistance (EIDBI) 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.
Set by statute for every Medical Assistance member, fee-for-service or managed care. An EIDBI agency must "provide clinical supervision for a minimum of one hour for every 16 hours of direct treatment per person, unless otherwise authorized in the person’s individual treatment plan," and must provide "the required EIDBI intervention observation and direction by a QSP at least once per month" (Minn. Stat. § 256B.0949, subd. 16(a)(15)–(16), as amended by Laws 2026, ch. 95). The QSP may do that monthly observation and direction by telehealth for no more than two consecutive months; the third month must be in person. DHS’s clinical supervision page (updated 9/15/26) adds that each person gets one primary QSP (who signs the ITP), a backup QSP must be available, and a different ratio needs an exception documented in the ITP and approved through service authorization. Every intervention must be "provided by a qualified EIDBI provider and supervised by a QSP" (subd. 13(a)).[1][2][12]
Allowed in defined cases. DHS: "Multiple providers may deliver and bill for" the CMDE, ITP development and progress monitoring, coordinated care conference, observation and direction, and family/caregiver training "at the same time," and "Multiple providers may deliver a combination of EIDBI services at the same time (e.g., one provider delivers individual intervention, and another provider delivers observation and direction) as medically necessary." So 97153 and 97155 may be billed for the same clock time by two providers. 0373T is billed once per period no matter how many staff are present. DHS also tells providers to check the Medicaid NCCI edits before billing simultaneous codes.[7][5]
From the August 2026 billing grid: 97151 8 hours a day and 80 units a calendar year; 97153 and 0373T 8 hours a day; 97154 4.5 hours a day (up to 8 people); 97155 6 hours a day and "approximately 20% of the total authorized intervention time" unless the ITP justifies otherwise; 97156 and 97157 4 hours a day; H0032 and T1024 as clinically necessary. Medical-necessity guidance is at least 10 hours a week and no more than 20 for a person over seven without an exception. Statutory weekly limits (40 hours intensive, 20 hours observation and direction, 2 hours travel a day, 300 ITP units a year) take effect July 1, 2027 or on federal approval.[5][9][3]
Statutory since 2026. New subdivision 19 of § 256B.0949 (Laws 2026, ch. 95, art. 4, sec. 26) requires all CMDE and EIDBI documentation to be "signed and dated by the provider completing the documentation with the provider’s full name, title, and credentials," to "be entered within 72 hours of service and contain a record and explanation of any delays in entry," and to "include a record of supervision and oversight for staff providing services requiring supervision." "Each EIDBI service occurrence must be documented in a progress note." DHS-7108 (CMDE) must be signed by the CMDE provider and the caregiver or guardian, and DHS-7109 (ITP) by the QSP and the caregiver or guardian; those signatures are the family’s consent to start or continue services.[2][7]
Center, clinic, office, or home or community (including school). Bill POS 12 for home and community services in the ITP, POS 11 for office-based and non-direct work, POS 02/10 for telehealth. EIDBI may run during school hours when the ITP documents why, but must not replace IEP services or instruction, and since January 1, 2026 97153, 97154 and 0373T may not be delivered during homeschool or virtual-school instruction (97156 with a participating parent may). Travel time (H0046) is payable to and from home, school or community settings with POS 12 or 99.[7][4][5][1]
Both. The claim carries "The Unique Minnesota Provider Identifier (UMPI) or National Provider Identifier (NPI) of the rendering provider who delivered the service" and "The supervising provider for any services that require the supervision of a QSP"; the grid: "The QSP must be on all other EIDBI claims as the supervising professional," except CMDEs. Level III services always need the rendering provider’s number. Every individual provider enrolls with MHCP under provider type EI.[4][5]
Fee-for-service EIDBI claims are under enhanced pre-payment review: DHS suspends them each two-week warrant cycle and releases unflagged claims in the following cycle, about two weeks later; flagged claims are reviewed by hand. Claim cut-off and payment dates are on DHS’s payment and claim cut-off calendar. The general standard is 30 days for clean claims and 90 days for complex ones.
Yes, through the EIDBI benefit for members under 21 with autism spectrum disorder or a related condition. ABA is one of four approved EIDBI modalities. A CMDE establishes medical need, a QSP writes the ITP, and the plan (Acentra Health for fee-for-service, otherwise the member’s MCO) authorizes treatment.
Not the first CMDE (97151 UB) in a calendar year, up to 80 units; ITP development (H0032) needs none either. A second CMDE in the same year needs form DHS-3806. Treatment codes (97153–97157, 0373T, H0046) need service authorization.
Under SPA MN-24-0010 (effective Jan. 1, 2024), $20.178 per 15-minute unit for individual intervention, observation and direction, and family training by a QSP or Level I provider; 80% of that for Level II and 50% for Level III; $24.192 for two-provider intervention; $50.112 per unit for the CMDE. MCOs pay contracted rates.
Yes, since January 1, 2025, to practice ABA in Minnesota, unless exempt (licensed psychologists; supervisees working under a licensed behavior analyst; school-district employees; supervised students). The statute has no out-of-state or telehealth exception, and an EIDBI QSP must hold a Minnesota license as a behavior analyst or mental health professional.
Yes for the CMDE, ITP work, care conferences, family training, individual and group intervention, and observation and direction, at the same rates and with the same authorization; not for higher-intensity 0373T. QSP observation and direction can be remote only two months in a row. Bill POS 02 or 10.
Not for EIDBI. DHS says providers "are not required to bill a member’s commercial insurance before billing Medicaid"; MHCP or the MCO recovers from the commercial plan ("pay and chase"), for fee-for-service and managed care members alike.
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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