California Just Proposed Major Changes to Medi-Cal ABA Therapy Coverage: What Parents Need to Know (2026)

California's Medi-Cal program is preparing another significant change to how it authorizes Applied Behavior Analysis (ABA) therapy for children and teens under 21, and this time disability advocates say the stakes are much higher than the April 2026 update many families already navigated. The Department of Health Care Services (DHCS) has circulated a draft rewrite of the state's core ABA and Behavioral Health Treatment (BHT) policy, and autism advocacy groups are warning that it could quietly roll back protections that took years to establish.

Here is what California families need to know about the proposed changes, why advocates are concerned, and what to watch for next.

What Is DHCS Proposing?

On June 22, 2026, DHCS circulated a draft All Plan Letter that would replace APL 23-010, the policy that currently governs how Medi-Cal managed care plans authorize and coordinate ABA and BHT services for members under 21. The draft is formally titled "Responsibilities for Behavioral Health Treatment Coverage, Including Applied Behavior Analysis, for Members Under 21 Years of Age," and it tracks language from a 2026-27 state budget proposal aimed at tightening oversight of ABA and BHT spending.

If finalized, Medi-Cal managed care plans would have 90 calendar days to update their internal policies, or to formally attest that no changes are needed on their end.

The Biggest Concern: Weakened Parity Protections

The most significant flashpoint in the draft is what advocates say it removes, not what it adds. Federal mental health parity law requires that limits placed on mental health and behavioral health benefits, like ABA, be no more restrictive than the limits placed on comparable medical or surgical benefits.

According to autism policy advocates, the draft APL strikes several pieces of language that currently make that parity requirement operative for California's Medi-Cal ABA program, including a standalone paragraph requiring plan compliance with federal parity law and a parallel directive tied to APL 22-006. What remains in the draft is largely background language acknowledging that parity law exists, rather than a direct command that plans follow it.

Julie Kornack, Chief Government and Payor Relations Officer at the Center for Autism and Related Disorders, has publicly characterized the change as reversing protections that took decades to build, and other advocates argue the draft would be inconsistent with both the federal Mental Health Parity and Addiction Equity Act and the Medicaid EPSDT mandate, which guarantees medically necessary care for children under 21.

New Utilization Management Hurdles

The draft also introduces a tiered documentation framework tied to how many hours of ABA a child is authorized to receive each week:

• Enhanced review above 25 hours per week. Requests exceeding this threshold would trigger additional documentation requirements.
• Extra justification above 4 hours per day. Higher daily intensity would require progressively more specific clinical justification.
• Mandatory step-down planning. Treatment plans would need to include defined mastery criteria, discharge criteria, and projected timelines, with plans able to reduce services if a child shows no measurable progress across two consecutive authorization periods.

DHCS frames these changes as encouraging individualized, outcome-based care. Advocates counter that the thresholds still reference CASP guidance suggesting a 10 to 25 hour weekly range, even though research on intensive early intervention has generally found better outcomes at higher weekly hours for children who need them.

Guardian Participation and Re-Diagnosis Concerns

Two other proposed changes have drawn particular scrutiny from parent advocates:

Mandatory guardian training. The draft would require documented guardian training and home generalization strategies as a condition of continued coverage, a departure from current policy, which explicitly prohibits plans from mandating parent participation as a coverage condition.

Independent diagnosis confirmation. The draft allows plans to require independent confirmation of an autism diagnosis when the diagnosing clinician is affiliated with the BHT provider. Advocates say this functions as a de facto re-diagnosis requirement, which would sit in tension with California's AB 951, the state law that took effect January 1, 2026, and prohibits commercial health plans from requiring repeat autism diagnoses for children who already have one on file.

School-Based Services Could Get More Complicated

The draft would also require families and providers to first request school-based BHT services through the child's Local Educational Agency (LEA), with plans reviewing the child's Individualized Education Program (IEP) to check for duplication of services. If a school district does not amend an IEP within 45 business days, plans could pause or reduce a child's ABA services in the meantime.

Critics say this shifts financial responsibility onto school districts and regional centers without reducing what managed care plans are paid, while families are left navigating delays between two separate systems.

What Stays the Same

Not everything in the draft is a reduction in protections. The proposal keeps a safeguard prohibiting plans from denying ABA authorizations based solely on artificial intelligence or automated review tools; a licensed clinical professional must still review any denial. Plans would also be required to allow make-up sessions when weekly limits create scheduling conflicts, and DHCS has signaled it intends to ease established-place-of-business requirements for Board Certified Behavior Analysts through a future bulletin, which could help address California's ongoing BCBA shortage in some regions.

Where Things Stand Now

The public comment period on the draft APL closed July 3, 2026, and DHCS has not yet released a finalized version. Once finalized, plans would have 90 days to implement changes. Advocacy organizations, including the Center for Autism and Related Disorders and the ADEC Foundation, have urged families and providers to continue pressing DHCS to restore explicit parity language and to reconsider using an All Plan Letter, rather than a formal rulemaking process under the Administrative Procedure Act, for changes advocates argue are substantive enough to warrant it.

Because nothing is final yet, California families do not need to take any action today. But if your child receives ABA therapy through Medi-Cal, it is worth keeping an eye on your managed care plan's authorization letters over the coming months, since a finalized policy could change documentation requirements at your next reauthorization.

What California Families Can Do

• Keep documentation current. Make sure your child's treatment plan includes clear, measurable goals, since more detailed documentation requirements appear likely regardless of the final policy language.
• Ask your provider about mastery and step-down criteria. Providers who already track progress against specific milestones will be better positioned for reauthorization under any new framework.
• Understand your appeal rights. If a future authorization is reduced or denied, Medi-Cal enrollees have the right to a state fair hearing, and continuation of benefits ("aid paid pending") while an appeal is active.
• Watch for the finalized APL. DHCS behavioral health information notices and All Plan Letters are published on the DHCS website, and your managed care plan is required to notify providers of policy changes.

If your family is navigating a change in ABA coverage, or if you are looking for a new provider who can help with authorization paperwork and documentation, ABA Navigator's provider directory can help you find ABA therapy providers near you who are experienced with Medi-Cal and California's evolving behavioral health policy landscape.