If your child receives ABA therapy through Medi-Cal in California, a significant policy change took effect on April 20, 2026. California Medi-Cal managed care plans adopted new medical necessity criteria for ABA therapy, replacing the standards that had previously governed Medi-Cal coverage and marking a shift toward more individualized, outcome-focused care for children under 21.
This article explains what changed, who is affected, and what California families should know before their child's next ABA authorization renewal.
What Changed on April 20, 2026
Effective April 20, 2026, California Medi-Cal managed care plans — including Health Net and other contracted plans — adopted a new clinical policy: CA.CP.BH.104 Applied Behavior Analysis (ABA). This policy replaces the Council of Autism Service Providers (CASP) criteria that had previously been used to determine medical necessity for Medi-Cal enrollees.
This is a Medi-Cal-specific change. Families with commercial employer group health plans (HMO, POS, PPO) or Individual and Family Plans through Covered California are not affected — CASP criteria continue to apply to those plans.
What the New Criteria Mean for Families
The stated goal of the new policy is to support more individualized, needs-based care for children and adolescents with autism — promoting developmental, behavioral, and functional improvements for each child and their family. In plain language, the shift moves away from purely standardized, hours-based benchmarks toward a more child-specific assessment of what ABA therapy should look like for your individual child.
In practice, this change may affect:
- Prior authorization decisions: ABA hour requests may now be evaluated under the new CA.CP.BH.104 criteria, which could produce different outcomes than reviews conducted under CASP. Some families may find approvals better reflect their child's actual clinical profile.
- Renewal reviews: When your child's ABA authorization comes up for renewal, the reviewing plan will apply the new policy standards.
- Appeals: If coverage is denied or reduced under the new criteria, the formal basis for your appeal will reference CA.CP.BH.104 rather than CASP.
Is There a New Hour Cap?
No. The April 2026 Medi-Cal update does not establish a hard hour cap for ABA therapy. Coverage remains based on medical necessity — your child's BCBA and treatment team document why the requested hours are clinically appropriate for your child's specific goals and needs.
However, because the medical necessity criteria have changed, some families may notice differences in approved hours during their next authorization review. If your child's hours are reduced or denied, ask the plan to provide a written explanation citing the specific criteria applied, and work with your BCBA to respond with updated clinical documentation.
What to Do If Your Authorization Is Denied or Reduced
Families whose ABA coverage is denied or reduced have strong protections under California law. Here is your step-by-step action plan:
- Request a written Notice of Action (NOA). Your Medi-Cal managed care plan is required to give you a written explanation for any denial, reduction, or termination of services — including which specific criteria were applied.
- File an internal appeal. Submit a formal appeal to the plan. Your child's BCBA can provide updated clinical documentation, progress notes, and a letter of medical necessity to support the appeal.
- Request a State Fair Hearing. You have the right to request a hearing through the California Department of Social Services if you disagree with your plan's decision.
- Request an Independent Medical Review (IMR). California's Department of Managed Health Care (DMHC) offers free independent review of disputed coverage decisions. IMR is especially effective when strong clinical documentation supports continued or increased hours.
- Contact Disability Rights California. This organization provides free legal advocacy for Californians with disabilities navigating Medi-Cal denials. They have specific expertise in ABA coverage disputes.
How Medi-Cal ABA Coverage Works in California
For families new to Medi-Cal coverage for ABA, here is the basic framework:
- Medi-Cal covers all medically necessary behavioral health treatment (BHT) services — including ABA — for eligible members under age 21
- A physician or psychologist must document that ABA therapy is medically necessary for your child
- Prior authorization is required before services begin
- Coverage is managed through Medi-Cal managed care plans — there is no hard hour cap, but all hours must be authorized
- As of July 1, 2025, children with fee-for-service Medi-Cal can receive ABA from enrolled Medi-Cal Qualified Autism Service (QAS) providers outside of the Regional Center system, expanding provider options for some families
Commercial Insurance vs. Medi-Cal: Different Rules Apply
It is important to keep these systems separate in your mind. The April 2026 criteria change applies only to Medi-Cal managed care plans.
If your child has commercial insurance — through an employer plan or a plan purchased through Covered California — the CASP criteria still govern your coverage. California's state insurance mandate (Senate Bill 946, signed in 2011) requires commercial plans to cover medically necessary ABA therapy for individuals with autism, and CA.CP.BH.104 does not affect those reviews.
Questions to Ask Your ABA Provider About the Medi-Cal Change
Your child's BCBA and provider billing team should already be aware of the April 2026 change. If you are unsure how this affects your child, here are good questions to ask:
- Are you familiar with California's new Medi-Cal ABA medical necessity criteria (CA.CP.BH.104) effective April 20, 2026?
- Do you anticipate any changes to my child's authorized hours at our next renewal?
- What clinical documentation do you plan to submit with our next prior authorization request?
- If our hours are reduced, can you help us file an appeal?
Find a Medi-Cal ABA Provider in California
Not all ABA providers in California accept Medi-Cal, and not all participate in every managed care plan. Finding a provider who accepts your specific plan — and who has experience navigating California's authorization requirements under the new criteria — is essential.
ABA Navigator lists hundreds of ABA therapy providers across California, including many who accept Medi-Cal and various managed care plans. Use our directory to search by location and insurance accepted.
Search ABA therapy providers in California on ABA Navigator and filter by insurance to find a Medi-Cal provider near you.
If you have questions about how the new Medi-Cal criteria apply to your child's plan, contact your managed care plan's member services department — or ask your child's BCBA before your next authorization renewal date.