8
Real compliance deadlines between Aug 1, 2026 and Dec 31, 2027
Compliance Calendar · ABA · 2026-2027
The real ABA compliance calendar: every 2026-2027 deadline in one table.
A rumor that "every ABA agency must be all-BCBA or all-RBT by January 2027" has been making the rounds. It is false, and we fact-checked it line by line in our full guide to ABA agency requirements for 2027. The danger is not the rumor itself. The danger is that operators who dismiss it also dismiss the eight real deadlines hiding underneath it.
Oct 1 2027
Indiana ABA group enrollments must be actively accredited (ACQ or BHCOE)
6 new
Adaptive behavior CPT codes effective Jan 1, 2027, with 97151-97158 revised
52 x 8
Jurisdictions and payer lanes tracked in our live policy matrix
Exhibit 1 · Seventeen months, eight deadlines
The calendar the rumor was hiding.
Five independent transitions, issued by four different kinds of authority, landing between mid-2026 and late 2027. Agencies that treat them as one rumor will miss real deadlines. Agencies that separate them can schedule the work.
Here is the actual calendar. Print it, share it, and assign an owner to every row that touches a state you bill in. Each deadline below comes from a primary source: a Medicaid bulletin, a certification board, a state licensing act, the AMA, or a payer contract. Nothing on this page is a rumor.
The rumor is false. The eight deadlines underneath it are not.
Exhibit 2 · The centerpiece
Every 2026-2027 ABA deadline, one table.
Eight rows, August 1, 2026 through December 31, 2027. Scroll sideways on mobile. Every row cites its issuing authority.
| Date | Authority | Requirement | Who it hits | What to do now |
|---|---|---|---|---|
| Aug 1, 2026 | Indiana Medicaid IHCP BT202646 |
Enrolled ABA groups must have submitted proof they initiated accreditation. Failure results in enrollment deactivation. | Currently enrolled Indiana ABA group providers. | Confirm your submission is on file. If it is not confirmed, this is a this-week problem. |
| Dec 31, 2026 | MassHealth | Center-based ABA providers must be accredited. | Massachusetts center-based ABA providers. | Start now if you have not. Accreditation cycles commonly run 9 to 15 months end to end. |
| Jan 1, 2027 | BACB | New BCBA and BCaBA eligibility and fieldwork standards take effect. Pathways 3 and 4 end. | Individuals applying for or maintaining certification, and agencies employing trainees. | Verify trainee coursework and fieldwork map to the 2027 forms now, not at application time. |
| Jan 1, 2027 | AMA CPT | Adaptive behavior code family rewritten: 6 new codes, 97151-97158 revised, 0362T and 0373T deleted. | Every ABA agency in the country. | Build a December test plan: fee schedules, spanning authorizations, EHR templates, denial crosswalks. |
| Jan 1, 2027 | Point32Health | MA and RI center-based ABA providers must be accredited. All other contracted providers: January 1, 2028. | Center-based ABA providers in Massachusetts and Rhode Island contracted with Point32Health. | Check your contract lane and confirm which date applies to you, in writing. |
| Jan 15, 2027 | Illinois Licensing Act Sec. 150 |
Owners of private ABA businesses who are not Illinois-licensed behavior analysts must divest. PA 104-0618 carves out schools, qualifying nonprofits, and certain multidisciplinary entities. | Private Illinois ABA business owners without an Illinois behavior analyst license. | Get entity-level legal review well before January 15. Hiring a BCBA does not cure the ownership structure. |
| Oct 1, 2027 | Indiana Medicaid | All ABA group enrollments must have completed accreditation and remain actively accredited (ACQ or BHCOE) or lose enrollment. | All Indiana ABA group enrollments, new and existing. | Pace the cycle: subtract survey scheduling and corrective actions and October 2027 is closer than it looks. |
| Dec 31, 2027 | MassHealth | All ABA providers must be accredited. | Every MassHealth ABA provider. | Put the deadline on the executive calendar with a named owner today. |
Cannot wait · Indiana
The row that cannot wait: Indiana.
IHCP Bulletin BT202646 required currently enrolled ABA groups to submit documentation proving they initiated accreditation by August 1, 2026, and states that failure results in enrollment deactivation. Completion deadline: October 1, 2027, with accreditation from ACQ or BHCOE. If your Indiana submission is not confirmed, stop reading and confirm it.
Two more rows to read carefullyThe one everyone misreads, and the one that hits everyone.
Misread row · Jan 1, 2027
The BACB change is not a staffing mandate
The January 1, 2027 BACB changes govern people applying for or maintaining BCBA and BCaBA certification: Pathways 3 and 4 end, and new fieldwork standards apply. They do not order your agency to change its staffing model. Your staffing rules live in state law, Medicaid policy, and payer contracts, which is why the same model can be billable in Georgia and unbillable in Massachusetts.
National row · Jan 1, 2027
The 2027 CPT rewrite hits every agency
Six new adaptive behavior codes, revisions across 97151-97158, and deletion of 0362T and 0373T, effective January 1, 2027. Every fee schedule, spanning authorization, EHR template, and denial crosswalk needs a December test plan. Our ABA CPT code guide tracks the finals as the AMA releases them.
Checklist · This week
Three moves this week.
- Map every state you bill in against the table above.
- Split individual compliance (certifications, licenses, payer credentialing) from organizational compliance (accreditation, ownership, enrollment) into separately owned trackers.
- If Indiana, Massachusetts, Rhode Island, or Illinois is in your footprint, put the specific deadline on the executive calendar with a named owner today.
We maintain a live ABA payer policy matrix covering 52 jurisdictions and 8 payer lanes, refreshed monthly, and our credentialing team runs BCBA payer enrollment at a 22-day average turnaround. For the full line-by-line fact-check of the 2027 rumor, read the complete guide to ABA agency requirements for 2027.
Sources
- Indiana Health Coverage Programs (IHCP), Provider Bulletin BT202646, ABA group accreditation requirement. in.gov/medicaid
- Behavior Analyst Certification Board, 2027 BCBA and BCaBA eligibility and fieldwork requirements. bacb.com
- MassHealth, ABA provider accreditation requirements (vendor contract). mass.gov
- Point32Health, provider update on ABA accreditation requirements. point32health.org
- American Medical Association, September 2025 CPT Editorial Panel Summary of Actions, adaptive behavior services. ama-assn.org
- Centers for Medicare and Medicaid Services, Medicaid FAQs on state flexibility in provider qualifications. medicaid.gov
- Illinois General Assembly, Public Act 104-0618 and the Behavior Analyst Licensing Act, Section 150. ilga.gov
This article is educational information, not legal advice. Deadlines and requirements are drawn from primary sources current at publication; verify each item against the issuing regulator, payer, and your counsel before acting.
Want your footprint mapped against every row?
Book a 30-minute review and we will map your states and payers against this calendar with you, at no charge. Live payer-policy matrix, 52 jurisdictions and 8 payer lanes, refreshed monthly. BCBA payer enrollment at a 22-day average turnaround.