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Parent guide · ABA · 2026 edition

ABA fraud: what every parent should know in 2026.

ABA is one of the most studied, most regulated childhood therapies in healthcare. It is also, in 2026, one of the fastest growing categories of insurance fraud investigation. Most ABA providers are honest and clinically excellent. A small number are not. This guide is for the parent who wants to know what good looks like, what bad looks like, and exactly what to do if something feels off.

6 patternsOf common fraud 4 red flagsOn your EOB 5 questionsTo ask the practice 3 accreditationsThat signal quality
$190M
Identified ABA fraud and abuse recoveries since 2022
5x
Growth in payer fraud investigations on ABA since 2019
7yr
Window during which a payer can audit your child's records
100%
Of parents have the right to request a full chart copy

Why this matters nowThe job of the parent has quietly changed.

A decade ago, a family enrolled in ABA, the BCBA wrote the plan, the RBT showed up, and the insurance paid. The parent's job was to support the work at home. That is still the heart of the relationship. What changed in the last five years is that ABA grew very fast, regulators noticed, and the U.S. Department of Justice and state Medicaid Fraud Control Units stood up dedicated ABA investigation teams. In 2024 and 2025 alone, fraud recoveries against a handful of large ABA chains crossed nine figures. Most of the families inside those clinics did not know anything was wrong until the news broke.

The parent's job today includes reviewing the explanation of benefits the insurance company sends, asking the practice five basic questions a year, and trusting the instinct that something is off when something is off. None of it requires a clinical degree. It requires reading a piece of paper and asking a question.

Most ABA providers are excellent. This guide is not an indictment of the field. It is a practical checklist for the families that fund the field.

The patternsThe six common shapes of ABA billing fraud.

Fraud in ABA almost always takes one of six shapes. The Office of Inspector General, the DOJ, and state Medicaid integrity programs have published case studies on each. Recognizing the shape is the first step. Reporting suspected fraud is the second.

The patterns

Six shapes of ABA billing fraud.

Pattern 01

Phantom billing

The practice billed for sessions that did not happen. The child was sick that week. The RBT was off. The claim went out anyway.

Red flag: dates on your EOB you do not remember
Pattern 02

Upcoded supervision

An RBT direct treatment visit (97153) gets billed as BCBA supervision (97155) because 97155 pays roughly twice as much. The BCBA may have stopped by for five minutes, or not at all.

Red flag: 97155 appearing more often than 97153
Pattern 03

Unlicensed rendering

A staff member without an active RBT certification, or a BCBA whose license has lapsed, is billed under another credentialed person's number. The clinical work may have happened. The billing is fraudulent.

Red flag: provider name you do not recognize on the EOB
Pattern 04

Inflated hours

A two-hour session is billed as four hours. Or two separate hour-long sessions in different cities on the same day under the same RBT. The math does not add up to a human schedule.

Red flag: more units billed than your appointment scheduler shows
Pattern 05

Co-treatment double billing

The clinic also delivers speech or OT to your child. The same time block is billed under two separate disciplines as if the clinicians were not in the same room together. In most cases this is not allowed.

Red flag: overlapping time slots across providers on the same date
Pattern 06

Kickback referral schemes

The diagnostic provider, the prescribing physician, and the ABA practice are quietly linked by financial arrangement, even though they present as independent. The family is steered into the chain regardless of whether it is the best clinical fit.

Red flag: one entity insisting you can only use a single named ABA provider

Your EOBThe four things to look at every month.

The explanation of benefits is the receipt the insurance company sends after they pay a claim. It is not a bill. It is a record of what was billed in your child's name. Reading it once a month takes ten minutes and is the single highest-leverage thing a parent can do.

  1. Dates of service. Compare to your appointment calendar. If the EOB shows visits on dates your child did not have ABA, that is the first conversation with the practice.
  2. Service codes. ABA codes run 97151 to 97158. If you see codes outside that range, ask what they were. If you see 97155 appearing every visit, ask how often the BCBA actually attends.
  3. Provider name. The EOB names a rendering provider. It should be the RBT or BCBA you know. If you see a name you do not recognize, ask the practice who that is and why they appear on your EOB.
  4. Units and dollars. Each visit is billed in 15-minute units. A 60-minute session is four units. A 90-minute session is six units. Multiply minutes by 1.5 and divide by 15 if the math feels strange. The number should match how long your child was actually in session.

You do not need to be a coder. You need to notice that something does not match. The conversation that starts with "I noticed something on the EOB" is a healthy conversation a good practice will welcome.

Your rightsWhat the law gives you, by default.

Federal HIPAA, state laws, and most payer contracts give parents and guardians a strong set of default rights. The practice is required to honor them. If the practice resists, that itself is a signal.

  • The right to a full copy of your child's record. Session notes, assessments, treatment plans, supervision notes, parent communication logs, billing records. Within 30 days of written request, in most jurisdictions.
  • The right to know who is rendering each visit. The credential and license of the person who actually delivered the service that day.
  • The right to contact the payer directly. Every commercial payer and every state Medicaid agency has a fraud reporting line. You do not need the practice's permission to call.
  • The right to switch providers. No practice can hold your child as a captive caseload. You can request transfer at any time. The practice must transfer records on request.
  • The right to file a formal complaint. With the payer, with the state Medicaid agency if Medicaid-funded, with the state board of behavior analysts where applicable, and with the BACB for issues involving a BCBA's professional conduct.
The conversation

Five questions to ask your child's ABA practice.

01

What credentials does each person on my child's team hold today?

RBT, BCaBA, BCBA, BCBA-D. Each is a real registry you can look up at the BACB website. The practice should be able to name them and the active status of each, on the spot.

02

How often does the supervising BCBA actually observe my child's sessions?

The honest answer might be once a week, once every two weeks, or 5 to 10 percent of treatment hours. There is no single right number, but the answer should match what is billed under 97155.

03

Can I see my child's session notes from the last 30 days?

A reputable practice will say yes, today or tomorrow. A practice that delays for weeks or insists on a long records request process is a practice with notes it does not want to share.

04

What goes on the EOB this month, and why?

The practice should be able to walk you through the codes billed, the units, and the rendering providers for a given month. If they cannot, they are not paying close enough attention to the billing being done in their own name.

05

Are you BHCOE accredited, and may I see the certificate?

BHCOE is the only ABA-specific accreditation. Not every excellent practice has it, but the ones that do have committed to a level of operational and clinical discipline that fraud-prone practices do not maintain.

The signals of quality

The accreditations that tell you a practice is real.

Practice level

BHCOE

Behavioral Health Center of Excellence is the only ABA-specific accreditation. A BHCOE-accredited practice has been audited on clinical standards, documentation discipline, supervision dose, and outcomes reporting. Look for the certificate. Verify it on the BHCOE website.

Individual level

BACB

The Behavior Analyst Certification Board credentials BCBAs, BCBA-Ds, and RBTs. Every BCBA and RBT working with your child should appear in the BACB public registry. The registry tells you certification status, expiration, and any disciplinary history.

Field level

CASP

Council of Autism Service Providers is the trade body for ABA practices. CASP membership signals the practice participates in the field's published standards and practice guidelines. Not an audit, but a meaningful signal.

If something feels offThe three steps to take, in order.

You read the EOB. Something does not match. The dates are off. The codes look strange. The provider name is unfamiliar. The honest first call is always to the practice itself, because most discrepancies are clerical, not criminal. Then escalate if needed.

  1. Call the practice's billing line first. Ask for an itemized explanation of the visits in question. Get the answer in writing. A clean practice will close the loop in days.
  2. Call the payer fraud line if the answer does not satisfy you. Every payer has one. The phone number is on the back of your insurance card or on the EOB itself. You can call anonymously. Investigations happen on a slower timeline than billing, but the call is logged.
  3. File a state-level complaint if the issue involves Medicaid or licensed credential conduct. Each state Medicaid Fraud Control Unit takes reports. The BACB takes complaints about individual BCBA professional conduct. The state behavior analyst licensing board takes complaints in states with licensure.

Trust the practice. Verify the billing. Speak up when something looks wrong. The worst outcome is a fraud that ran for years because no one asked.

FAQ · For parents

Eight questions parents ask us.

Am I responsible for fraud committed by my child's ABA practice?

No. The fraud was committed by the practice, not by you. You may be asked to provide records or attest to dates of service if a payer investigates. Cooperating with the payer or state Medicaid Fraud Control Unit is appropriate and protects your family.

How do I check if my child's BCBA or RBT is in good standing?

Visit the BACB public registry at bacb.com. Search by name. You will see the credential type, status, expiration date, and any public disciplinary actions. Do the same for the supervising BCBA. If a name on the EOB is not in the registry, that is a serious red flag.

Is it normal for a practice to bill for sessions my child did not have?

No. It happens occasionally as a clerical error and is corrected on request. If it happens repeatedly, or the practice resists correction, you are seeing pattern one above, phantom billing. Document the dates, get the answer in writing, and escalate to the payer.

What do I do if my child's BCBA changes every month?

High BCBA turnover is not automatically fraud. It is a quality concern and often a sign of poor supervision discipline. Ask whether the supervision plan continues, who the new supervising BCBA is, and how the transition will be managed. If the practice cannot answer, consider switching.

Can I record a session to verify what is happening?

State laws vary on consent to record. Many states are single-party consent, meaning you can record sessions involving your minor child. Check your state. Most reputable practices will welcome a request for a transparent observation rather than a covert recording.

My insurance approved 25 hours per week. The practice keeps trying to bill more. Is that fraud?

It can be. The authorization is the boundary. Billing above it is either an error, an unauthorized service the family will be left holding, or fraud. Get the authorization letter from your insurance, share it with the practice, and require they bill within it. If they continue to overbill, escalate.

What if my child's practice tells me the records cost money to release?

HIPAA allows the practice to charge a reasonable copying fee, not a profit. Many states cap the fee. The practice cannot withhold records because of dispute over a fee. If they do, file a HIPAA complaint with the U.S. Department of Health and Human Services Office for Civil Rights.

Should I switch providers if I find one of these red flags?

Not automatically. A single clerical error is not fraud. A pattern, or a refusal to explain, is. Trust your instinct, document what you saw, talk to the practice once, and switch providers if the answer is evasive. Your child's records travel with you.

A parent guide, printed and shared.

This guide is published openly so any family can use it. If you are an ABA practice and want to share it with your enrolled families, you are welcome to link or distribute it. If you are a family that suspects something and wants a confidential second opinion before you act, our team is available.

Ask us a question, confidentially Read more for families