State Regulatory · Massachusetts · ABA

The answer first: MassHealth ABA reimbursement rates are not going up. On May 22, 2026, EOHHS filed a proposed re-adoption of 101 CMR 358.00, the regulation that sets applied behavior analysis rates, with a proposed effective date of December 1, 2026 and no increase to the fee schedule that has been in place since October 2024. EOHHS projects zero aggregate spending change from the re-adoption. If finalized as filed, the October 2024 rates carry into 2027.

What actually happened, and when

Massachusetts law, M.G.L. c. 118E, s. 13D, requires EOHHS to periodically review the rates it pays for health services. That review happened for ABA. The outcome was a decision to re-adopt 101 CMR 358.00 as is, not to raise it. The procedural trail is short and fully public.

• October 2024

  Current fee schedule takes effect

  The rates in 101 CMR 358.00 that ABA providers bill against today were last set here. No update since.

• May 22, 2026

  EOHHS files proposed re-adoption

  The filing re-adopts 101 CMR 358.00 with no rate increase and projects no aggregate change in spending.

• June 17, 2026

  Public hearing held

  Noticed through the Secretary of the Commonwealth (sec.state.ma.us). The comment window was the industry's formal shot at the record.

• December 1, 2026

  Proposed effective date

  If adopted as filed, the October 2024 schedule is locked in and runs into 2027.

A freeze is a cut, just measured in real terms

Nothing on the fee schedule goes down. That is the framing EOHHS's zero-change projection invites. But every ABA operator in Massachusetts knows the other side of the ledger: BCBA compensation, RBT wages, recruiting costs, and supervision overhead have kept climbing since October 2024. A rate held flat while labor costs rise is a real-terms cut, compounding for every month the freeze runs. By the proposed effective date the schedule will be 26 months old, and it will keep aging into 2027.

The state's own analysts have been circling this tension. The Massachusetts Health Policy Commission's Behavioral Health Rates Analysis chartpack, published May 2026, examines how behavioral health reimbursement compares to the cost of delivering care in the Commonwealth. Read alongside the 101 CMR 358.00 filing, the picture is a payer that has studied the rates and chosen to hold them.

The lever left is operations, not rate relief

With the hearing behind us and the effective date ahead, the realistic planning assumption for Massachusetts ABA organizations is flat MassHealth rates through at least 2027. That moves the margin conversation away from the fee schedule and onto the two levers providers actually control: payer mix and utilization efficiency. Every authorized hour that goes undelivered, every cancellation that is not backfilled, every claim that leaks to denial or untimely filing is now a permanent loss, because there is no rate increase coming to paper over it.

Operator to-do list

• Track final adoption of 101 CMR 358.00 in the Massachusetts Register via sec.state.ma.us so the December 1, 2026 effective date does not arrive as a surprise.
• Rebuild FY2027 budgets on flat MassHealth ABA rates. Model the freeze explicitly as a real-terms decline against your actual BCBA and RBT wage trend, not as a neutral event.
• Re-run payer mix math. Know your blended revenue per delivered hour by payer, and weight growth toward contracts that still have rate motion.
• Close the utilization gap: authorized hours versus delivered hours, cancellation recapture, and RBT schedule density are now the primary margin levers.
• Tighten the revenue cycle under the frozen schedule: clean claims, denial prevention, and timely filing discipline, because there is no rate cushion to absorb leakage.
• Benchmark your economics against the HPC Behavioral Health Rates Analysis chartpack (May 2026) so your next comment letter or association filing argues from the state's own data.