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The ABA Operator · Issue 5, November 2026

Prior auth API countdown: eight weeks to January 1, 2027

This month: the Prior Authorization API due January 1, 2027 and six questions for MCOs; Indiana's FBA rule from October 29; two Blue plans tightening ABA review.
CMS-0057-F · Jan 1, 2027 IN BT2026162 · Oct 29 BCBS Nebraska I.178 · Nov 15

October 27, 20265 min readASP-RCM Solutions

Edition
5 · Nov 2026
Focus
PA API countdown
Audience
ABA operators
Dates
Oct 29 · Nov 15 · Jan 1
Horizon
8 weeks
Length
5 min
Jan 12027
Prior Authorization API, CMS-0057-F [1]
Oct 292026
Indiana FBA per BIP target behavior [4]
Nov 152026
BCBS Nebraska I.178: 25 hours a week; telehealth 97155 and 97156 only [6]
6questions
For every plan that authorizes ABA, this month
Story 1

Eight weeks

The API lists covered services and documentation requirements, takes the request and answers one of three ways [1]; drugs excluded; CMS names the Da Vinci CRD, DTR and PAS kits [2].

Approve

With the date or circumstance the authorization ends [1]

Deny

With a specific reason [1]

More information

A request for the missing items [1]

  1. 1
    Jan 1, 202672-hour and 7-day clocks, specific denial reasons [1]
  2. 2
    Mar 31, 2026First public PA metrics
  3. 3
    Nov 2026Send the six questions
  4. 4
    Jan 1, 2027Prior Authorization API required [2]
Ask every MCO, FFS program and MA planKeep
Where are your published 2025 prior authorization metrics?URL and the figures
What are your measured decision times for 97151 to 97158?Your own request-to-decision log
Will the API be live January 1, and through CRD, DTR and PAS?Written go-live date, sandbox access
Which ABA documentation requirements will the API expose?The list, against your treatment plan template
How will approvals carry an end date and denials a specific reason?Sample responses for your ledger
Which portal, clearinghouse or vendor paths stay open?Your fallback per plan; scope table in the MCO readiness map
Story 2

Indiana: an FBA behind every BIP from October 29

BT2026162: the state has seen BIPs with no FBA [4]. North Carolina: RBT or ABAT certification to be paid [5].

A complete FBA

Indiana, Oct 29, 2026

  • Indirect tool (QABF, FAST, MAS, MARS, PBQ, FAI), graphed
  • ABC data; triggers and precursors where applicable
  • Hypothesized function statement [4]

Each reauthorization

Indiana

  • Updated indirect assessment, recent ABC data, function statement [4]

Late November 2026

North Carolina

  • 120-day certification grace from August 1 runs out [5]
Story 3

Two Blue plans tighten review, both in the payer matrix

Nebraska adds an LBA or BCBA supervising at least 25% of a BCaBA's direct hours [6]. Michigan's criteria cover Blue Cross commercial, Medicare Plus Blue, BCN commercial and BCN Advantage [7].

PlanDateControl to change before the date
BCBS Nebraska I.178 [6]Nov 15, 2026Cap plans at 25 hours a week; 97153 telehealth to in-person; log BCaBA supervision at 25%
BCBS Michigan and BCN [7]Jan 1, 2027Rebuild continued-stay packets to the updated criteria for admissions, continued stays and discharge before the first 2027 reauthorization
The clocks

Days

Clocks, in days

Expedited decisionowed since Jan 1, 2026 [1]
3 days72 h; standard is 7 days
To the API
56 days8 weeks, 46.7%
NC certification grace[5]
120 daysends late November
0306090120 days
Payer decision clocksCountdownGrace period
ASP update
This month

New: the 2027 margin playbook and the Q4 rate tracker. Our ABA billing team is sending the six MCO questions for clients now.

30 minutes

Open a request-to-decision log today

Plan, code set, standard or expedited, date sent, date decided: by January you know which plans to hold to the clocks in writing.

Export the requests in flightBackfill sent dates.
Add two ledger columnsDecision date, denial reason text.
Review the log every FridayAnything past 72 hours or seven days is escalated in writing.
Use the templateFirst column of the ledger in the multi-location operating model; in the ABA RCM toolkit.
FAQ

Frequently asked questions

When must Medicaid MCOs have a prior authorization API for ABA?

January 1, 2027, under CMS-0057-F: covered services listed, documentation requirements identified, and each request answered with an approval and end date, a denial with a specific reason, or a request for more information. Drug prior authorizations are excluded.

What does Indiana BT2026162 require from October 29, 2026?

A complete FBA for each behavior targeted by a BIP in an ABA treatment plan: a function-based indirect assessment with graphed results, ABC data, triggers and precursors where applicable, and a hypothesized function statement, updated at each reauthorization.

What changes in BCBS Nebraska's ABA policy on November 15, 2026?

Policy I.178: treatment plans of no more than 25 hours a week, 97155 and 97156 the only services payable by telehealth, and an LBA or BCBA supervising at least 25% of a BCaBA's direct therapy hours.

Sources
  1. CMS fact sheet, CMS Interoperability and Prior Authorization Final Rule (CMS-0057-F), January 17, 2024
  2. CMS, Electronic Prior Authorization overview (page updated October 21, 2026)
  3. CMS, Interoperability and Prior Authorization Final Rule (CMS-0057-F) overview page
  4. Indiana IHCP bulletin BT2026162, IHCP requires functional behavior assessments for ABA therapy and behavior intervention plan (September 29, 2026)
  5. NC Medicaid bulletin, Updated reminder: requirements for Research-Based Behavioral Health Treatment service delivery (August 31, 2026)
  6. Blue Cross and Blue Shield of Nebraska, Medical Policy Update November 2026, Policy I.178 Autism Spectrum Disorders (effective November 15, 2026)
  7. Blue Cross Blue Shield of Michigan, The Record, October 2026: updated ABA utilization management criteria for dates of service on or after January 1, 2027

Checked October 27, 2026. Confirm against the source; proposed rules are marked proposed.

Related
ABA billing services ABA payer policy matrix by state ABA prior authorization API readiness 2027 The ABA Operator: year-end sweep ABA billing for multiple locations ABA RCM toolkit

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