Wisconsin Made at Least $18.5 Million in Improper Fee-For-Service Medicaid Payments for Applied Behavior Analysis Provided to Children Diagnoses With Autism

Why OIG Did This Audit

• Early treatment for autism is important because proper care can reduce children’s difficulties while helping them build on their strengths and learn new skills. Although there are other treatments, applied behavior analysis (ABA) is a commonly used therapy for managing autism symptoms.
• Wisconsin’s fee-for-service (FFS) Medicaid payments for ABA in 2018 totaled $39.9 million, and by 2022, these payments had increased to $53.7 million.
• This audit examined whether Wisconsin’s FFS Medicaid payments for ABA for 2021 and 2022 complied with Federal and State requirements.

What OIG Found

Wisconsin’s payments for ABA did not fully comply with Federal and State requirements. All 100 sampled enrollee-months included payments for 1 or more claim lines that were improper or potentially improper.

What OIG Recommends

We made six recommendations to Wisconsin, including that it refund $12.2 million to the Federal Government, provide additional guidance to ABA facilities for documenting ABA, and periodically perform a statewide post payment review of Medicaid ABA payments to educate providers on requirements. The full recommendations are in the report.

Wisconsin partially concurred with our first recommendation, concurred with our remaining recommendations, and detailed steps it plans to address our recommendations.