Evidence record

Colorado Made at Least $77.8 Million in Improper Fee-for-Service Medicaid Payments for Applied Behavior Analysis Provided to Children

Jurisdiction
Colorado
Audit organization
Department of Health and Human Services Office of Inspector General Office of Audit Services
Publication date
February 2026
Source record
Original document linked
Open original reportOriginal source available

Findings

7

Recommendations

5

Overall conclusion

Colorado’s FFS Medicaid payments for Applied Behavior Analysis provided to children did not fully comply with Federal and State requirements, resulting in improper and potentially improper payments and highlighting a need for stronger governance, oversight, and guidance to prevent future noncompliance.

Scope

Audit covered Colorado's Health First Colorado, the State's Medicaid program, focusing on fee-for-service Medicaid payments for Applied Behavior Analysis (ABA) for calendar years 2022 and 2023. The audit analyzed $289.5 million ($158.2 million Federal share) across 1,057,164 claim lines and 60,131 enrollee-months, with service dates from January 1, 2022 through December 31, 2023 for enrollee-months with payments over $1,000.

Findings (7)

Each finding has a stable link.

  1. F-1224

    All 100 sampled enrollee-months included payments for one or more claim lines that were improper or potentially improper.

  2. F-1225

    Session notes or EVV records did not meet documentation requirements.

  3. F-1226

    ABA was provided by staff who did not have the appropriate credentials.

  4. F-1227

    ABA was provided to children without documentation of a comprehensive diagnostic evaluation or treatment referral for ABA.

  5. F-1228

    The State agency did not perform a statewide postpayment review of ABA payments and did not provide sufficient guidance to ABA facilities.

  6. F-1229

    Oversight of the prior authorization contractor was insufficient to ensure compliance with diagnostic evaluation and referral requirements.

  7. F-1230

    The audit estimated improper payments totaling at least $77.8 million ($42.6 million Federal share) and potentially improper payments totaling $207.4 million ($112.5 million Federal share).

Recommendations (5)

  1. R-1087

    Refund $42.6 million to the Federal Government.

    Related finding F-1230
  2. R-1088

    Provide additional guidance to ABA facilities for documenting and billing ABA.

    Related finding F-1228
  3. R-1089

    Periodically perform a statewide postpayment review of Medicaid ABA payments to educate providers on requirements.

    Related finding F-1228
  4. R-1090

    Strengthen oversight of the prior authorization contractor to ensure that prior authorizations are approved with documentation of required diagnostic evaluations and treatment referrals.

    Related finding F-1229
  5. R-1091

    Provide guidance on documentation, credentialing, EVV, and signature requirements; ensure facilities bill only for allowable ABA activities.

    Related finding F-1226