On July 7, the Centers for Medicare and Medicaid Services (CMS) issued an informational bulletin which clarifies the coverage available for services for children with autism. The bulletin notes that there are courses of treatment beyond Applied Behavioral Analysis (ABA) and lists the authorities that may be used by states to reimburse an array of services, including state plans, HCBS waivers, and section 1115 demonstrations. It outlines other licensed practitioner services, preventative services, therapy services, and 1915(i) HCBS benefits which states may include in their state plan options to cover autism services. It then outlines 1915(c) HCBS waivers and 1115 research and demonstration waivers, which, unlike state plans, may be limited in the population served, allowing states more flexibility to target service delivery to certain populations.
The bulletin notes that in states that currently provide waiver services to individuals under age 21 to address autism spectrum disorders, the ability to provide services under a 1905(a) state plan may have the effect of making those individuals ineligible for the waiver unless another waiver service is available. The bulletin urges states to ensure that individuals who are not coverable under a section 1905(a) state plan receive another waiver service when they age out. The bulletin concludes by offering technical assistance to states whose programs will be impacted by the clarification.