Does Arizona's proposed ABA rule cap weekly therapy hours?

No hard cap is set in the proposal. A prior authorization request for more than 25 hours a week of direct ABA, or more than 15 hours a week outside school for a full-time student, must add justification of medical necessity, specific goals, step-down goals, and plans for caregiver training and supervision by a licensed behavior analyst.

How long can an AHCCCS ABA authorization last under the proposed rule?

Health plans could authorize ABA for no more than six months at a time. Each request needs an assessment and treatment plan dated within 30 days, services must begin within 30 days of approval, and a licensed behavior analyst must reassess the member at least every six months.

Arizona ABA rules aim to save AHCCCS $46.5M a year

Arizona's Medicaid agency projects $46.5 million a year in savings from proposed ABA rules, mostly in its developmental disabilities program. The rules add six-month authorizations and extra justification above 25 hours a week.

Direct Support News desk · October 22, 2026 · Updated October 23, 2026 · 3 min read

Arizona's Medicaid agency, AHCCCS, has proposed rules for applied behavior analysis (ABA) that it estimates would save about $46.5 million a year in total funds. The rules would add six-month limits on authorizations, extra paperwork for more than 25 hours a week of therapy, and new supervision and screening requirements. The Notice of Proposed Exempt Rulemaking was posted Sept. 17, 2026. Public comments closed Oct. 17, and Breaking News ABA reported Oct. 22 that no final rule had been posted as of Oct. 20.

Where the savings come from

Population	Estimated annual savings (total funds)
ALTCS developmentally disabled members (served through DDD)	About $28.7 million
AHCCCS Complete Care, KidsCare and Children's Health Plan	About $17.8 million
Total	About $46.5 million

The notice gives these totals but doesn't say which provisions produce the savings. More than 60% of the estimate comes from members of the Arizona Long Term Care System (ALTCS) who have developmental disabilities, the group served by the state's Division of Developmental Disabilities.

What the proposed rules would require

Shorter authorizations. Health plans could approve ABA for no more than six months at a time. A request must include an assessment and treatment plan dated within 30 days, and services must start within 30 days of approval.
More justification above 25 hours. A request for more than 25 hours a week of direct ABA, or more than 15 hours a week outside school for a full-time student, must explain why the extra hours are medically necessary. It must also list specific goals, set goals for stepping down to less care, and include plans for caregiver training and supervision.
School deferral. If a child who is 5 or older skips school to receive ABA, the behavior analyst must document what keeps the child from school, how ABA addresses it, and the milestones for returning. A parent or caregiver must sign informed consent.
Supervision ratio. A licensed behavior analyst (LBA) must provide at least one hour of case supervision for every ten hours of direct ABA delivered by technicians and other supervisees.
Assessment limits. An LBA reassesses each member at least every six months, and an assessment can't exceed 12 hours unless more time is documented as necessary.
Diagnostic evaluations. Members getting ABA without a comprehensive diagnostic evaluation must have one by Nov. 1, 2027, or within 12 months of enrolling, whichever is later. Services can't be cut only because the evaluation is still pending, if the member is scheduled or on a waiting list.
Background and registry checks. Provider organizations must bar supervisees with certain criminal convictions or substantiated abuse or neglect findings, and staff must report new charges or allegations right away. Organizations that haven't finished screening current staff by Nov. 1, 2026 get a 180-day grace period.

The rules also set credential deadlines for ABA technicians.

How the process works

AHCCCS is using an exemption in state law (Laws 2026, Chapter 132, Section 19) that lets it skip the usual Administrative Procedure Act steps. Under the exemption, there was a 30-day comment window and no public hearing. The notice doesn't give an effective date. Arizona's Division of Developmental Disabilities is running separate rule work on member rights, with input due Nov. 5.

What this means for providers and DSPs

DDD members carry most of the savings. Families and support coordinators for children in the DDD program should watch for shorter authorization periods and requests for more documentation when renewals come up.
Paperwork grows above 25 hours a week. The rule doesn't set a hard cap, but high-intensity plans will need more written justification, step-down goals, and caregiver training and supervision plans. Agencies that coordinate ABA with other in-home supports may see schedules shift if hours are reduced.
Screening rules reach frontline staff. ABA supervisees would be checked against Arizona's Adult Protective Services registry and child abuse records, and would have to report new charges or allegations right away. Agencies with ABA staff should confirm that their screening and reporting policies match.
Arizona is part of a wider trend. Medicaid programs and health plans are tightening ABA spending in several states, including Georgia's 30% foster-care rate cut, Florida's lower ABA forecast and North Carolina's limits on concurrent billing.
Watch for the final rule. AHCCCS posts final rules on its proposed and final state rules page. The final text may differ from the proposal.