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FOR IMMEDIATE RELEASE Idaho Providers Warn of Equity Risks in Medicaid Shift from ABA to CHIS Behavioral Intervention; Seek Written Clarification from IDHW

Boise, Idaho — 11/11/2025 — Sunderlin Behavioral, an Idaho provider of autism services, is calling on the Idaho Department of Health & Welfare (IDHW) to issue written clarification on how children covered by Medicaid will continue to access clinically supervised, evidence-based Applied Behavior Analysis (ABA) following a December 1, 2025 transition announced by Magellan Behavioral Health.

On October 31, 2025, Magellan notified providers that Behavior Modification & Consultation (BMC) services billed under the Idaho Behavioral Health Plan will transition to “Behavioral Intervention (BI)” under Children’s Habilitation Intervention Services (CHIS), which is reimbursed through Idaho Medicaid fee-for-service. On November 5, 2025, IDHW acknowledged provider questions and shared a CHIS FAQ and CHIS fee schedule (DD/Children’s tab) while indicating it was still “working to find the answer” on code comparability/mapping from ABA CPT codes to CHIS codes and modifiers.

“We’re asking for basic, written details: the full code mapping, whether BCBA supervision remains billable, and how the state will maintain EPSDT and parity protections,” said Yrenka Sunderlin, M.S., BCBA, LBA, Executive Director of Sunderlin Behavioral. “Without that, providers cannot ethically or legally plan care, and families risk gaps in medically necessary treatment.”

What’s confirmed to date

  • Transition notice: Magellan’s 10/31/25 communication states BMC services will no longer be billed via Magellan after December 1, 2025 and will move under CHIS “Behavioral Intervention.”

  • IDHW response (11/5/25): The Department provided a CHIS FAQ and CHIS fee schedule, referenced Qualitrac/Telligen processes, and noted it is still compiling answers on CPT↔H-code comparability.

  • Materials received to date (FAQ + fee schedule) reference habilitation-based H-codes (e.g., H0004, H2015, H0032, T1005) rather than the CPT 97-series ABA codes (97151–97158). No official CPT crosswalk has been provided yet.

  • Operational timing: Providers were given <30 days between notice and the December 1 effective date to reconfigure authorizations, documentation, and billing.

Why providers are concerned

  • Clinical oversight & ethics: ABA—as outlined by the Behavior Analyst Certification Board (BACB)—requires BCBA supervision, data-driven treatment design, and ongoing analysis. Materials provided to date describe habilitation BI without explicit preservation of BCBA supervised treatment or CPT coding—creating potential ethical and licensure conflicts for BCBAs.

  • Parity & EPSDT: Reclassifying ABA into habilitation and away from CPT-coded, medically necessary treatment risks a two-tiered system: families with private insurance retain CPT-coded, clinically supervised ABA; families with Medicaid may be limited to habilitation services without equivalent clinical safeguards. Providers have asked IDHW to explain how parity and EPSDT will be maintained.

  • Continuity of care: With no published code mapping and authorization guidance, providers cannot assure uninterrupted services or meet Medicaid notice requirements to families.


Sunderlin Behavioral’s formal requests to IDHW

In written correspondence (most recently reaffirmed for Wednesday, November 12, 2025 at 10:00 AM), Sunderlin Behavioral has requested:

  1. Full code mapping (CPT 97151–97158 to CHIS BI codes/modifiers) and corresponding rates.

  2. Written confirmation of whether BCBA supervision and treatment design will remain billable and recognized within CHIS.

  3. A statement explaining how EPSDT/MHPAEA parity and equitable access for Medicaid-insured children will be preserved.

  4. An implementation plan to resolve the 30-day/60-day compliance conflict and support continuity of care for families.

“This isn’t about opposing reform—it’s about ensuring equitable, clinically supervised care for children who rely on Medicaid,” Sunderlin added. “Families deserve clarity. Providers deserve a clear, ethical path to deliver it.”

If written clarification is not provided by the requested time, Sunderlin Behavioral will transmit its correspondence and the state-provided materials (CHIS FAQ and fee schedule) to the Autism Legal Resource Center and other appropriate oversight entities for review.


About Sunderlin Behavioral

Sunderlin Behavioral is a BCBA-led organization serving Boise-area children and families. The company provides autism services and operates Sunderlin’s Learning Center, a small-group, developmental and ABA-informed program for ages 2–6. Sunderlin Behavioral is an approved Idaho Empowering Parents/ClassWallet vendor.


Media Contact: Sunderlin Behavioral, LLC

Phone: (208) 297-1405


Background documents available upon request:

  • Magellan notice re: BMC → BI (Oct 31, 2025)

  • IDHW email acknowledging code comparability under review and providing CHIS FAQ + Fee Schedule (Nov 5, 2025)

  • Provider correspondence requesting written clarification (Active through Nov 12, 2025)

 
 
 

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