ABA Policy Update

Cynthia Macluskie • May 14, 2026

Arizona Health Care Cost Containment System recently updated the ABA policy, and it is now open for public comment. There are many positive improvements within the proposal, including stronger fingerprinting, criminal background check, and abuse registry requirements for certain ABA providers.


However, I do not believe the proposed protections go far enough. Children and vulnerable adults receiving ABA services often interact with many individuals throughout the day beyond credentialed clinical staff. Front office personnel, float staff, transportation staff, aides, interns, volunteers, and others may all have access to vulnerable members.


Safety standards should not depend on a billing code or job title. They should depend on access to a vulnerable person. Any individual who may supervise, transport, escort, monitor, or otherwise interact with a vulnerable member should be required to complete fingerprinting, criminal background checks, and abuse registry screening before member contact occurs.


In addition, providers serving vulnerable populations through Arizona Department of Economic Security Division of Developmental Disabilities, AHCCCS, and contracted health plans should all be held to the same strict safety standards.


Protecting vulnerable children and adults should always be the priority. If you wish to learn more please use the link below:

https://scs-public.s3-us-gov-west-1.amazonaws.com/env_production/oid347/did200055/pid_214247/project-documents/AMPM%20POLICY%20320-S.pdf


If you would like to comment on the policy use the link below:

https://ahcccs.commentinput.com/?id=8e7uZSx2hH



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