Michigan Medicaid ABA requirements changed on October 1, 2026, when MDHHS issued bulletin MMP 26-18. A child no longer needs a physical examination before starting behavioral health treatment for autism. A diagnostic re-evaluation is no longer required unless a practitioner finds it medically necessary or the family asks. In return, every treatment plan sent to the PIHP for prior authorization must measure each goal with a standardised tool such as the VB-MAPP or ABLLS-R, progress must be reported at least every six months, and discharge cannot follow a fixed timeline. For a Michigan ABA practice, that means fewer forms at the door and more measurement in the file.
In short
- MMP 26-18 was issued October 1, 2026 to Michigan's CMHSPs and PIHPs, effective "As Indicated" (MDHHS, 2026).
- Eligibility covers Medicaid beneficiaries under 21 with autism "all levels of severity" (MDHHS, 2026).
- Interim progress assessments go to the PIHP at least every six months; parents hear progress every three to six months (MDHHS, 2026).
- About 1 in 31 eight-year-olds has been identified with autism, per CDC's 2022 surveillance data (CDC, 2025).
What MMP 26-18 changes
The bulletin rewrites the Behavioral Health Treatment Services/Applied Behavior Analysis section of the Medicaid Provider Manual. In its own words, the updates include "removing the requirement that a child has to receive a physical examination prior to accessing BHT services, updating diagnostic re-evaluation language, and clarifying applied behavior analysis (ABA) standards to align with generally accepted standards of care."
It also writes Michigan law into the manual. Behavior analyst licensure comes from Public Act 403 of 2016. The re-evaluation rule comes from Public Act 111 of 2021, now MCL 400.109n, which says a child with a confirmed diagnosis from a qualified licensed practitioner "is not required to have a re-evaluation to determine continued eligibility for behavioral health treatment unless a re-evaluation is medically necessary."
The bulletin is addressed to the PIHPs and CMHSPs, not to practices. A practice feels it through its PIHP: the prior authorization packet, the progress reports the PIHP asks for, and its review of discharge. Expect your PIHP's forms and contract language to follow.
| Area | What MMP 26-18 says |
|---|---|
| Physical exam | No longer required before BHT services |
| Re-evaluation | Not required unless medically necessary or requested by the family or guardian |
| Screening | "No prior authorization is required for screening." |
| Treatment plan | Each goal measured "using a standardized measurement system that may include" VB-MAPP or ABLLS-R |
| Progress reports | To the PIHP "at least every six months"; more often if the PIHP requires |
| Parents | LBA reports progress "minimally every three to six months" |
| Discharge | Gradual step-down; "cannot be based on a set timeline" |
How a Michigan ABA practice should respond
- Stop asking for the physical exam as a condition of starting. Check your intake packet, your website and the script your front desk uses. A family who was told to book a physical first can now be scheduled for the behavioral assessment.
- Stop scheduling routine re-diagnosis. Re-evaluation now happens when "determined medically necessary by a physician, other qualified licensed practitioner or when requested by the beneficiary's family or legal guardian." If a PIHP or payer asks for one outside those cases, cite the bulletin and MCL 400.109n.
- Measure every goal with a standardised tool. The plan sent for prior authorization must use a standardised measurement system for each goal, give "an anticipated timeline and treatment hours needed to achieve each goal," and document that services will be delivered by a provider "licensed to provide ABA services in Michigan."
- Put the six-month progress dates on a calendar per child. The PIHP "shall require" an interim progress assessment at least every six months, measured the same way as the plan. The PIHP may ask for it more often "when warranted by individual circumstances."
- Schedule parent progress updates. The licensed behavior analyst is responsible for "communicating progress on goals to parents/legal guardians minimally every three to six months." Record each one.
- Rewrite any discharge policy that uses a fixed term. Discharge "should generally involve a gradual step-down in services and cannot be based on a set timeline (e.g., one year, three years, etc.)." And: "Treatment should not be denied or withheld based on caregiver availability."
- Check every clinician's licence is on file. The provider list is BCBA/LBA or BCBA-D/LBA, BCaBA/LABA under an LBA, licensed psychologists meeting the bulletin's ABA training test, and RBTs or BTs supervised by an LBA or LABA.
The mistake most practices will make at step 4
They will treat the six-month progress report as a form to fill in when the PIHP chases it. The bulletin ties the progress report to the same standardised measures as the plan and the same anticipated timelines. A report that cannot show movement against the baseline measure is hard to defend, and the discharge criteria include a child who "has not demonstrated measurable improvement and progress toward goals as documented by the LBA." Measure on schedule, from the first plan, so the six-month report writes itself from data you already have.
Why the change is overdue
CDC's Autism and Developmental Disabilities Monitoring Network estimates that "About 1 in 31 (3.2%) children aged 8 years has been identified with ASD," based on 2022 surveillance data. The physical exam and the routine re-diagnosis were steps between a family and treatment that did not change the diagnosis. The bulletin says its language is consistent with recommendations from the Behavior Analyst Certification Board, the Association of Professional Behavior Analysts, Autism Speaks and the Council of Autism Service Providers.
Medicaid eligibility itself keeps moving this year; our guide to Medicaid changes for non-citizens covers the October 1 checks for another group of Michigan patients.
Where we fit
For Michigan healthcare practices we build the front desk around what this bulletin asks for: intake forms sent by text and completed on a phone, with the answers landing in the chart, and appointment confirmations by text at the intervals you choose, so a family starting treatment is not lost between the referral and the first session.
The bulletin takes two hurdles away from families. The measurement it asks for in return is the practice's to keep.
