Wisconsin Medicaid Payments for Applied Behavior Analysis Audit

This technical report presents the findings of an audit conducted by the Office of Inspector General (OIG) regarding Wisconsin's fee-for-service (FFS) Medicaid payments for applied behavior analysis (ABA) provided to children diagnosed with autism during the years 2021 and 2022. The audit aimed to determine compliance with Federal and State requirements. It was found that all sampled enrollee-months included payments for one or more claim lines that were improper or potentially improper, totaling at least $18.5 million in improper payments. The report outlines six recommendations for Wisconsin, including a refund of $12.2 million to the Federal Government and improved guidance for ABA facilities on documentation practices. Wisconsin's response to the recommendations is also documented, indicating partial concurrence with the first recommendation and agreement with the others. The report emphasizes the importance of adhering to established guidelines to ensure proper use of Medicaid funds.