If your child receives ABA through Virginia Medicaid, you have probably heard that therapy is being capped at 20 hours a week. Here is where things stand in September 2026: the Virginia Medicaid ABA therapy changes are written into the state budget, but they are not in effect yet. The Department of Medical Assistance Services (DMAS) is still waiting on federal approval, and the current authorization process has not changed.
A mother in Virginia Beach asked me last month, “Should I cut his hours now so it hurts less later?” My answer was no. Preparation helps far more than worry, and families can do a lot today to protect their child’s care.
Below, I break down what the policy says, who it affects, how children can still receive more than 20 hours when they need them, and how to make every therapy hour as productive as possible.
What the July 2026 DMAS Bulletin Says
On July 28, 2026, DMAS released a provider bulletin explaining changes required by Item 291.WW.2 of the 2026 Appropriation Act. They apply to children who receive ABA through Cardinal Care, Virginia’s Medicaid program, and they fall into three areas.
A 20-Hour Weekly Limit on ABA Services
The budget sets a cumulative limit of 20 hours per week, per child, on ABA services. DMAS has not yet published the manual guidance defining how hours across billing codes will be counted, so some details are still pending.
The limit can be exceeded when medical necessity is documented under EPSDT, a federal protection for Medicaid members under age 21. For families, that exception is the most important part of the policy.
An Autism Diagnosis Before Authorization
DMAS will also require an autism spectrum disorder (ASD) diagnosis before authorizing ABA. Children age 5 and younger may qualify with a provisional diagnosis for one year, using a protocol DMAS will designate.
For toddlers stuck on long evaluation waitlists, that provisional pathway can keep early intervention moving. Families using it should still schedule a full diagnostic evaluation well before the one-year window closes.
More Oversight of ABA Documentation
The budget directs DMAS to give providers guidance on required documentation and to work with managed care organizations on periodic reviews of ABA payments, both before and after claims are paid. DMAS will also collect standardized reporting from each health plan.
For parents, this likely means your provider may ask for signatures, schedules, and caregiver training records more consistently. Those requests protect your child’s authorization, so it helps to respond quickly.
Is the 20-Hour ABA Limit in Effect Yet?
Not yet. Although the budget language names July 1, 2026, DMAS states that the effective date will come in a later notice, after the Centers for Medicare and Medicaid Services (CMS) approves the change and the Mental Health Services Manual is updated. Until then, existing authorizations follow the current process.
Some websites describe the cap as active, so rely on DMAS notices. Several related rules are already in place, and they show where things are heading:
- Code-level requests. Since October 15, 2025, providers must request units for each ABA billing code rather than one bundled request.
- Extra justification above 20 hours. Since December 2025, any request above 20 hours (80 units) per week must include the session schedule and a description of how those activities support the treatment plan.
- Required family training. DMAS already requires family training as part of ABA services.
- Telehealth documentation. Providers must document that a child and caregiver can participate safely and meaningfully before delivering ABA by telemedicine.
In other words, the 20-hour mark has been a documentation checkpoint for most of a year. The new law turns it into a formal limit with an EPSDT exception.
Who the Virginia Medicaid ABA Changes Affect
The changes apply to ABA funded by Virginia Medicaid and FAMIS, whether your child is enrolled through Aetna Better Health, Anthem HealthKeepers Plus, Humana Healthy Horizons, Sentara Community Plan, UnitedHealthcare, or fee-for-service Medicaid. A few situations work differently.
Children Receiving Behavior Services Through School Divisions
The limit does not apply to behavior therapy provided by local education agencies and billed through Medicaid’s school-based services program. Private ABA delivered in a classroom and billed through your child’s health plan is a separate arrangement, so ask your provider how those hours are billed.
Families With Private Insurance
Commercial plans follow their own coverage rules and are not governed by this budget item. If your child has both private insurance and Medicaid, ask your provider which plan pays first and how the Medicaid portion of care could be affected once the limit takes effect.
How EPSDT Protects Children Who Need More Than 20 Hours
The EPSDT benefit requires states to cover medically necessary services that correct or ameliorate a child’s health condition. Because Virginia’s budget language includes it, a child whose assessment supports 25 or 30 hours still has a path to that care.
I think of the 20-hour line as a documentation threshold. Above it, the clinical case has to be made clearly and backed by data.
What Strong Medical Necessity Documentation Includes
When I write a request above 20 hours, a reviewer should be able to see the reason behind every hour. That usually includes:
- Standardized assessment results and baseline data showing needs across several developmental areas
- Measurable goals tied to safety, communication, and daily living skills
- A weekly schedule showing how each block of time targets those goals
- Progress data from earlier authorization periods, including what happened when hours were lower
- A caregiver training plan showing how skills will carry over outside sessions
Last year, I supported a four-year-old near Petersburg who often ran toward busy roads. His request above 20 hours was approved because the data tied each hour to specific safety goals and showed how progress would be measured.
Focused Versus Comprehensive ABA
Professional practice guidelines generally describe two treatment models. Focused ABA targets a smaller set of goals and often falls around 10 to 25 hours a week. Comprehensive ABA addresses needs across many areas, such as communication, play, self-care, and safety, and often ranges from 30 to 40 hours a week.
Many children already receive 20 hours or fewer, and they make real progress. Our post on ABA therapy hours explains how BCBAs match hours to need, and our overview of full-time ABA covers when 30 or more hours may fit.
Making Every ABA Hour Count
Whether your child ends up at 12 hours or 30, the quality of each session shapes progress as much as the total. These are the strategies I lean on most when hours are limited.
Caregiver Training That Extends Progress
A child spends far more waking hours with family than with any therapist. When parents learn to prompt a request at snack time or practice a calm-down routine before bath, learning continues all week.
In my experience, families who practice one or two strategies consistently between sessions often see skills generalize faster than families who rely on therapy time alone.
Coordinating Home and School Goals
One family I work with in Harrisonburg had a daughter who used a picture system at home but not at school. Once her BCBA and teacher agreed on the same communication targets and prompting, she started using it in both places within a few weeks.
Shared goals mean your child practices the same skills in more settings without adding therapy hours.
Prioritizing High-Impact Goals
When hours are limited, we put safety, functional communication, and daily living skills first, since progress in those areas often reduces frustration and challenging behavior across the day. Our piece on ABA goals explains how we choose targets that reflect your family’s priorities.
Virginia Medicaid ABA Therapy Changes: Steps Families Can Take Now
New rules feel less stressful when your paperwork is ready ahead of time. Here is what I recommend to every Medicaid family I work with:
- Keep the full diagnostic report on file. A documented ASD diagnosis will be required, so a complete evaluation is more useful than a referral note.
- Ask your BCBA about your current plan. Learn how many hours your child receives and how they are divided across services.
- Note your reauthorization dates. Renewals are when hour changes are most likely to appear.
- Stay active in caregiver training. DMAS requires family training, and it helps skills carry over between sessions.
- Keep your contact information current. Missed mail can mean missed appeal deadlines.
- Let data guide hour changes. Reducing hours ahead of the rule can slow progress without any benefit.
If the policy has you thinking about switching ABA providers, it helps to know what transfers between agencies before making a move.
What to Do If ABA Hours Are Denied or Reduced
If your child’s health plan denies, reduces, or ends ABA services, you will receive a written notice. Virginia families have the right to appeal a denial, and acting quickly protects your options.
Appeal Steps for Cardinal Care Families
- Read the notice carefully. It lists the reason for the decision and your deadlines.
- Ask about continuing services. If hours are being reduced or stopped, filing quickly, generally before the change takes effect or within 10 days of the notice, may allow services to continue during the appeal. Not every case qualifies, so read your notice closely.
- File an internal appeal with your health plan. Your BCBA can supply updated data and a letter explaining medical necessity.
- Request a state fair hearing if needed. After the health plan’s decision, you can appeal to DMAS, generally within 120 days.
Free legal help is also available through organizations such as the Virginia Poverty Law Center, which publishes a guide to Medicaid service appeals.
How Little Champs ABA Supports Virginia Families
At Little Champs ABA, we accept Virginia Medicaid and manage authorizations and documentation so parents can focus on their child. Our Virginia ABA therapy team follows DMAS updates and explains any change in plain language before it touches your schedule.
Care is available in the places your child spends the day:
Our Virginia office is in the Richmond area, and we support families from Fredericksburg to Norfolk. We also serve communities west of the Blue Ridge and beyond, including Staunton, Lynchburg, and Blacksburg.
If your child’s authorization is coming up for renewal, or you want a second opinion on whether current hours fit your child’s needs, contact our team for a free consultation.
Staying Steady Through the 2026 Changes
With about 1 in 31 eight-year-olds identified with autism nationally, according to the CDC, these decisions affect many Virginia families. The Virginia Medicaid ABA therapy changes are real, but they are not yet in effect, and EPSDT keeps a path open to medically necessary care.
Families who handle transitions well keep records organized, stay close to their BCBA, and let progress data guide decisions about hours. You do not have to track every bulletin alone. Reach out to us, and we will help you understand what these updates mean for your child.
Frequently Asked Questions About the Virginia Medicaid ABA Limit
Will my child’s ABA hours drop to 20 on a set date?
Not at this point. DMAS will announce an effective date after CMS approval. Until then, authorizations follow the existing process.
Can my child still receive more than 20 hours a week?
Yes, when medical necessity is documented. The budget language allows the limit to be exceeded under EPSDT for Medicaid members under 21.
Does my child need a new autism evaluation?
DMAS has not asked families to repeat evaluations. The rule requires a documented ASD diagnosis before authorization, and children 5 and younger may use a one-year provisional diagnosis. Your provider can confirm your records meet the standard.
Does the limit apply to ABA at school?
It does not apply to behavior therapy billed by local school divisions through Medicaid’s school-based services program.
Does the 20-hour limit include caregiver training?
DMAS describes the limit as cumulative across ABA services, but the manual guidance explaining how each billing code counts has not been published yet. Your provider should review the details with you once it is released.
Does the limit affect teenagers?
Yes. It applies to Medicaid members receiving ABA regardless of age, and EPSDT protections continue until age 21.
What if my child’s hours are denied or reduced?
Note the deadline on the notice and contact your BCBA right away. Families can appeal through their Cardinal Care health plan and then request a state fair hearing through DMAS.
Sources:
- Centers for Medicare & Medicaid Services. (n.d.). Early and periodic screening, diagnostic, and treatment. https://www.medicaid.gov/medicaid/benefits/early-and-periodic-screening-diagnostic-and-treatment/index.html
- Cover Virginia. (n.d.). Your right to appeal. https://coverva.dmas.virginia.gov/learn/appeals
- Virginia Association for Behavior Analysis. (2026). Budget Item 291 update. https://virginiaaba.org/budget-item-291-update/
- Virginia Department of Medical Assistance Services. (2025). Applied behavior analysis (ABA) policy and regulatory clarifications. https://vamedicaid.dmas.virginia.gov/bulletin/applied-behavior-analysis-aba-policy-and-regulatory-clarifications
- Virginia Department of Medical Assistance Services. (2025). Service authorization update for applied behavior analysis (ABA) effective October 15, 2025. https://vamedicaid.dmas.virginia.gov/bulletin/service-authorization-update-applied-behavior-analysis-aba-effective-october-15-2025
- Virginia Department of Medical Assistance Services. (2026). Applied behavior analysis (ABA) policy changes. https://vamedicaid.dmas.virginia.gov/bulletin/applied-behavior-analysis-aba-policy-changes
- Virginia Department of Medical Assistance Services. (n.d.). Applicant/member appeals resources. https://dmas.virginia.gov/appeals/applicant-member-appeals-resources/
- Virginia Poverty Law Center. (2021). A guide to Medicaid appeals in Virginia: Medical service denials, terminations and reductions. https://www.vplc.org/content/uploads/2025/12/Medicaid-Guide_6_14_Final.pdf