Texas - Autism Service — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-09-10
The Texas Department of Licensing and Regulation (TDLR) issues the Licensed Behavior Analyst (LBA) credential required to deliver Applied Behavior Analysis (ABA) under Texas Medicaid Autism Services. Texas Medicaid strictly prohibits autism agencies, clinics, or employers from enrolling as the billing entity for ABA services; only the individual LBA may enroll through the Provider Enrollment and Management System (PEMS) and must use their individual National Provider Identifier (NPI) as both the rendering and billing provider on all claims.
To become an approved provider, an LBA must secure an active, unrestricted TDLR license, obtain an NPI with taxonomy code 103K00000X, and complete Texas Medicaid & Healthcare Partnership (TMHP) enrollment, which requires an on-site visit for clinic-based providers. Following state enrollment, the LBA must independently credential and contract with regional Managed Care Organizations (MCOs) to receive reimbursement for services delivered to Medicaid members age 20 or younger with an autism spectrum disorder diagnosis.
1. Service Definition and Scope
Texas Medicaid Autism Services provides Applied Behavior Analysis (ABA) evaluation and treatment to Medicaid members age 20 or younger who have a diagnosis of autism spectrum disorder (ASD). Services are designed to encourage positive, adaptive behaviors and apply skills across everyday settings to improve health, safety, and independence.
ABA services can be delivered in the home, community, or in a clinic by an LBA. The LBA works with the child and family to create a treatment plan and may coordinate with other therapists and providers to ensure a team approach to treatment.
- Target Population: Medicaid members age 20 or younger with an ASD diagnosis.
- Covered Services: ABA assessment/evaluation (procedure code 97151) and treatment services.
- Service Settings: Client homes, community locations, or designated clinic office spaces.
- Care Coordination: LBAs may coordinate with the child's other therapists and providers up to twice a year.
- Telehealth: Permitted when the LBA uses professional judgment to determine remote delivery is clinically appropriate and effective.
2. Regulatory and Oversight Agencies
The Texas Health and Human Services Commission (HHSC) administers the Medicaid program and sets policy for Autism Services. The Texas Department of Licensing and Regulation (TDLR) handles the professional licensure of behavior analysts.
The Texas Medicaid & Healthcare Partnership (TMHP) manages provider enrollment, conducts site visits, and processes claims on behalf of HHSC.
- Texas Health and Human Services Commission (HHSC): Sets Medicaid ABA policy and oversees MCOs (https://www.hhs.texas.gov/).
- Texas Department of Licensing and Regulation (TDLR): Issues and regulates LBA licenses (https://www.tdlr.texas.gov/).
- Texas Medicaid & Healthcare Partnership (TMHP): Processes Medicaid enrollment applications and manages the PEMS portal (https://www.tmhp.com/).
- Provider Enrollment and Management System (PEMS): The official portal for submitting Medicaid enrollment and revalidation applications (https://www.tmhp.com/topics/provider-enrollment).
3. Gatekeeping Prerequisites: Who Can Even Apply
Texas Medicaid strictly limits ABA provider enrollment to individual Licensed Behavior Analysts (LBAs). There is no facility, agency, or group practice enrollment category for ABA services in Texas Medicaid.
An LBA's employer NPI cannot be designated as the rendering or billing provider for reimbursement. Texas does not require a Certificate of Need or Facility Need Review for ABA providers, but the individual enrollment mandate serves as an absolute structural gate for corporate entities attempting to bill directly.
- Individual Enrollment Mandate: Only individual LBAs may enroll as billing and rendering providers for ABA services.
- Agency Exclusion: No other professional or entity (including autism clinics or agencies) may enroll as a provider of ABA assessment and treatment.
- License Expiration Window: LBAs within 30 days of their TDLR license expiration are blocked from enrolling in Texas Medicaid.
- MCO Contracting: While TMHP enrollment is open year-round, actual service delivery and reimbursement require subsequent credentialing and contracting with regional Medicaid Managed Care Organizations (MCOs).
- Need-Review/CON: Texas does not require a Certificate of Need or Facility Need Review for ABA providers.
4. Licensure and Certification Requirements
Providers must hold a current, active, and unrestricted LBA license from TDLR. Board Certified Behavior Analysts (BCBAs) and BCBA-Ds must obtain this state license to be eligible to enroll, provide services, and supervise technicians.
Subordinate staff cannot enroll in Medicaid but must hold specific national certifications to deliver authorized treatment under the direct supervision of the enrolled LBA.
- Primary License: Licensed Behavior Analyst (LBA) issued by TDLR.
- National Certification: BCBA or BCBA-D certification is a prerequisite for TDLR licensure.
- Out-of-State Providers: May provide services if they hold a TDLR license and meet all Texas Medicaid policy requirements, including telehealth rules.
- Technician Certifications: Behavior Technicians (BTs) must hold active Registered Behavior Technician (RBT), Board Certified Autism Technician (BCAT), or Applied Behavior Analysis Technician (ABAT) certification.
5. Medicaid Provider Enrollment
Enrollment is conducted entirely online through the TMHP Provider Enrollment and Management System (PEMS). Applicants must apply as individual professionals using their specific taxonomy code.
Providers must submit specific attestations regarding their practice locations, which dictates whether they are subject to pre-enrollment site visits.
- Enrollment Portal: TMHP Provider Enrollment and Management System (PEMS).
- Required NPI: Must obtain an individual Type 1 NPI from CMS.
- Taxonomy Code: Must use 103K00000X for the NPI and Medicaid enrollment.
- Location Attestation: Must submit the Licensed Behavior Analyst (LBA) Attestation Form Regarding Location and Services.
- Physical Address Rule: Clinic-based providers must list the physical office; home/community-based providers must list the location where client records are kept (e.g., home address).
6. Staffing, Training and Background Checks
The enrolled LBA serves as the rendering professional for all ABA services and is responsible for the supervision of subordinate staff. Subordinate staff cannot enroll in Medicaid directly but must meet specific certification standards to deliver care.
Background checks are conducted during the TDLR licensure process and the TMHP Medicaid enrollment screening.
- LBA Role: Acts as the rendering and billing provider and must directly supervise all technicians.
- Technician Qualifications: BTs must be RBTs, BCATs, or ABATs.
- Background Checks: Required as part of the TDLR licensure process and TMHP Medicaid enrollment screening.
- Supervision Standards: LBAs must adhere to BACB and TDLR supervision ratios and documentation requirements for all LaBAs and BTs.
7. Documentation, Policies and Records
Enrolled LBAs are strictly responsible for all Medicaid activities, including accurate billing, timely form submission, and maintaining comprehensive client records. Records must be stored securely at the physical address registered in PEMS.
Providers must utilize specific state forms for prior authorization and claims submission.
- Treatment Plan: LBAs must create a comprehensive treatment plan in collaboration with the child and family.
- Prior Authorization: Must submit the CCP Prior Authorization Request Form for ABA services.
- Form Types: LBAs must only use and submit professional claim forms; institutional forms will be rejected.
- Record Retention: Client files and records must be kept at the physical address updated in the PEMS system.
- Temporary Spaces: Conference rooms occasionally used for visits but not leased as office space cannot be used as the official record storage address.
8. Billing, Rates and Claims
Claims are submitted to the respective MCO or TMHP using professional claim formats. The LBA's individual NPI must appear as both the billing and rendering provider.
Specific modifiers must be used to indicate when services were delivered by subordinate staff under the LBA's supervision.
- Billing Provider: The individual LBA's NPI must be used; employer NPIs will cause claim rejection.
- Assessment Code: 97151 is used for ABA assessment/evaluation.
- Modifiers: The LBA must append appropriate modifiers to designate which services were provided by Licensed Assistant Behavior Analysts (LaBAs) or BTs.
- Claim Format: Professional claims only; institutional claims are explicitly prohibited.
- Reimbursement: Rates are established by HHSC and administered through contracted MCOs based on the specific procedure code and modifier combination.
9. Approval Sequence and Timeline
The approval process begins with obtaining national certification and state licensure, followed by Medicaid enrollment and MCO credentialing. TMHP conducts specific screening steps, including potential site visits, before approving the PEMS application.
Once TMHP enrollment is complete, the provider must independently contact MCOs to join their networks.
- Step 1: Obtain BCBA certification and TDLR LBA license.
- Step 2: Secure an individual NPI with taxonomy 103K00000X.
- Step 3: Submit the Medicaid enrollment application via TMHP PEMS.
- Step 4: Complete a TMHP on-site visit prior to enrollment if operating a designated clinic location.
- Step 5: Contract and credential with individual Texas Medicaid MCOs (e.g., Wellpoint) for in-network status.
10. Common Denials and Survey Findings
Applications and claims are frequently denied due to structural misunderstandings of Texas's individual-only enrollment mandate. Failure to maintain active licensure or correct address information also leads to enrollment closures.
Site visit failures for clinic locations will halt the enrollment process.
- Entity Enrollment Rejections: Applications submitted by agencies or clinics attempting to enroll as the billing provider for ABA are denied.
- Claim Denials: Claims submitted with an employer NPI as the billing or rendering provider are automatically rejected.
- License Expiration: Applications submitted when the LBA license expires within 30 days are denied.
- Institutional Forms: Claims submitted on institutional forms rather than professional forms are rejected.
- Site Visit Failures: Failure to pass the 42 CFR §455.432 on-site visit for designated office locations halts enrollment.
11. Key Contacts and Resources
Providers must utilize official state portals and contact centers for enrollment and policy guidance. MCO-specific resources are also necessary for the final contracting phases.
TMHP serves as the primary point of contact for all PEMS enrollment inquiries.
- TMHP Contact Center: 800-925-9126 (Option 3 for provider enrollment).
- TMHP Provider Enrollment Portal: https://www.tmhp.com/topics/provider-enrollment
- HHSC Medicaid ABA Flyer: https://www.hhs.texas.gov/sites/default/files/documents/applied-behavior-flyer.pdf
- TDLR LBA Licensure: https://www.tdlr.texas.gov/
- MCO Contracting Resource: Texas Association of Health Plans (TAHP) Medicaid Managed Care Provider Contracting and Credentialing Resources for LBAs.
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