Insights

Between 2021 and 2025, Medicaid spending on ABA therapy grew six times faster than the number of children who received services, making it one of the fastest-growing areas of Medicaid expenditure, according to CMS. On August 4, 2026, CMS released a toolkit to help state Medicaid and CHIP agencies strengthen their programs and limit fraud, waste, and abuse tied to increased demand for ABA therapy. In 2025, Medicaid spent about $10 billion on ABA and related therapy services for children with ASD — a dramatic increase from the $2 billion spent in 2021. 

On September 8, 2026, the U.S. Department of Labor's (DOL) Employee Benefits Security Administration (EBSA) issued “Field Assistance Bulletin No. 2026-03” to clarify compliance with the Mental Health Parity and Addiction Equity Act (MHPAEA) and nonquantitative treatment limitations (NQTL). Under the 2013 final rule implementing MHPAEA, health plans and issuers must use comparable processes, strategies, evidentiary standards, or other factors when applying NQTLs and they cannot apply such methods more stringently to benefits for mental health and substance use disorder (MH/SUD) compared to benefits for general medical and surgical care. While the bulletin doesn’t break much new ground on compliance, it does reaffirm existing enforcement priorities and expectations. 

On March 3, 2026, the Department of Labor (DOL), Department of Health and Human Services (HHS), and Department of the Treasury (TREAS) — collectively, the “Tri-Agencies” — published their fourth annual report to Congress on enforcement of the Mental Health Parity and Addiction Equity Act (MHPAEA). The 2025 Report demonstrates a shift in approach by the Tri-Agencies in its tone and content and suggests that federal regulators, and the DOL in particular, are not as active as they previously were in MHPAEA enforcement. However, federal enforcement remains ongoing, and state enforcement of mental health parity laws continues to grow. Plans and issuers must continue to maintain comprehensive compliance processes and documentation for MHPAEA compliance.

In recognition of World Elder Abuse Awareness Day (June 15), hosts Payal Nanavati and Savanna Williams talk to Jen Mika about best practices that providers should keep in mind to combat elder abuse, neglect, and exploitation. This podcast episode features the following speakers: