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Telehealth Beyond the PHE: What ABA Agencies Need to Know

by Michael Fabrizio
Aug 21, 2025

A New Telehealth Landscape After October 1

Telehealth rules are changing—again. On October 1, 2025, CMS will roll back several COVID-era telehealth waivers. For most healthcare services, this means tighter rules on patient location, approved sites, and technology requirements.

For ABA services, the outlook is different: ABA telehealth is still protected under CMS’s behavioral health carve-outs. Clients can continue to receive care from home and, when appropriate and allowed, through audio-only sessions.

But here’s the catch: even though Medicare does not cover ABA therapy, CMS policy changes often ripple through Medicaid telehealth coverage and private insurance telehealth policies. That means these shifts could affect the payers you rely on most.

In this article, we’ll explain:

  • What CMS telehealth changes mean for ABA providers

  • Why Medicaid clients could see the biggest downstream effects

  • How commercial insurers may respond

  • Compliance checkpoints every ABA agency should implement now

Plus: We’ve created a free Telehealth Compliance Checklist to help you prepare your agency for October 1.

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About Us ABA Compliance Collective Community ABA Session Note Frameworks Our Services Our Newsletter Get in Touch