Federal ABA Oversight & Program Integrity Aug 2026
Centers for Medicare & Medicaid Services. State Medicaid & Children’s Health Insurance Program Applied Behavior Analysis Toolkit. August 2026.
The 173-page toolkit addresses clinical standards, outcome assessment, payment, provider qualifications and ownership, organizational accreditation, utilization management, and fraud/waste/abuse prevention. It is now a central source for the Project's payer and state work.
- CMS ABA Toolkit — August 2026. Federal guidance for state Medicaid and CHIP programs, including provider ownership structures, accreditation, supervision, utilization management, and program integrity.
- ABA CMS Standards & Accountability Crosswalk v3. Project source-level crosswalk comparing the Toolkit with state, credentialing, accreditation, ownership, and oversight requirements.
- ABA Payer Brief — August 2026. What Payers Already Have Authority to Require in ABA Provider Contracts. Project analysis translating existing contracting authority into targeted safeguards.
Professional Ethics & Scientific Integrity Added
- American Psychological Association. Ethical Guidance for AI in the Professional Practice of Health Service Psychology. Updated July 2025 — transparency, informed consent, bias, privacy, validation, accuracy, and human professional judgment.
- APA Ethics Code Task Force. 2025 substantive discussion materials — includes Scientific Mindedness, Integrity and Trustworthiness, competence, technology, research/publication/scientific integrity, and public responsibility in the revised framework under discussion.
CASP's Own Website — casproviders.org
All pages accessed and verified March–April 2026.
- Mission & History — casproviders.org/history-and-mission
- Staff & Board of Directors — casproviders.org/staff-and-board
- Membership Information & Fee Structure — casproviders.org/casp-member-organization
- Autism Commission on Quality (ACQ) — casproviders.org/the-autism-commission-on-quality
- ACQ Frequently Asked Questions — autismcommission.org/faq
- ACQ Accreditation Committee — autismcommission.org/accreditation-committee
- Advocacy Page (Indiana, Federal priorities) — casproviders.org/advocacy
- Annual Conference Description — casproviders.org/events/2026-conference
- Business Affiliate Program New — casproviders.org/business-affiliate
- Training Affiliate Program New — casproviders.org/casp-training-affiliate
- Allied Affiliate Program New — casproviders.org/casp-allied-affiliate
- Legal Notices, Bylaws & IRS Form 990s New — casproviders.org/legal
- Antitrust Policy (adopted March 17, 2026) New — casproviders.org/legal
- AI Practice Parameters (July 2025) — casproviders.org
IRS Form 990 Filings New
Publicly filed and available at casproviders.org/legal. All 990s from 2018–2024 are posted.
2024 Form 990 — Council of Autism Service Providers, Inc. (EIN 81-1254601). Filed September 23, 2025.
Key documented figures: Total revenue $2,593,034 · CEO (Lorri Unumb) total compensation $266,054 · Affiliate revenue $140,400 · Lobbying confirmed · Related party transaction: $16,550 paid to Autism Legal Resource Center, identified as organization of CEO's spouse.
ACQ Schedule R reporting — CASP's 2024 Form 990 identifies ACQ as a disregarded entity controlled by CASP, and reports $178,317 in total income and −$636,088 in the Schedule R field labeled “end-of-year assets.” The 2023 return reports −$393,738 in the same field. The filing does not characterize these figures further, and we do not interpret them here.
- 2023 Form 990 — available at casproviders.org/legal
- 2022 Form 990 — available at casproviders.org/legal
- 2018–2021 Form 990s — available at casproviders.org/legal
Behavior Analyst Certification Board (BACB)
- BACB Blog. (March 2020). ASD Practice Guidelines find new home with CASP. bacb.com — Source for the transfer of the ABA Practice Guidelines from BACB to CASP.
- BACB RBT Credential Standards — bacb.com. Source for the consumer protection purpose of the RBT credential and its supervision requirements, referenced throughout the position statement's credentialing sections.
CASP Leadership Statements & Journalism
- Larson, C. (January 13, 2026). CASP acquires fellow autism services accreditation body Jade Health. Behavioral Health Business. bhbusiness.com — Source for CEO Lorri Unumb quotes: "wouldn't have been able to make ends meet" and "exponentially increase in short order."
- Gonzales, M. (October 4, 2024). Massachusetts mandates accreditation for Medicaid ABA providers. Behavioral Health Business. bhbusiness.com
- CASP / ABA Centers NYSE Closing Bell Press Release, December 24, 2024. PRNewswire. prnewswire.com
Peer-Reviewed & Published Research
- Singh, Y. et al. (2026). Private equity acquisition of autism therapy centers. JAMA Pediatrics, January 5, 2026.
- Batt, R. & Appelbaum, E. (2023). Pocketing money meant for kids: Private equity in autism services. Center for Economic and Policy Research. cepr.net
- Silbaugh, B.C. & El Fattal, R. (2022). Exploring quality in the applied behavior analysis service delivery industry. Behavior Analysis in Practice, 15, 571–590. New
- Townsend, D.B. et al. (2024). Alliance for Scientific Autism Intervention: System components and outcome data from high-quality service delivery organizations. Behavior Analysis in Practice, 17, 565–580. New
Salary Data New
- Bureau of Labor Statistics. Occupational Employment and Wage Statistics, SOC 21-1018 (counselors and specialists, including behavior-analytic roles). National median: $59,190. bls.gov
- ZipRecruiter. Average BCBA salary, United States, April 2026: $89,075. ziprecruiter.com
Legislative & Regulatory Context
Note: This legislative landscape is moving quickly. The following were verified or rechecked through August 2026.
- Oregon SB 951 (2025) — Private equity healthcare ownership disclosure and clinical control restrictions.
- California AB 3129 and SB 1063 (2025) — Mandatory reporting of private equity healthcare transactions; prohibition on PE interference with physician and dentist professional judgment.
- Massachusetts Steward Health Care legislative response (2024–2025) — enacted in response to PE-backed hospital system bankruptcy.
- Health Over Wealth Act — introduced by Senator Edward Markey. Would require PE firms to obtain federal HHS license before healthcare transactions.
- FTC Chair public statement on financialization in healthcare — cited in position statement Section XII.