Your child's ABA plan should carry goals for you too, and a federal toolkit now says so
Most families receive a copy of their child's ABA therapy plan, read the parts about their child, and file it. The plan is a working clinical document and also an administrative one, and the parts of it that a family is entitled to question are not marked as such. In August 2026 the Centers for Medicare and Medicaid Services published a toolkit for state Medicaid and CHIP programs that sets out what belongs in one of these plans, and it makes two of those parts visible.
There is no master document that tells a family what their plan is supposed to contain, and nobody is going to hand you one. This is the closest thing that now exists, it is public, and it is free to read.
What the toolkit is, and what it is not
The State Medicaid and Children's Health Insurance Program Applied Behavior Analysis Toolkit is guidance written for state programs, not for families and not for providers. It is 173 pages, and it sits alongside the state-level rules covered in our guide to Medicaid for autism. Its purpose is to help states design coverage policy, and a large part of it is about identifying documentation that signals improper billing.
That matters for how to use it. It does not say what any plan will approve, and it does not create an entitlement. It is a description of what federal guidance considers appropriate documentation. Reading your own plan against it tells you what to ask about. It does not tell you what you are owed.
What the toolkit says a plan should contain
Figure 6, on page 34, lists appropriate treatment plan documentation. Stated plainly, the elements are these.
- Assessment results and a reassessment schedule. Not only the findings, but when the next look is due.
- Measurable, functionally relevant goals for both the child and the caregiver, with mastery criteria, targeting core autism-related needs. Baselines are established at the initial assessment.
- Planned activities and hours, defined as direct ABA hours per week. Supervision and caregiver sessions are counted and documented separately.
- An anticipated duration and a transition plan. The toolkit gives the reason in the same line: to prevent open-ended authorizations without time-bound goals.
- A plan to monitor progress and modify goals, with an explicit caution against ABA being used as a custodial, respite, or educational substitute.
- Updates that describe the response using established outcome measures, not measures the provider created, and that identify when goals are completed, when progress stalls, and when a caregiver is progressing or having difficulty with their own goals.
Two of those elements are commonly misread
Item three separates direct ABA hours from supervision and from caregiver sessions, and counts them in different places. Families often see a single weekly number and assume it is all time with their child. It usually is not, and the split is not a discrepancy. Knowing which number is which is the difference between thinking hours were cut and understanding that supervision was recorded correctly.
Item five carries a caution rather than a requirement: the plan should not have ABA operating as a custodial, respite, or educational substitute. That sentence is aimed at states and at billing review, not at families, and it is easy to read as an accusation. It is more useful read as a description of scope. ABA therapy is not childcare, it is not a school program, and a plan that drifts toward either will eventually be questioned by someone. If your plan has stopped naming specific skills and now mostly names hours, that is the drift the line is describing.
Item two is the one most families have never been shown
Goals for both the child and the caregiver. With mastery criteria. With baselines.
That line places the caregiver inside the plan as someone with their own named, measurable objectives, rather than as a recipient of updates about their child. Item six extends it: plan updates are expected to record when a caregiver is making progress, and when a caregiver is having difficulty.
The same figure lists documentation flags for potentially erroneous or improper billing. The last entry on that list is lack of parent or caregiver engagement.
Read those together and the position is consistent. Federal guidance treats caregiver participation as a documented component of the plan, and its absence as something a reviewer should notice. If your plan has nothing under your name, that is a question worth asking, and the toolkit is the reason the question is reasonable.
There is a version of this that is worth naming before anyone reads it the wrong way. A caregiver goal with a baseline and a mastery criterion is not a performance review of a parent. It is the same thing the plan does for a child, applied to a skill an adult is learning, and it exists so that the support a family receives is specific rather than assumed. A goal that reads as though it is measuring effort rather than teaching something is a goal worth discussing with your clinical team.
What a reasonable caregiver goal looks like is a separate question from whether one is present, and the toolkit does not answer it. It asks only that the goals be measurable, functionally relevant, and tied to a baseline. Your BCBA can tell you what that means for your family and what would be realistic to carry through an ordinary week. The point of the federal line is narrower: it establishes that the section should exist.
Two other lines worth knowing
Page 32 describes Washington State's pathway, where authorization is granted in three to six month increments and each continuation requires a reassessment and an updated plan showing progress. States set their own periods, so yours may differ, but short renewal cycles are normal rather than a sign of a problem.
Page 110 explains something that puzzles a lot of families, which is why a provider sometimes asks for a fresh assessment at what feels like an arbitrary moment. The toolkit describes Georgia as an example of a state that requires updated behavioral assessment results dated no more than two months before the authorization period begins, along with progress summaries, revised goals, and objective data rather than narrative alone. Where a state sets a rule like that, the timing of the assessment is driven by the renewal date rather than by anything that changed with your child. If the request arrives without an explanation, that is usually what is behind it, and it is a fair thing to ask about directly.
The phrase worth carrying out of that page is objective data rather than narrative alone. It is the same standard as item six in the plan list, and it is the reason your clinical team collects numbers during sessions that may look, from the outside, like they are not about your child at all.
Back on page 32, the toolkit addresses when a diagnostic reevaluation should happen. It notes there are no universal standards, and that the literature suggests roughly one year for children diagnosed at two or three, more often if indicated, and at times of transition or significant life changes. Starting school is the example given. If your child started school this fall and the last evaluation predates it, that is a timing question you can raise now rather than at the next renewal.
What to check in your own plan
Open the copy you have, next to whatever you already use to track progress. If you do not have a current one, ask your provider for it, and ask for the most recent update rather than the original.
- Is there a reassessment date written anywhere, and has it passed?
- Are there goals listed under your name, separately from your child's?
- If there are, do they have a baseline and a stated mastery criterion, or are they described in general terms?
- Do the most recent updates say anything about your participation, in either direction?
- Are direct hours, supervision, and caregiver sessions listed separately?
- Is there an anticipated duration and a transition plan, or does the plan simply continue?
- Do the progress measures have names, or are they described only as the provider's own observations?
- Was the last diagnostic evaluation before your child's most recent major transition?
Bring the list to your next plan meeting with the date of the toolkit and the page number. Page 34 is the figure, and the document is published at medicaid.gov.
Questions about coverage for ABA therapy?
Our care team can walk you through what your coverage asks for before therapy starts and at each renewal.
Forta provides Online ABA therapy in 47 states and Washington, D.C., and In-Home ABA therapy in Houston, TX.
Sources
- Centers for Medicare and Medicaid Services, State Medicaid and Children's Health Insurance Program Applied Behavior Analysis Toolkit, August 2026. Link
About this article
Written by Megan Butler, MPH, VP of Clinical Operations · Clinically reviewed by Janelle Deveau, MA, BCBA · 2026-10-08
What this is. General information, reviewed by a BCBA. It is not legal advice and it is not clinical advice about your child. What works for one child often does not work for another, and your child's BCBA is the person who can tell you which of this applies.
