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Applied Behavior Analysis denials: what the review data shows

Independent reviewers have decided 528 published cases where an insurer denied Applied Behavior Analysis — and they overturned the insurer 68% of the time. A denial for Applied Behavior Analysis is a starting position, not a final answer.

Published decisions
528
2001–2026
Overturned
68%
359 denials reversed

By condition

Published outcomes when Applied Behavior Analysis was denied for these conditions.
ConditionDecisionsOverturned
Autism Spectrum Disorder506
69.4%
ADHD14
28.6%

What the insurer actually argued

Denials fall into different categories, and they don’t succeed equally — so the reason on your letter changes how you should answer it.
Reason givenDecisionsOverturned
Medical Necessity
The plan said the care wasn’t medically necessary. The most common fight, and the most winnable.
500
67.2%
Experimental/Investigational
The plan called the treatment unproven. These turn on published evidence, so the appeal is a literature argument.
28
82.1%
Typical time to a decision
10 days
Most land between 4 and 21 days
Handled as urgent
53.6%
Expedited when a delay would cause harm
Recent direction
Rising
40%53.3% overturned, last three years
What the reviewers wrote
Excerpts from the independent reviewers’ published findings — the actual reasoning, quoted, not summarised.

Where the denial was overturned

Nature of Statutory Criteria/Case Summary: The parent of a patient has requested authorization and coverage for ongoing psychotherapy treatment, every two weeks. The American Academy of Child and Adolescent Psychiatry (AACAP) and American Association for Community Psychiatry (AACP) have unified the Child and Adolescent Level of Care Utilization System (CALOCUS) and the Child and Adolescent Service Intensity Instrument (CASII) into a single instrument, the Child and Adolescent Level of Care/Service Intensity Utilization System (CALOCUS-CASII). This instrument is a standardized tool used to determine the intensity of services needed for children and adolescents, 6-18 years of age, presenting with psychiatric, substance use, medical and/or developmental concerns. Using CALOCUS-CASII, providers score patients on a scale of 1-5 using a six-pronged Dimensional Rating System.
Medical Necessity · 2023 · IMR MN23-39147
Nature of Statutory Criteria/Case Summary: The patient’s parent has requested (ABA) nine hours of behavior identification assessment by clinician for a total of 15 hours per six months; three hours of behavior identification supporting assessment by technician for total of five hours per six months; and ten hours per week adaptive behavior treatment by protocol by technician for a total for 40 hours week. The ABA Coding Coalition describes comprehensive treatment as appropriate for patients who engage in harmful and risky behaviors and/or have substantial deficits in adaptive skills that jeopardize their health and safety. Comprehensive programs often involve 30 to 40 hours of service weekly, plus direct and indirect case supervision and caregiver training.
Medical Necessity · 2022 · IMR MN22-38111

Where the denial was upheld

Worth reading too — these show what an appeal has to overcome.
Nature of Statutory Criteria/Case Summary: The parents of the enrollee have requested reimbursement and prospective authorization and coverage for an additional 15 hours per week of ABA, for a total of 40 hours per week provided by California Unified Service Providers, LLC, from 11/12/20 through 5/12/21.At issue in this case is whether the additional 15 hours per week of ABA, for a total of 40 hours per week provided by California Unified Service Providers, LLC, from 11/12/20 through 12/31/20 were medically necessary to treat the patient’s condition. Were and/or are the additional 15 hours per week of ABA, for a total of 40 hours per week provided by California Unified Service Providers, LLC, from 1/01/21 through 5/12/21 medically necessary to treat the patient’s mental health or substance use disorder as defined in Health and Safety code section 1374(a)(3)(A)?
Medical Necessity · 2021 · IMR MN21-35090
Nature of Statutory Criteria/Case Summary: The patient has requested reimbursement and prospective authorization and coverage for 20 hours per week of direct applied behavioral analysis (ABA) (30 hours total) and 16 hours per month supervision by a B.C.B.A. (24 hours total) and 0.5 hour per month reassessment (one hour total). The Council of Autism Service Providers (CASP) guidelines on ABA treatment of autism spectrum disorder highlight the difference between focused treatment, ten to 25 hours weekly, and comprehensive treatment, 30 to 40 hours weekly. Specifically, the guidelines note that comprehensive treatment refers to “treatment of the multiple affected developmental domains, such as cognitive, communicative, social, emotional, and adaptive functioning. Maladaptive behaviors, such as noncompliance, tantrums, and stereotypy are also typically the focus of treatment.
Medical Necessity · 2022 · IMR MN22-36686

Figures and quotations on this page come from 42,749 published decisions in the California DMHC Independent Medical Review dataset. These are California outcomes — every state runs an equivalent external review, but the rates here are California’s. Excerpts are quoted verbatim from the public record and describe this treatment generally, not any individual case.

How to use this in your appeal

These are outcomes from California’s external review program — an independent physician panel that binds the insurer. Every state has an equivalent process, and internal appeals succeed even more often. Cite the outcome record for Applied Behavior Analysiswhen you appeal: reviewers routinely find that denials like yours didn’t hold up.

SOURCE: CALIFORNIA DMHC INDEPENDENT MEDICAL REVIEW OUTCOMES (CHHS OPEN DATA) · DERIVED AGGREGATE STATISTICS ONLY · METHODOLOGY

Not legal or medical advice. Coverage Rights is a self-help tool that helps you prepare your own appeal. For advice about your specific situation, talk to a licensed attorney or your doctor.

Denied Applied Behavior Analysis? 68% got it reversed.

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