Posted 1 week ago Author: 3 Pie Squared Marketing Team

Concerns Grow Over Insurance Misuse of Medically Unlikely Edits (MUEs) in ABA Therapy Denials

A recent article published in Behavior Analysis in Practice has raised concerns about the growing misuse of Medically Unlikely Edits (MUEs) by some insurance companies when processing claims for Applied Behavior Analysis (ABA) therapy. Originally intended as a tool to prevent billing errors and potential fraud, MUEs are now being applied in ways that may improperly limit access to necessary autism services.

What Are Medically Unlikely Edits (MUEs)?

MUEs were created by the Centers for Medicare & Medicaid Services (CMS) as a system of checks to flag unlikely or erroneous billing patterns. For example, they might limit the number of certain procedures that could reasonably occur for a patient in a single day.

However, MUEs were never intended to place hard caps on medically necessary treatment — especially when services are correctly authorized, delivered, and documented.

How Are MUEs Being Misused in ABA?

According to the study, some insurance companies are using MUEs as a justification to automatically deny claims once a certain threshold is reached — regardless of the treatment plan or medical necessity.

This is problematic because:

MUEs are based on assumptions about typical billing patterns — not individualized client needs.
ABA therapy often involves intensive, multi-hour sessions, especially for children with significant support needs.
Denials based on MUEs may ignore prior authorization approvals and clinical recommendations.

Impact on Providers and Families

When insurers treat MUEs as strict coverage limits:

Claims can be denied even when therapy was authorized and provided correctly.
Families may face unexpected bills.
Providers lose reimbursement for legitimate services.
Access to medically necessary care may be delayed or reduced.

In some cases, providers have reported that even after submitting appeals with clear documentation, claims are still being denied based solely on the MUE threshold.

What the Authors Recommend

The authors of the article urge behavior analysts, insurance companies, and regulators to:

Clarify that MUEs are not treatment caps.
Educate providers on proper billing practices without misinterpreting MUEs.
Advocate for policy changes to prevent inappropriate use of MUEs in ABA services.

They also stress the importance of documenting medical necessity clearly in session notes and treatment plans, especially when billing for higher-than-average service hours.

Why This Matters to ABA Providers

As insurance companies look for ways to control costs, the misuse of tools like MUEs creates an additional challenge for ABA providers trying to deliver ethical and medically necessary care.

For providers, this means:

Monitoring EOBs (Explanation of Benefits) closely for MUE-related denials.
Preparing for appeals with detailed documentation.
Educating billing staff on CMS rules vs. insurance company interpretations.
Staying informed about state laws and parity protections that may prevent these practices.

The Bigger Picture: Advocacy is Essential

This issue ties directly into broader efforts to protect access to ABA under mental health parity laws. Limiting care based on administrative edits rather than clinical need undermines the standards of care for individuals with autism.

As this issue gains more attention, providers, families, and professional organizations will need to work together to push for clear guidelines and enforcement to prevent MUE misuse.

Sources:

Disclaimer: This article summarizes publicly available information and reporting from external sources. We encourage readers to review the original reports linked above for complete details and context. This summary does not represent legal advice, nor is it an official statement from any party involved.