On October 1, 2025, Sunshine Health will begin a temporary pause on enrolling new practitioners into existing Behavioral Analysis (BA/ABA) provider groups. For many ABA practice owners in Florida, this announcement has raised alarm bells. Sunshine Health is one of the state’s largest Medicaid managed care organizations, and a pause in credentialing new providers could directly impact access to care for thousands of families.
According to Sunshine Health, this moratorium is necessary to ensure that its current network of providers and credentialed staff are fully loaded and all related functions are managed accurately. While Sunshine has indicated it may make...
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This development adds yet another challenge for providers already navigating rate pressures, payment delays, and growing compliance demands. Let’s look at what this means for ABA practice owners, what we’re hearing from the provider community, and how practices can respond.
What Sunshine Health Announced
- Effective date: October 1, 2025
- Scope: A temporary moratorium on adding new practitioners to existing BA/ABA provider groups
- Reason: Sunshine Health states this pause is necessary to stabilize its credentialing process and ensure accuracy
- Exceptions: The pause does not apply to Regions A and B, and Sunshine may selectively enroll new providers in areas of demonstrated need
Sunshine Health emphasized its commitment to ensuring members and families continue to have access to quality care. But for many providers, the pause raises more questions than it answers.
Provider Concerns
In professional forums and provider discussions, ABA leaders have voiced serious worries about the impact of this pause:
- Access to care: Providers fear families will face delays if staff leave and new hires cannot be credentialed to take their place.
- Staff transitions: Questions remain about whether an RBT promoted to BCBA after October 1 will be treated as a new provider subject to the moratorium.
- Roster management: Agencies report that Sunshine already struggles with timely roster updates. Some staff who left more than a year ago still appear as credentialed in the system.
- Operational strain: Providers worry they may be forced to refer clients elsewhere if they can’t credential new staff, disrupting continuity of care.
- Confusion and inconsistency: Some providers said they received recruitment emails from Sunshine while also being told new enrollment was paused.
As one provider bluntly put it: “Sunshine holds the majority of Medicaid recipients, and to not credential a BCBA or RBT due to their own workflow issues is unacceptable.”
Why This Matters for ABA Practice Owners
This pause comes on top of other Medicaid challenges ABA practices are already facing in Florida, including payment delays and administrative hurdles. The Sunshine Health decision adds a new layer of uncertainty:
- Staffing risk: If you hire new RBTs or promote staff to BCBA after October 1, they may not be credentialed, leaving you with limited billable hours.
- Financial strain: Practices relying heavily on Sunshine Health Medicaid may see gaps in revenue if they cannot bill for newly hired staff.
- Client impact: Families could face interruptions in services if agencies can’t fill open staff roles quickly.
- Strategic planning: Practice owners will need to anticipate these disruptions and explore ways to stabilize revenue and staffing.
Practical Steps to Take
1. Review Your Payer Mix
Understand how much of your revenue comes from Sunshine Health Medicaid. If it represents a large share, consider diversifying into other payers such as commercial insurance, TRICARE, or direct-pay services.
2. Plan Hiring Timelines Carefully
If you have RBTs close to certification or BCBAs finishing exams, be strategic about their onboarding. Clarify with Sunshine whether they will be considered “new providers” subject to the pause.
3. Strengthen Your Billing and RCM
With fewer staff credentialed to bill, efficient billing becomes critical. At 3 Pie Squared, we offer Revenue Cycle Management services at 2.99% , one of the lowest rates in the industry. If you’re trying to reduce costs while improving cash flow, outsourcing your RCM is an effective place to start.
4. Advocate Collectively
Raise your concerns with professional associations like FABA and regulatory bodies like AHCA. Sunshine Health manages a large share of Medicaid members in Florida, and provider voices are critical to ensuring accountability and access to care.
5. Communicate with Families
Be proactive with your clients. Explain that credentialing delays are payer-driven and not within your practice’s control. Setting clear expectations helps maintain trust, even when systems outside your practice create disruptions.
Conclusion
Sunshine Health’s decision to pause enrollment of new ABA providers underscores a troubling pattern in Medicaid-funded services. As we’ve already seen with Florida’s payment delays, North Carolina’s rate changes, and Nebraska’s cuts, ABA practices are being squeezed by systemic challenges that threaten sustainability.
For ABA practice owners , the key is to stay proactive: monitor your payer mix, plan hiring carefully, and strengthen your revenue cycle management. Most importantly, join with other providers to advocate for solutions that protect access for the families who rely on ABA.
This pause may be temporary, but its impact could last long after October 1 if practices don’t prepare.
For further reading on Medicaid challenges in ABA, explore our earlier coverage:
