The 40-Mile Rule Is Gone
One of the most controversial proposals would have prevented Medicaid reimbursement when an ABA provider lived more than 40 miles outside North Carolina. That restriction has been removed. If your client’s BCBA already lives across the state line and is enrolled as a North Carolina Medicaid provider, services can continue without worrying about that mileage requirement. Before anyone starts recruiting across state borders, though, there’s an important catch. North Carolina law still prohibits new out-of-state providers from enrolling in NC Medicaid. This policy change protects providers who were already enrolled—it doesn’t create new enrollment opportunities.
Telehealth Supervision Just Became Much More Practical
North Carolina also increased the amount of supervision that can be conducted through telehealth. The limit moved from 20% to 50%. For many practices, that’s a meaningful operational improvement. Less windshield time. More scheduling flexibility. Better access to supervision in rural areas. The clinical standards haven’t changed. BCBAs are still responsible for providing quality supervision. They simply have more flexibility in how they deliver it.
CARS-2 Finally Gets the Recognition It Deserves
Another welcome clarification is the formal recognition of both versions of CARS-2 as approved diagnostic tools. Previously, the policy only referred to a “validated diagnostic tool,” leaving providers to interpret what qualified. Now there’s clarity. For many clinicians, CARS-2 offers a faster and more accessible assessment process than ADOS-2. While every child deserves the assessment that’s clinically appropriate for them, having CARS-2 explicitly recognized should help reduce unnecessary confusion and delays for many families.
Prior Authorization Gets Easier—But Read the Fine Print
One change that’s generating a lot of excitement involves treatment plans exceeding 16 hours per week. Coverage authorization now moves from every 30 days to every 90 days. That’s excellent news for billing departments. But don’t stop reading there. The clinical treatment plan itself still requires monthly review and reauthorization under North Carolina law. In other words: Your billing team gets some relief. Your clinicians still have monthly documentation responsibilities. It’s progress—but it’s not a complete reduction in paperwork.
The Bigger Story
The biggest lesson isn’t actually any of these four policy changes. It’s that public comments mattered. When the original draft was released, providers across North Carolina raised concerns. Parents shared how the proposed rules could reduce access to care. Professional organizations submitted detailed feedback. Advocacy groups organized responses. The final policy reflects many of those concerns. That’s an important reminder for everyone working in ABA. Too often, providers assume policy decisions are already set in stone. Sometimes they aren’t. Sometimes showing up, submitting comments, and participating in the process genuinely changes the outcome. This appears to be one of those times.
Final Thoughts
These changes won’t solve every operational challenge facing ABA providers in North Carolina. Documentation requirements remain significant. Provider shortages still exist. Recruiting continues to be difficult. But compared to the proposals released earlier this year, this final version is undeniably better. More flexibility. Less administrative burden. Clearer guidance. That’s a rare sentence to write about healthcare regulation. Hopefully, it’s not the last.