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National Law Review
National Law Review
6/16/2026
Applied Behavior Analysis (ABA) Medicaid Investigation Defense

Applied Behavior Analysis (ABA) Medicaid Investigation Defense

Short summary

ABA therapy providers face intensified Medicaid fraud investigations from HHS OIG in 2026. Defense requires understanding False Claims Act, Anti-Kickback Statute, and Stark Law violations. Criminal convictions carry six-figure fines and up to 10 years federal imprisonment.

  • HHS OIG aggressively targeting ABA providers for alleged Medicaid billing fraud
  • Seven-step defense strategy includes engaging experienced counsel and assessing investigation scope
  • Violations can trigger civil or criminal prosecution with substantial financial and imprisonment penalties

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