National Law Review
6/16/2026

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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