If your child receives ABA therapy through Florida Medicaid, the last 18 months have probably brought paperwork, phone calls, and uncertainty that you did not expect when you enrolled in services. You may have received a notice that your provider is no longer in-network. You may have been told that a prior authorization that was valid last year needs to be resubmitted. You may have been automatically moved to a new health plan without fully understanding what changed or why.
None of this happened by accident. It is the result of Florida's Statewide Medicaid Managed Care 3.0 — a major restructuring of how Medicaid delivers healthcare to approximately three million Florida residents — and a second, overlapping transition affecting a specific population of medically complex children. This article explains what changed, why it is still causing disruption, and what rights families have to protect access to their child's ABA therapy.
What SMMC 3.0 is and what changed on February 1, 2025
The Florida Agency for Health Care Administration (AHCA) implemented the Statewide Medicaid Managed Care 3.0 program on February 1, 2025. SMMC 3.0 is a new six-year contract cycle (running through 2030) that restructures how Medicaid delivers services across the state through nine managed care organizations, or MCOs: Aetna Better Health, Children's Medical Services, Community Care Plan, Florida Community Care, Humana, Molina Healthcare, Simply Healthcare, Sunshine Health, and UnitedHealthcare.
The most significant change for ABA families is that behavior analysis (BA) services for children under age 21 were moved from fee-for-service Medicaid into the managed care system. Before February 2025, ABA providers could bill the state directly through AHCA — one system, one payer ID, one set of documentation standards. Under SMMC 3.0, providers must be individually contracted and credentialed with each specific MCO. If your child is enrolled in Simply Healthcare and your provider is not contracted with Simply Healthcare, your child's therapy is no longer covered under that plan — regardless of how long your child has been receiving services or how strong their clinical progress has been.
Children not enrolled in a managed care plan remain under the traditional fee-for-service system and are unaffected by this change. However, the vast majority of Florida Medicaid recipients — approximately 70 percent — are enrolled in managed care. For most ABA families in Florida, SMMC 3.0 changed how their child's therapy is billed, authorized, and paid for.
Why the transition has been disruptive
The structure of the change created a credentialing bottleneck that caught many ABA providers off guard. Contracting and credentialing with AHCA as a Medicaid provider is one process. Contracting and credentialing with each individual MCO is a separate process — and there are nine of them, each with its own application system, documentation requirements, timelines, and approval criteria. A provider with a valid Florida Medicaid ID who had been billing the state for years under fee-for-service had to restart the process, essentially from scratch, with each managed care plan.
MCOs began receiving a significant surge in credentialing applications in the months leading up to February 2025. Some plans responded by declaring network adequacy — claiming they already had sufficient providers in their networks — and rejecting new applications. ABA providers reported that applications were being denied not because of any clinical or licensure deficiency, but because plans were managing their network sizes administratively. A Change.org petition signed by ABA providers in early 2025 specifically documented this issue, calling for AHCA to expedite the credentialing process and ensure immediate access to MCO billing portals for providers who could not complete credentialing before the February launch.
The billing impact on providers has been significant. Under SMMC 3.0, each plan has its own payer ID, its own portal for claim submission, its own prior authorization requirements, its own CPT code policies, and its own documentation standards. Providers who were not contracted with a plan when services were rendered — even during the official continuity of care period — faced delayed reimbursement, denied claims, and extended accounts receivable. Some practices serving predominantly Medicaid populations reported cash flow disruptions that threatened their operational stability.
Your child's continuity of care rights
Florida AHCA built continuity of care (COC) protections into the SMMC 3.0 transition specifically to prevent service interruptions for children already receiving ABA therapy. These protections are legally enforceable, and families should know them. Under the SMMC 3.0 requirements, managed care plans must reimburse ABA providers who are not yet in-network for services delivered during the COC period at the rate those providers received prior to the transition, for a minimum of 60 days. Plans must also honor existing prior authorizations and approved service levels for a minimum of 90 days, and must extend any authorization that expires during the 90-day COC period.
This means that if your child's ABA provider is not currently in-network with your child's Medicaid plan, your child is entitled to a transition period during which services should continue without interruption and at no cost to you — while the provider completes contracting or while you locate an in-network alternative. The key word is entitled. This is not a courtesy extended by the plan; it is a regulatory requirement AHCA placed on all SMMC MCOs.
Beyond COC protections, children enrolled in Florida Medicaid have federal rights under the Early and Periodic Screening, Diagnosis and Treatment (EPSDT) mandate. Under EPSDT, states must cover all medically necessary healthcare services for Medicaid-enrolled children under age 21, including ABA therapy. A managed care plan cannot deny ABA therapy to a child who meets clinical eligibility on the grounds that it is inconvenient, administratively burdensome, or outside their standard coverage parameters. If your child's ABA services are denied, reduced, or terminated, you have 60 days from the date of the Notice of Adverse Benefit Determination to file an appeal.
The second transition: the CMS Plan moving from Sunshine Health to Molina
Overlapping with SMMC 3.0 is a separate, significant transition that will affect a specific group of Florida Medicaid children: those enrolled in the Children's Medical Services (CMS) Managed Care Plan. The CMS Plan serves medically complex children — children who typically require intensive, coordinated care across multiple specialties and therapy types. The plan has been operated by Sunshine State Health Plan.
Florida AHCA has selected Molina Healthcare to assume responsibility for the CMS Plan. All current CMS Plan members will automatically transition to Molina Healthcare on October 1, 2026. Members do not need to take any action — the transition is automatic, and existing authorizations, prescriptions, and scheduled appointments will be honored. Molina has committed to accepting and honoring existing authorizations and processing claims accordingly during the transition.
For ABA providers who currently serve CMS Plan families, this transition requires attention. Molina Healthcare currently operates SMMC plans only in Miami-Dade and Monroe counties. Winning the CMS Plan contract means Molina is rapidly building a comprehensive statewide provider network from scratch. Providers who are contracted with Sunshine State Health Plan for CMS services will need to complete a separate contracting and credentialing process with Molina before October 2026 to remain in-network for those families. AHCA has indicated that Molina will begin sharing contracting and credentialing information as part of its transition timeline. Providers should not wait for those communications — outreach to Molina provider relations should begin now.
What families with Simply Healthcare should know
Simply Healthcare Plans, Inc. remains an active SMMC MCO under the new contracts and continues to serve Florida Medicaid members across all 11 regions of the state. If your child is enrolled in Simply Healthcare, the change that matters most under SMMC 3.0 is whether your current ABA provider has completed contracting with Simply. Simply Healthcare uses Carelon Behavioral Health for behavioral health utilization management, which means prior authorization requests for BA services are processed through Carelon, not through Simply's general provider line. ABA providers and families should confirm this routing when submitting or checking on authorizations.
If you received a notice that your child's ABA provider is no longer in-network with Simply Healthcare, you have the right to a continuity of care period as described above. You also have the right to request a list of in-network ABA providers from Simply's member services. Florida law requires managed care plans to maintain network adequacy — a sufficient number of contracted providers to meet the reasonable access needs of enrolled members. If no in-network provider is available within a reasonable distance or timeframe, Simply is obligated to arrange out-of-network care at in-network cost.
What ABA providers need to do
For ABA practices still navigating the SMMC 3.0 transition, the operational priority is completing contracting with every MCO that covers your patient population — not just the largest plans. Verify each current patient's plan enrollment before each authorization cycle, because AHCA auto-assigns members to plans and reassignments can happen at renewal. Each plan has its own payer ID and portal; routing claims to the wrong payer results in immediate rejection that may not be correctable after the timely filing window closes.
For the CMS Plan transition specifically: begin Molina contracting outreach now. The October 2026 deadline is close enough that the credentialing timeline — which can run 90 to 120 days or longer under high application volume — makes early action essential. Providers who wait for formal Molina communications risk arriving at the transition date without completed credentials, creating the same disruption the field experienced at the SMMC 3.0 launch.
Documentation standards have also tightened under managed care. Plans are now conducting medical necessity reviews with more specificity than the prior fee-for-service system required. Clinical notes, supervision logs, caregiver training records, and authorization requests must align precisely with what each plan's utilization management team considers sufficient to support continued service levels. Practices should audit their documentation workflows against the specific requirements of each plan they are contracted with, not against a generic Medicaid standard.
Your rights if services are denied or disrupted
If your child's ABA therapy is denied, reduced, or terminated by a Medicaid managed care plan, you have enforceable rights that extend beyond the plan's internal policies. First, request the denial in writing — a Notice of Adverse Benefit Determination (NABD). Plans are required to provide written notice with a specific reason for any denial. Without a written NABD, the appeals clock has not started.
Once you have the NABD, you have 60 days to file a written or oral appeal with the plan. If the plan upholds the denial, you can request a fair hearing through AHCA — an administrative process with independent review. During the appeal and fair hearing process, your child may be entitled to continuation of services while the dispute is pending. This is particularly important for children whose authorizations are being reduced mid-treatment.
For complaints about how a plan is managing your child's care — including failure to honor COC protections, unreasonable delays in prior authorization decisions, or failure to maintain an adequate provider network — you can file a complaint directly with AHCA through its Medicaid Managed Care complaint portal. Document every call, every denial, and every authorization submission with dates, reference numbers, and the name of the representative you spoke with. That documentation becomes the record in any appeals or complaint process.
Spectrum Analytics Consulting is in-network with the major Florida Medicaid managed care plans serving Miami-Dade and Broward counties. If your child's current provider is no longer accessible due to the SMMC 3.0 transition, we are available for an intake consultation to discuss continuity of care options.
