IPSON INVESTMENTS

The Texas ABA Coverage Playbook · 2026 edition

How families actually pay for ABA therapy in Texas.

Written by a licensed Houston practice, est. 1996. Every figure in here is a public, published 2026 number, and every claim about the law says which law. Where something is genuinely unknowable, this guide says so instead of guessing.

2026 plan-year edition · figures verified August 2026 · also available en español

1 · Start here: the decision order

The most expensive mistake a Texas family can make is starting with the marketplace. Before comparing a single plan, screen these three programs in this order — each one, for the families who qualify, beats every marketplace option:

First: Children's Medicaid (STAR). Household income up to roughly 133% of the federal poverty level, ages 0–18. Covers ABA under the THSteps/EPSDT benefit with no dollar cap and no waiting list, and you can apply in any month — Medicaid has no open-enrollment window. If your household qualifies, this is the whole answer.

Second: CHIP. Income up to roughly 201% of the poverty level. Here is the trap almost nobody warns you about: a child who qualifies for CHIP cannot receive premium tax credits on a marketplace plan. You may enroll the child in your family marketplace plan anyway — but at full, unsubsidized price. The arithmetic almost always lands the same way: child on CHIP, parents on a subsidized marketplace plan. Texas charges a small annual CHIP enrollment fee.

Third — and most missed: Medicaid Buy-In for Children (MBIC). Texas covers children with disabilities up to age 19 with family income up to 300% of the federal poverty level — roughly $96,000 for a family of four in 2026 — for a monthly premium of at most about $230. It is full Medicaid: ABA with no annual cap, no age cliff, no network fight, and enrollment any month of the year. The gate is a disability determination to the Social Security standard — receiving SSI is not required, but a diagnosis alone does not automatically qualify. Most families earning a normal income have never heard MBIC exists. Ask us, or ask HHSC, about it by name.

Do not join the HCS or CLASS waiver interest lists expecting ABA. Those waivers fund long-term support services, the lists hold over 130,000 people, and the wait runs 17–18 years. Join them anyway — it is free and starts the clock for adult services — but ABA comes from regular Medicaid, CHIP or MBIC today, not from a waiver in 2043.

Only then: the marketplace. If your child does not qualify for any of the above — or you want the parents covered too — the individual marketplace is the right tool, and the rest of this guide is about using it well.

2 · The out-of-pocket reality

At published 2026 rates, a comprehensive ABA program — 30 to 40 hours a week of direct therapy plus supervision — bills roughly $112,000 to $190,000 a year. Read that number, then set it aside, because it is not what you pay.

Every marketplace plan carries a legal ceiling on what your family can pay in a year for in-network, covered care:

2026 planIndividual maxFamily max
Any marketplace plan$10,600$21,200
Silver with cost-sharing reduction, income 201–250% FPL$8,450$16,900
Silver with cost-sharing reduction, income ≤200% FPL$3,500$7,000

So for in-network, authorized ABA, a $150,000 therapy year costs your family at most the out-of-pocket maximum — and on a cost-sharing-reduction silver plan, dramatically less. Which means the real questions are never "what does ABA cost?" They are:

Is the clinic in the plan's network? Will the hours be authorized? Does a coverage cap apply? Those three questions are sections 4, 5 and 3 of this guide, and they are where plans genuinely differ.

One honest caveat on rates: what an insurer actually pays your clinic is set by private contract and is not public. The billed range above comes from the two published public schedules — Texas Medicaid's fee schedule at the low end and TRICARE's Houston-locality maximums at the high end. Anyone who quotes you one confident commercial number is guessing.

3 · What Texas law does and doesn't promise

You will hear — from clinics, from Facebook groups, sometimes from people selling insurance — that "Texas law requires health plans to cover ABA." Here is the precise truth, because the imprecise version costs families money:

Texas's autism mandate (Insurance Code §1355.015) applies to employer group plans. This trips up almost everyone, including people who should know better, because §1355.015 itself says "a health benefit plan" — it does not say "group." But it sits inside Chapter 1355, Subchapter A, whose heading is Group Health Benefit Plan Coverage and whose applicability section, §1355.002(a), states that the subchapter "applies only to a group health benefit plan." The applicability section governs. Self-funded employer plans (most large employers) are exempt from state mandates entirely under federal ERISA law.

On an individual marketplace plan, ABA coverage comes from somewhere else — and one of those places is still Texas law. First, the federal Essential Health Benefits rules: Texas's benchmark plan includes autism services under habilitative and behavioral-health benefits. Second — and this is the part usually reported wrong — Texas Insurance Code Chapter 1355, Subchapter F (added by HB 10 in 2017). Its applicability section, §1355.252(a), reaches "an individual, group, blanket, or franchise insurance policy," and §1355.254 requires that mental-health and substance-use benefits carry no treatment limitations more restrictive than those on medical and surgical benefits. The Commissioner enforces it (§1355.255), and §1355.2571 requires TDI to run a parity complaint portal families can file through. Federal mental-health parity says much the same thing on top.

So the honest summary is this: your individual marketplace plan is regulated by the Texas Department of Insurance and is covered by a Texas parity statute — just not by the autism mandate specifically. That distinction is worth getting right in both directions. Someone who tells you Texas law does nothing for your marketplace plan is as wrong as someone who tells you §1355.015 forces it to cover ABA.

Two age rules worth knowing from the group-plan mandate, because carriers sometimes import its language into individual policies: coverage under the mandate requires the autism diagnosis to have been in place before the 10th birthday, and from age 10 the mandate does not require ABA coverage above $36,000 per year. Whether an individual policy applies either rule is decided by that policy's own contract language — it has to be read, not assumed, and reading it is part of our free review.

Also check the visit limit. Texas's benchmark caps "habilitation services" at 35 visits a year — meaningless against 1,500+ hours of ABA — while behavioral-health outpatient benefits carry no visit cap. Which category a carrier processes ABA under decides everything, it varies, and it is written in the plan's Evidence of Coverage. This is the single most important thing to verify before enrolling, and the least-known.

4 · Network: the question that decides the year

Behavioral-health networks are the narrowest networks in the marketplace — narrower than primary care, narrower than any other specialty. Confirming your clinic's status is worth more than any premium comparison.

How to check properly. The federal Marketplace's own data answers "is this provider in this plan's network" — but carriers sometimes submit no provider data at all, and no data is not the same as no. A clinic that shows nothing may well be in network. The only reliable confirmation is the carrier's own directory plus a phone call to the clinic's billing office asking "are you in network for this exact plan name for 2026?" Plan names are precise; "we take Blue Cross" is not an answer.

Your rights when no clinic is in network. Texas law (Insurance Code §1301.005 and rule 28 TAC §3.3708) requires an insurer whose network cannot actually provide a covered service to pay an out-of-network provider at the in-network benefit level. In practice: if no in-network ABA provider is reasonably available near you, you can demand a network-gap referral, and the insurer must process it — for EPO plans, within five business days of your documentation. Ask for it by name: a network adequacy referral or single-case agreement.

The fine print that matters: in-network cost-sharing is fully protected only when you use the provider the insurer designates. If you insist on your own clinic, you get in-network benefit levels but remain exposed to balance billing — which is exactly why a negotiated single-case agreement, where the clinic agrees to accept the insurer's payment as payment in full, is the thing to ask the clinic and insurer to sign.

The balance-billing trap in intake paperwork. Neither the federal No Surprises Act nor Texas's surprise-billing law protects scheduled outpatient therapy at a freestanding ABA clinic — those laws cover emergencies and in-network facilities. Worse, Texas's protections have a written-consent exception, and ABA clinic intake packets routinely include exactly that consent form. Signing it waives protection you may not know you had. Read intake paperwork for the words "out-of-network" and "balance bill" before signing, and ask what happens if your insurance pays less than billed.

5 · The prior-authorization file

Every carrier requires prior authorization for ABA, and the family that walks in with the file complete gets authorized weeks faster. Have these ready:

The reauthorization clock. Authorizations run out — typically every six months, sometimes quarterly. Progress data and an updated treatment plan are due each time, and clinics generally start the renewal six to eight weeks early. Put the renewal date on your own calendar too; a lapsed authorization means unpaid weeks, and the family finds out last.

For reference, the CPT codes on an ABA bill — all billed in 15-minute units:

CodeWhat it is
97151The initial behavior assessment by the BCBA (includes report-writing time)
97153Direct one-to-one therapy by a technician — the bulk of every bill
97155The BCBA adjusting the treatment protocol, often during sessions
97156Parent and caregiver training
97154 / 97157 / 97158Group-treatment variants

6 · The 2026 numbers that change decisions

The subsidy cliff is back. The expanded premium subsidies expired at the end of 2025. For 2026, above 400% of the federal poverty level — about $128,600 for a family of four — there is no premium tax credit at all, and premiums rose sharply this year. If your income sits near the line, the difference between 399% and 401% is thousands of dollars; income timing (retirement contributions, HSA contributions) genuinely matters, and is a conversation for a licensed advisor and your tax professional.

Repayment caps are gone. Starting with tax year 2026, if you underestimate your income and receive too much advance premium credit, you repay all of the excess at tax time — the old caps were eliminated. For a family with variable income, estimating conservatively is the safer direction.

Cost-sharing reductions are the quiet giant. Below 250% of the poverty level, silver plans come with reduced deductibles and out-of-pocket maximums — at or below 200% FPL, the family maximum falls to $7,000. For a family expecting a full year of ABA, a CSR silver plan is frequently worth more than any premium difference. And for high, predictable spend generally, gold plans — with lower deductibles and coinsurance — often beat cheaper bronze plans on the year's total.

7 · Questions to ask any carrier before you enroll

Get answers in writing where you can. A reference number for every call, the representative's name, and the date — it feels excessive until the week it wins an appeal.

8 · What to do next

If this guide did its job, you now know which program order to check, what your real exposure number is, and what to verify before enrolling. The step this guide cannot do is the plan-by-plan answer for your exact clinic, doctors and prescriptions against the actual 2026 plans in your county. That review is free, it is done by a licensed advisor from our Houston office — the same practice 350+ Texas companies use — and it takes three minutes to request: start the coverage review, or call 281.493.6862. Se habla español.

Hipson Investments is an insurance agency in Houston, Texas, established 1996. This guide is educational. It is not a determination of eligibility for any program, an offer of coverage, or legal, tax or medical advice. Figures are 2026 plan-year figures from public federal and Texas sources, verified August 2026; program rules change, and the current rule controls. Securities and certain advisory services offered through Ameritas — see our privacy notice and site disclosures.