Michigan’s House Bill 5044 (HB 5044) would require every school district, intermediate district, and public school academy to adopt a policy that lets students receive medically necessary treatment in the school setting when ordered by a private health care specialist. For families and providers, that sounds like a clear win: less missed class time, more treatment where behavior happens, and fewer blanket refusals from schools that currently say, “we don’t allow outside providers.”
But if you run an ABA company, you know the second question is the one that keeps the lights on: who pays? Many funders still refuse to...
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reimburse ABA in schools, and some also deny goals they view as “educational.” This bill may open doors inside schools, but it doesn’t guarantee payment once you’re in the building. Below is what HB 5044 actually does, what it doesn’t, and what it means for your operations and billing teams.
What HB 5044 Actually Does
The text of HB 5044 (introduced September 24, 2025) amends Michigan’s Revised School Code by adding Section 1178b. It focuses entirely on district policies—not insurance coverage.
- Policy required by July 1, 2026: Each district or public school academy must adopt a written, publicly available policy allowing students to receive medically necessary treatment in school when prescribed by a licensed health care provider.
- Procedural requirements: The policy must explain how private providers can observe or deliver treatment in school, how collaboration with teachers occurs, and how parents are notified of rights under Section 504 and the ADA.
- Meetings and timelines: When a family requests school-site care, the district must meet within 30 days with the parent, relevant staff, and any health personnel to determine feasibility. If the request doesn’t create an undue burden or fundamental alteration, it must be approved.
- Appeals and reporting: Parents must be told how to appeal denials. Beginning July 1, 2027, districts must report yearly how many requests they received, how many they approved or denied, and why.
Importantly, “medically necessary treatment” is defined broadly—it includes a medical device, a therapy, or “person-implemented treatment, including applied behavior analysis.”
What HB 5044 Does Not Do
HB 5044 does not compel insurers to cover ABA delivered in school settings. There is no language in the bill amending Michigan’s Insurance Code or directing any payer—commercial or Medicaid—to reimburse services provided at school. It’s an access bill , not a reimbursement bill.
So yes, a student may now be able to receive ABA sessions in their classroom, but if their insurer excludes school as a place of service, the claim will still be denied. Providers must treat HB 5044 as permission to enter, not a guarantee of payment once inside.
Why This Still Matters for ABA Practice Owners
From a clinical and ethical perspective, this bill supports generalization—the idea that skills should be taught where they actually occur. For ABA Business Owners, it could reduce transportation costs and scheduling headaches, and it might even make collaboration with educators smoother.
But it also raises compliance and billing questions. Providers will need to double-check payer contracts, ensure documentation clearly distinguishes medical necessity from educational support, and avoid delivering services that overlap with IEP obligations. The new law’s benefits are real, but only if your billing workflow keeps up.
Funding Reality: Many Payers Still Don’t Cover ABA in Schools
Across the country, most Medicaid managed care organizations and several commercial insurers restrict or prohibit ABA in school settings. Typical policies include:
- Place-of-service exclusions: Some explicitly list “school” (POS 03) as a non-covered site for ABA, regardless of medical necessity.
- Educational overlap clauses: Services that duplicate or support IEP goals are denied as the district’s responsibility under IDEA.
- Coordination-only coverage: A few plans will pay for observation or consultation in schools but not for direct treatment.
In Michigan, the state’s autism insurance mandate ensures that ABA is a covered benefit in general, but insurers retain broad discretion to define “covered settings.” Nothing in HB 5044 overrides that discretion.
Why the Law Could Still Help
Even without guaranteed reimbursement, HB 5044 could simplify logistics for medically necessary services. Districts would finally have a consistent process for allowing clinicians on campus. That clarity can reduce wasted time negotiating access and prevent disruption of medically prescribed care.
For example, if a BCBA determines that elopement only occurs during transitions between classes, a district policy built under HB 5044 could let treatment happen where the risk occurs—without months of red tape. Clinicians could observe, intervene, and coordinate directly with staff, benefiting both the student and the school.
How to Prepare Your Practice
- Audit payer manuals now. Create a quick-reference grid showing each payer’s rule on “school-site” or “POS 03.” Highlight exclusions, exceptions, and pre-authorization notes. Update it quarterly.
- Reinforce documentation standards. Treatment plans should emphasize clinical necessity, not academics. Frame goals around DSM-5 deficits, safety, or daily living—not reading or math. That distinction often determines reimbursement.
- Develop school access agreements (MOUs). Even if a district policy exists, you’ll still need written agreements on space use, supervision, FERPA compliance, and communication protocols. Add a school-site appendix to your ABA Employee Handbook .
- Clarify financial consent with families. Before starting school-day sessions, explain that insurance coverage may be denied and outline self-pay or district-billed alternatives if that happens.
- Engage early with districts. Offer to help shape their HB 5044 policy templates. Administrators will appreciate expert input on how to integrate clinical care without disrupting instruction.
Operational Scenarios to Expect
1. District approval, payer denial
A family wins school access under HB 5044, but your claim is denied for POS 03 or “educational purpose.” In this case, appeal with medical framing—highlight safety risks or behavioral impairments that occur only in that environment, and attach data showing why clinic-based treatment is insufficient.
2. Medicaid reimbursement through the district
Michigan’s School Services Program allows certain districts—not outside providers—to bill Medicaid for services in IEPs. If your client is Medicaid-eligible, coordinate closely with the district; otherwise, you may not get paid even when the service is medically necessary.
3. Commercial plan with limited school coverage
Some ERISA or self-funded plans allow school-site ABA when strictly medical and pre-authorized. Verify the plan type, secure written confirmation, and document the need for in-situ treatment. These exceptions are rare but valuable.
Will HB 5044 Ever Lead to Coverage?
Possibly—but only if legislators follow with a second step: a companion bill amending Michigan’s Insurance Code to prohibit denials solely because a service is delivered at school. As of the current version, HB 5044 contains no such language.
That means ABA owners should advocate for follow-up legislation once districts report data on requests and denials. When families can show that medical services are being allowed but still unpaid, that data becomes leverage for payer accountability.
What to Watch Next
- Amendments: If committee discussions add insurance or Medicaid references, that would change the landscape.
- District implementation: Policies are due by July 1, 2026. Expect a learning curve as districts figure out supervision, credentials, and space.
- Annual reports: Beginning in 2027, those reports will reveal how many requests are made and denied. They could become a tool for future advocacy.
Bottom Line for ABA Business Leaders
HB 5044 is a meaningful access reform. It removes one layer of bureaucracy that kept many students from receiving medically necessary care at school. But from a business perspective, it changes nothing about reimbursement. Insurers still control whether ABA in schools is covered, and most continue to exclude it. Treat this law as an access lever —a door opener, not a financial guarantee.
Now is the time to tighten your payer policy tracking, reinforce medical documentation, and collaborate with districts preparing their new policies. The practices that plan ahead will be ready to deliver care ethically and sustainably the day HB 5044 takes effect.
Sources
- Michigan Legislature — HB 5044 introduced bill text (2025)
- Michigan School Services Program (Medicaid) — https://www.michiganallianceforfamilies.org/medicaid-reimbursement/
- Michigan Department of Education — Autism Insurance Fact Sheet
- Michigan Department of Health and Human Services — School Services Program Policy Bulletin
