LapseGuard · first-party data · as of 16 July 2026

We checked 241 BCBAs against the public records. Zero were excluded.

Most compliance vendors sell you a number designed to scare you. Here is ours instead: we ran the public records of every clinician we could find at 172 ABA practices, and not one of them was excluded from Medicaid. We think you should know that before you buy anything — including from us.

What we did find is a different problem, and it's the one that actually costs practices money.

What we checked

Between June and July 2026 we looked up every clinician named on the public team page of 172 applied-behavior-analysis practices across 46 states — 241 people in total. For each name we ran:

• NPPES — the national provider registry: does an active NPI exist under this name, is it filed under the behavior-analyst taxonomy (103K), and is it registered in the state where the clinician practices?
• The OIG LEIE — the federal exclusion list: does this person appear on it, by name and, where an NPI existed, by NPI.

Every result below is our own lookup. No estimates, no modeling, no projections.

0 of 241

Nobody was excluded. The scare is overblown.

The number the industry leads with — $25,595 per claim for billing under an excluded provider — is real, current, and strict-liability. It is also, on our sample, rare. Across 241 clinicians at 172 practices in 46 states, we did not find a single confirmed exclusion.

If a vendor tells you your roster is probably harboring an excluded clinician, they are describing something we did not observe once. We would rather tell you the number is zero than sell you a number that isn't.

58

Nineteen clinicians drew 58 exclusion-list "matches." Every single one was the wrong person.

This is the part we most want practice owners to understand, because it is where automated compliance tooling does real damage.

Matching a roster against the LEIE by name produces hits. Nineteen of our clinicians drew a total of 58 possible name matches. Every one of the 58, checked by a person against state, specialty, and NPI, turned out to be a different human being who happened to share a surname — a general practitioner in Ohio excluded in 2000, a nurse in Connecticut excluded in 1999, and so on. Not one was the clinician on the roster.

Name-matching is the easy 90% of this problem. The last 10% — deciding whether a match is the same human being — is the whole job, and it is not something we are willing to let software decide on its own.

29%

What we actually found: paperwork that doesn't resolve

69 of the 241 clinicians we checked — 29% — carried a genuine discrepancy in the public record. None of it suggested fraud. All of it is the kind of thing an auditor opens with.

148 + 69 + 22 + 2 = 241. The flag sub-counts (22 + 35 + 12) sum to 69.

Most of these have innocent explanations: a record filed under a maiden name, a clinician who moved states and never updated NPPES, a practitioner dual-licensed in two states, a taxonomy chosen years ago and never revisited. Nearly all are fixable in an afternoon — if you know about them.

Why the boring finding is the expensive one

Exclusion penalties make headlines. Recoupment takes the money.

MassHealth directed roughly $19M in recoupment across Massachusetts ABA providers this spring — six-figure demands with 30-day response windows, centered on supervision-ratio and credentialing documentation. OIG found at least $77.8M in improper fee-for-service ABA payments in Colorado, with a deficiency in 100 of 100 sampled enrollee-months; documentation, billing and credentialing were the core findings. Parallel reviews cover Indiana, Wisconsin and Maine.

Almost none of that is fraud. It is claims paid to providers whose records didn't reconcile — the same category we found on nearly a third of the clinicians we looked at. An exclusion is a rare catastrophe. A credentialing mismatch is a common, quiet, retroactive bill.

Every figure in this paragraph is sourced on our 2026 compliance numbers page, with links to the Federal Register, HHS-OIG and state agencies. Please check them.

What this sample is and isn't

We would rather state the limits than have you find them:

• It's a convenience sample, not a random one. These are practices we sourced for outreach, not a representative draw from all ABA providers.
• It skews senior. We can only check clinicians a practice publishes on its website — typically owners, founders and clinical directors. RBTs and junior staff are invisible from outside, and they're a large share of most rosters.
• "Zero exclusions" is bounded by that. It's a real finding about 241 senior clinicians. It is not a claim that no BCBA anywhere is excluded.
• Name-matching has known blind spots. Nicknames, surname changes, middle-name-in-use filings and records held under a business entity can all hide or fake a match. Our 58 false positives show the error runs in both directions.
• A public-record check is not a background check. These reports are for compliance verification only — never for employment decisions.

Published by LapseGuard, a service of Raserv Enterprises LLC, on 16 July 2026. Figures are from our own lookups against NPPES and the HHS-OIG LEIE between June and July 2026 and are accurate as of the date checked; public records change continuously, and our dataset grows as we check more practices. This page is general information, not legal advice. No individual clinician is identified here, and no finding on this page should be read as an allegation against any person. Questions or corrections: ram@getlapseguard.com.