Billing Errors and Documentation: What Recent OIG Audits Reveal About Applied Behavior Analysis (ABA Therapy) Revenue Cycle Risk

Billing Errors and Documentation: What Recent OIG Audits Reveal About Applied Behavior Analysis (ABA Therapy) Revenue Cycle Risk

Presented by Sarah Schmitz, Amber Broadway, & Katherine Wooten

Wednesday June 24th, 2026
10am PT / 11am MT / 12pm CT / 1pm ET

This program is scheduled for 60 minutes and is valid for 1 CHBME credit.

Member Price: $49.00
Non Member Price: $99.00

Description:
Recent audits by the Office of Inspector General (OIG) have identified significant improper payments tied to documentation deficiencies and billing errors across multiple Medicaid programs. These findings highlight ongoing vulnerabilities within the revenue cycle, particularly when services are billed without sufficient documentation to support medical necessity, service delivery, or provider qualifications.

For example, recent OIG audits found millions of dollars in improper Medicaid payments related to Applied Behavior Analysis and related services when claims lacked adequate documentation or failed to meet federal and state requirements. In one audit, a state was found to have made at least $45.6 million in improper payments for services that did not fully meet documentation or program requirements.

This session will examine trends identified in recent OIG audits and work plan initiatives, focusing on how documentation deficiencies translate into billing errors, claim denials, and audit exposure. Attendees will learn how common documentation gaps—such as incomplete treatment records, missing provider credentials, and unsupported services—create compliance risks across the revenue cycle.

Participants will gain practical strategies to improve documentation oversight, strengthen internal billing controls, and align billing practices with payer and regulatory expectations. The session will provide actionable tools for billing professionals, compliance teams, and practice managers seeking to reduce audit risk while improving reimbursement accuracy.

Learning Objectives:
Course participants will be able to:

• Identify documentation deficiencies cited in recent OIG audits.
• Explain how documentation gaps lead to improper payments and billing errors.
• Implement revenue cycle controls to reduce documentation-related denials and audit risk.
• Strengthen collaboration between providers and billing teams to ensure compliant documentation.

Speaker Bio:
Sarah Schmitz, CPB-I, CMRS-I, CPB, CPC, is a nationally recognized expert in Applied Behavior Analysis(ABA) revenue cycle management, medical billing, and healthcare compliance. She discovered her passion for medical billing over 20 years ago, graduating at the top of her class with Magna Cum Laudehonors from the American Academy of Professional Coders.

After her son was diagnosed with autism, Sarah shifted her focus to understanding therapies supporting children on the spectrum. When her provider stopped accepting her insurance, she identified a critical gap: strong clinical providers often lacked the expertise to navigate complex insurance systems.

In 2014, she founded Comprehensive Billing Consultants, now a nationally recognized billing, consulting,and credentialing firm serving ABA providers across the U.S. In 2025, the company was named Top Autism Billing Company of the Year. Through her work, Sarah helps organizations strengthen revenue cycle operations, improve compliance, and navigate audits and payer requirements.

Sarah is the founder of the ABA Revenue Cycle Management Conference, the first event dedicated exclusively to ABA RCM, bringing together over 222 professionals to advance reimbursement best practices. She also developed the ABA Billing Boot camp and provides on-site and virtual training to build strong, compliant billing teams.

She serves on the Autism Commission on Quality (ACQ) Standards Committee, contributing to national accreditation standards that promote quality and accountability across ABA organizations.

Her work is deeply personal—many members of her team, including Sarah, have family members on the autism spectrum—driving the mission to support providers helping children grow and thrive.

Sarah is also co-author of Revenue Cycle Management for Applied Behavior Analysis, a widely used resource for strengthening billing and reimbursement practices.

Amber Broadway has over 25 years of healthcare experience and serves as Director of Operations atComprehensive Billing Consultants (CBC), where she supports ABA providers in navigating billing and compliance. A member of CBC’s leadership team since 2017, she leads billing operations, payer strategy,and internal SOP development.

Amber is a Certified Medical Reimbursement Specialist (CMRS) and Certified Professional ComplianceOfficer (CPCO), and serves as CBC’s Compliance Officer. She helped lead CBC’s HBMA accreditation for Excellence in Compliance.

She is known for her expertise in ABA revenue cycle management, leads CBC’s ABA Billing Boot camp,and consults nationally with providers. Amber has presented for CASP, VABA, Autism New Jersey, and the Autism Law Summit, and serves as Co-Chair of the ABA RCM Conference.

Katherine Wooten is an executive-level consultant with over 20 years of experience in clinical services and managed care leadership. She partners with ABA and behavioral health organizations to develop innovative strategies that enhance client outcomes, optimize operations, resolve payer relationship challenges and maximize revenue. With deep expertise in the managed care landscape, Katherine combines strategic insight with practical, results-driven solutions to help organizations achieve meaningful, measurable impact.