What Michigan DIFS Says About ABA Limits
The Department of Insurance and Financial Services publishes consumer guidance on autism coverage. Its list of prohibited limits is broader than the statute’s text.
The regulator’s list
Prohibited limits
DIFS says insurers are prohibited from subjecting coverage to age limits, limiting the number of visits, denying coverage as educational or habilitative, applying annual dollar limits, and imposing cost sharing stricter than for other medical care.
ABA is habilitative
DIFS says ABA is categorized in Michigan’s essential health benefits as a habilitative service, which helps a person keep, learn or improve daily living skills.
Who the guidance covers
All individual plans on and off the Marketplace and fully insured group policies issued in Michigan. Self-funded plans are not required to provide autism coverage.
What is allowed
Insurers may use reasonable medical management, including medical necessity review, case management, and restricting services provided by family or household members.
Back to the ABA guide.
What Michigan DIFS Says About ABA Limits: short answers
Does DIFS say there is no age limit?
Its consumer page lists subjecting coverage to age limits among prohibited limits. The statute’s text says an insurer may limit coverage through age 18. Ask the carrier which it applies.
Why does the guidance differ from the statute?
We have not seen the two reconciled. Federal essential health benefit rules may explain the stricter message for individual and small-group plans, which is our reading and not the state’s statement.
Who can I contact at DIFS?
DIFS lists a toll-free line, 877-999-6442, and takes complaints online, by email, fax or mail.
What Michigan DIFS Says About ABA Limits: not legal advice. Send us your renewal.
Where these details come from
The laws and rules named on this page link to the official text. This is general information, not legal advice, and rules change, so check the current text.
DIFS: Autism Spectrum Disorder Health Coverage
MCL 500.3406s, Insurance Code of 1956
Michigan House Fiscal Agency: Autism Spectrum Disorder fiscal forum
Send us your renewal.
We’ll tell you whether it looks competitive, where we see opportunity, and the five questions we’d put to your carrier. No cost, and no obligation to move anything.
The renewal letter
Your current plan summary
Contribution split by tier
Enrolled counts by tier
Four documents — two more if your group is 50 or more. Nothing else; every extra one is a reason to postpone.
An independent employee benefits consulting firm. We look at the entire benefits program: cost, plan performance, risk and administration.
Switch to CFH. Unhappy with your broker? Your employees won’t notice. You will. →