The Quiet Tech Wave About to Hit ABA Therapy and How Small Practices Can Prepare (Before It Hits Hard)

If you own or run a small ABA practice, you already juggle a lot like staffing, scheduling, parent communication, billing, compliance, fires that appear out of nowhere, and the occasional “Why does this insurance portal hate me?” moment.

But there’s another challenge coming. And it’s a big one.
It won’t show up like a crisis at first. It won’t feel urgent today.
But by 2026, it will change how ABA practices handle data, technology, EHRs, patient records, insurance workflows, interoperability, and security.

This change comes from federal rules: ONC’s HTI-1, USCDI v3, FHIR/SMART v2 APIs, Decision Support transparency, information-blocking enforcement, and the rise of TEFCA, a nationwide system for exchanging patient data across states, health systems, and payers.

And yes - this absolutely affects small ABA clinics, not just hospitals and giant health systems.

But here’s the good news: If you understand what’s coming now, you’ll be miles ahead of other providers… and you’ll save time and money, avoid panic upgrades, and protect your business from surprise compliance risks later.

Let’s break this down in plain English - without the tech jargon headaches.

What is an HIE (Health Information Exchange)?

An HIE is a secure, statewide or regional network that allows healthcare organizations to share patient information with one another.

Think of an HIE as a digital highway that connects:

• hospitals
• pediatricians
• family doctors
• behavioral health providers
• labs
• pharmacies
• long-term care
• state public health agencies

An HIE helps these groups send and receive patient data safely and quickly.

In ABA language:

An HIE is the system pediatricians will expect you to use when they say:
“Can you send me Johnny’s treatment plan?”
or
“We need his latest eval for coordination of care.”

What HIEs do:

• move records between providers
• reduce paperwork and faxing
• support continuity of care
• help during emergencies (e.g., ER visits)
• allow public health reporting
• help states track care quality and outcomes
• plug organizations into TEFCA (the nationwide network)

Why HIEs matter specifically for ABA providers

Most ABA practices aren’t connected today — but that is changing fast because:

• many states now require HIE participation
• TEFCA uses HIEs as “on-ramps” to the national network
• pediatricians increasingly expect digital exchange
• paper or email-based sharing is becoming too slow
• information-blocking rules penalize delayed access
• referrals are shifting toward providers who can share data cleanly

ABA is becoming part of the larger healthcare ecosystem, and HIEs are the bridge.

What’s Actually Coming and Why ABA Providers Should Pay Attention

Think of this as the “internet upgrade” for healthcare data

The federal government (through ONC - the Office of the National Coordinator for Health IT) is updating the tech standards that EHRs, apps, and health systems must follow.

These updates kick fully into gear around January 1, 2026.
Some states are already rolling out early versions of these requirements (California, New York, NC, Nebraska, Maryland, Vermont, and more).

Here are the parts that matter most to ABA therapy:

1. USCDI v3: The new required data set for health records

This means your EHR will need to support a standardized set of data fields for every client… things like:

• demographics
• SDOH (Social Determinants of Health)
• updated sex/gender coding
• clinical notes
• care plans
• interoperability-friendly formatting

If your EHR doesn’t upgrade properly, you may lose access to insurance integrations, public health reporting capabilities, and future connections to health information networks.

2. SMART on FHIR v2 APIs: How apps plug into your EHR

This is like going from dial-up to fiber internet, but for client records.
Think:

• easier app integrations
• better connections to patient portals
• cleaner data movement to and from payers
• fewer manual uploads and downloads

If you’ve ever screamed at your practice management system because nothing talks to anything else, this is meant to fix that.

3. DSI Transparency: Your EHR must show its work

If your EHR uses algorithms (for scheduling, prediction, decision support, clinical suggestions), it must show you:

• what data is feeding the model
• how the algorithm works
• how safe, fair, and valid it is

This matters because ABA providers will need to understand whether algorithms are biased, unsafe, or misleading.

4. Information Blocking: Real penalties for not sharing data

This is a big shift.

If a provider delays, blocks, or refuses to share patient data (even accidentally, like through slow portal responses), they may face:

• financial disincentives
• compliance investigations
• problems with Medicare programs (if relevant)
• payer scrutiny
• patient complaints

Small practices who often struggle with admin bandwidth are at higher risk simply because they’re stretched thin.

5. TEFCA: A nationwide health data highway

TEFCA is a system connecting healthcare organizations across all 50 states.
You plug in through a QHIN (a Qualified Health Information Network) or your state HIE.

This affects ABA because:

• hospitals will expect you to share data
• payers will expect cleaner, faster data
• referrals may require TEFCA-level exchange
• your EHR will likely start charging for TEFCA connection fees

This is the direction healthcare is going whether we’re ready or not.

Part 2: How This Hits Small ABA Practices (the real-world impact)

Here’s the honest truth:
Most small ABA practices do not have an IT department.
They rely heavily on:

• one EHR system
• one billing system
• manual workflows
• spreadsheets
• email
• PDFs
• overworked BCBAs trying to keep everything compliant

So, when tech rules change, small ABA clinics feel it the hardest.

Let’s talk about the biggest risks.

Risk #1: Your EHR may raise prices or stop supporting your current plan

EHR vendors are already planning the upgrades they must complete by 2026.
Small vendors may:

• increase prices
• remove older plans
• sunset modules
• charge for TEFCA access
• charge for API access
• require you to upgrade storage or servers

If you don’t plan ahead, these “surprise costs” hit you at once.

Risk #2: Insurance companies will expect cleaner data

Payers are tying their own systems to FHIR and USCDI, too.
This means:

• fewer manual attachments
• fewer rejected claims
• more automated prior auth
• more “your system must match ours” requirements

Small practices that stay on old systems will feel like they’re always “behind the rules.”

Risk #3: Staff not trained on data access rules could trigger information-blocking investigations

Most information blocking is accidental.
Examples:

• a parent requests a full record… and the admin delays it
• a provider denies API access because “we don’t use apps here”
• someone “forgets” to send data to a referring pediatrician
• a cancellation leaves no one to process portal messages for a week

The scary part?
Intent doesn’t matter.
Delays can still trigger penalties.

Risk #4: Algorithms you didn’t know existed could influence care

Some ABA EHRs already use:

• predictive scheduling
• automated progress insights
• suggested goal pathways
• suggested parent responses
• risk scores

Under the new rules, you must know:

• where the model’s data comes from
• whether it has bias
• whether it’s safe
• whether it needs clinician oversight

Small ABA providers can’t ignore this anymore.

Risk #5: You’ll need new policies… fast

2026 will require updates to:

• HIPAA policies
• your WISP
• EHR access + API policies
• incident response
• vendor management
• client record release
• TEFCA participation
• algorithm transparency
• compliance training

If you don’t upgrade these policies, you’ll be out of alignment with federal expectations—and possibly with state mandates.

“But What If We Still Use Paper? Will ABA Be Required to Go Fully Digital?”

Let’s talk about something many ABA owners quietly wonder:

“We still use paper data sheets… is that going to be illegal soon?”

Here’s the honest answer:
You will not be legally required to go 100% digital on January 1, 2026.

BUT…
paper is becoming harder and riskier every single year, and the new rules will speed that up.

Let’s break this down simply.

1. You won’t be forced to stop collecting data on paper, but you will be expected to share data digitally.

The federal rules don’t ban paper.
You can still take paper notes if you choose.

But the expectation is shifting:

• Payers want digital data.
• Pediatricians and referral partners want digital data.
• Patients and parents want portal access.
• State HIEs require digital exchange.
• TEFCA connections require digital formats.

So, the collection can be on paper…
but the sharing cannot be.

This creates a new problem:
paper slows everything down.

2. If you use paper, you’ll spend WAY more time converting things into digital format later.

With USCDI v3, TEFCA, FHIR APIs, and information-blocking rules, organizations are expected to:

• respond to requests quickly
• share data in standardized formats
• send structured fields (not scanned PDFs)
• move data between systems without delay

Paper → scanner → PDF → email → upload → manual typing
won’t meet those expectations for long.

The more paper you use, the more staff time you’ll spend (and bill for!) just converting documents so your systems can actually talk to other systems.

This slows down:

• referrals
• insurance authorization
• continuity of care
• clinical communication
• audits
• legal requests
• parent access
• portal uploads

It becomes a bottleneck.

3. Information-blocking rules are where paper-based ABA clinics are most vulnerable.

If a parent requests access to their child’s record and you have to:

• find the binder
• scan 40 pages
• upload it
• redact manually
• send it through the portal
• double-check signatures
• wait for BCBA review

…that delay could be interpreted as “information blocking,” even if your intention was innocent.

Small clinics that rely on paper are statistically more likely to:

• respond slowly
• lose forms
• delay access
• send incomplete records
• struggle to provide data “on demand”

The rule doesn’t require a digital EHR, but it DOES require timely, unblocked access.

Paper creates delays by default.

4. Paper-based treatment plans will not meet future interoperability expectations.

Treatment plans that exist only in paper form:

• can’t be shared via TEFCA
• can’t be mapped to USCDI clinical fields
• can’t be sent to referrals easily
• can’t be exchanged through standardized APIs
• can’t be used by other providers’ digital systems
• can’t support automated prior authorization
• can’t pass data quality checks

You can still write them on paper…
but your system must store them digitally, in a usable format.

This is where many ABA clinics will struggle if they don’t start planning now.

5. The real shift: structured, standardized, searchable data.

The future isn’t just “digital.”
It’s digital + structured.

Meaning:

• fields
• codes
• categories
• data classes
• consistent vocabularies

Think:

“This is the client’s address”
vs.
“This is a scanned PDF that includes their address on page 2 in handwritten cursive.”

USCDI v3 and FHIR require:

• typed data
• standardized fields
• consistent formats
• exchange-ready information

Paper → PDF → upload doesn’t meet this standard long-term.

6. Paper will still exist… but as a backup, not the primary system.

Realistically?

In 2–4 years:

• session notes may still be scribbled on paper during the session
• assessments might still be done by hand first
• some signatures might still be ink-on-paper
• onboarding packets might still start as paper

BUT…

The official record, the one needed for:

• payers
• auditors
• parents
• state agencies
• data exchange
• TEFCA
• USCDI requirements
• clinical continuity

…will need to be digital, structured, and accessible.

Paper will be the “scratch pad,” not the “record.”

7. If you stay fully paper-based, here are the risks:

• slower access → higher risk of information-blocking claims
• more admin hours spent scanning and uploading
• harder payer audits
• harder prior auth processes
• more errors in client data
• incomplete documentation for investigations
• reduced credibility with pediatrics and referrals
• harder time joining your local HIE
• EHR vendors phasing out manual-upload workflows
• staff burnout from constant re-typing and re-scanning

No one will show up and take your clipboards away, but paper will quietly drain your time, money, and compliance safety.

8. You don’t need to go digital overnight - just start transitioning.

Here’s the gentle reality:

• You don’t need to throw out every binder today.
• You don’t need a brand-new EHR this week.
• You don’t need to digitize your entire history.

You do need to start:

• digitizing new clients
• building structured templates
• organizing your data fields
• cleaning up client demographics
• training staff on access timelines
• asking your EHR vendor about USCDI v3 support

This is a slow, friendly shift - not a panic moment.

Paper isn’t illegal. But the system around you is going digital, and paper won’t be able to keep up much longer. If you prepare now, you’ll save time, stress, and compliance risk later.

What ABA Practices Can Do Now (A Friendly, Doable Prep Plan)

No panic. No fear.
Just a clear, friendly roadmap.

Step 1: Ask your EHR vendor these five questions

1. When will you fully support USCDI v3?
2. When will SMART on FHIR v2 go live?
3. How will you meet DSI transparency requirements?
4. Will TEFCA participation cost extra?
5. Do you offer a 2026 readiness plan for customers?

Their answers tell you exactly how prepared you need to be.

Step 2: Update your internal policies

You’ll want updated versions of:

• Interoperability policy
• API access policy
• Release-of-Information SOP
• DSI/algorithm transparency documentation
• Information blocking procedures
• TEFCA participation policy
• HIPAA compliance plan
• Incident response policy

If this sounds overwhelming, that’s normal.
Most small ABA practices outsource this part.

Step 3: Train staff (short, friendly micro-trainings work best)

30 minutes each.

Topics:

• What is USCDI v3?
• How to help clients access their data
• What counts as “information blocking”
• What to do when a parent or pediatrician requests data
• How to report API/app issues
• How to escalate interoperability problems

Most staff just need simple checklists.

Step 4: Choose your TEFCA on-ramp

Your options:

• your EHR
• your state HIE
• a QHIN partner

You don’t need to connect today, just know how you will connect.

Step 5: Audit your current data quality

ABA data is often messy:

• inconsistent client info
• missing demographics
• mismatched sex/gender fields
• inconsistent note types
• outdated vocabularies
• no SDOH fields

USCDI v3 will require standardization.
Fixing this now saves you months later.

Step 6: Start budgeting for 2025–2026 upgrades

Expected costs may include:

• EHR plan upgrades
• data migration
• TEFCA connection fees
• API access fees
• additional storage
• consultant or compliance support
• staff training hours

Better to plan now than get hit with all of this at once.

Why This Actually Helps ABA Providers (If You Prepare Early)

It’s not all stress and compliance.
There are genuine benefits:

1. Faster, cleaner data = faster payments

Payers love structured, standardized data.
That means:

• fewer denials
• fewer “lost” documents
• fewer resubmissions
• less manual work
• smoother audits

2. Easier app integrations

Think:

• practice management tools
• parent-facing portals
• assessment apps
• scheduling tools
• care coordination apps

SMART v2 + FHIR will make this easier.

3. Better referrals and care coordination

Pediatricians, hospitals, and schools increasingly expect:

• immediate data sharing
• interoperable records
• consistent formatting

TEFCA makes your practice look more professional and trustworthy.

4. Better clinical insight

When data is cleaner, you’ll actually be able to see:

• progress trends
• dosage patterns
• outcome correlations
• scheduling impact
• caregiver involvement patterns

This is a huge win for client care.

The Real Risk for ABA Practices Who Delay

Let’s talk straight.

The biggest danger for small ABA providers isn’t the technology.

It’s waiting too long and getting hit with:

• surprise costs
• last-minute compliance rush
• broken workflows
• staff panic
• clients complaining
• payers pushing back
• investigations for accidental information blocking
• “Your system is too outdated to integrate” messages
• EHR vendors forcing expensive, rushed upgrades

This is exactly what happened to small mental health clinics during earlier EHR transitions.

Those who planned ahead survived.
Those who didn’t… struggled hard.

Where Small ABA Providers Should Start Today

Here’s a simple, no-panic plan:

1. Create a “2026 Upgrade Folder” in M365 SharePoint Drive/Google Drive

Put everything related to:

• EHR notifications
• TEFCA updates
• policy templates
• vendor emails
• data quality notes
• project plans

in one place.

You’ll thank yourself later.

2. Assign one person as your “Interoperability Owner”

Part-time is fine.
Just someone who watches the deadlines.

3. Build a “Questions to Ask Vendors” checklist

Use the 5 questions I gave earlier.

4. Start a 6-month runway for policy updates

You don’t need to rush… just plan.

5. Run one internal data cleanup project each month

Small steps → big payoff.

The Human Side - Why This Feels Scary for Small ABA Practices

“This won’t affect ABA.”

 “Why do they keep changing rules?!!!”

 “Maybe I can just ignore this for a bit…”

 “Okay… I should learn what this means.”

 “Let’s make a plan.”

You are not behind.
You are not alone.
And this doesn’t have to be overwhelming.

If you’re reading this, you’re already ahead of 90% of providers.

Final Thoughts: The Future of ABA Will Belong to the Prepared

The tech and data changes coming in 2026 are arguably the biggest shift since EHRs first rolled out.

But small ABA practices that prepare early will:

• avoid stress
• avoid penalties
• get paid faster
• coordinate care better
• strengthen compliance
• impress referral partners
• build a more modern and reliable practice

This is not a storm to fear.
It’s a wave to ride and you get to surf it ahead of everyone else.