| Legal basis | State mandates (2001-2019) + CMS EPSDT guidance (2014); dual structure of state law and federal guidance | OAP program guidelines (financing) + behavior-analyst regulation act (workforce); guideline-statute asymmetry | NDIS Act (2013); single federal statute | No specific legislation; universal service rights within general health/education law | Developmental rehabilitation services and behavioral development grounded in statute, but ABA not specified as a statutory service |
| Financing | Private-insurance mandate + Medicaid; ERISA self-funded plans may be exempt from direct application of state mandates | Needs-based family allocation from provincial tax revenue | Joint federal-state tax financing; individual budgets | Tax-based public health/education financing | Tax-based vouchers (income-differentiated co-payment) + state subsidy program; no ABA-specific insurance benefit or activity code |
| Coverage & intensity | Medical-necessity criteria; individualized authorization based on treatment plans and payer/state rules; service intensity varies by state and payer | Under 18, needs-based allocation; funding-allocation delays and waitlists noted | Reasonable-and-necessary individualized determination; early-childhood pathway under age 9; phased introduction of Thriving Kids from 2026, with NDIS access changes planned for 2028 | EIBI within habilitation; regional variation a persistent challenge | Under 18, use within monthly benefit ceiling; low relative to recommended intensity |
| Workforce credentialing | BACB private certification (BCBA-BCaBA-RBT) + state licensure; certification-benefit linkage | Mandatory college registration; only registered behavior analysts provide/supervise | No national licensure; suitability recognition of registered behavior-support practitioners + PBS Capability Framework | Nationally licensed vernepleiere + university-based behavior-analytic curricula | No national qualification; notice-level qualification recognition based on prescribed coursework + coexisting private certifications; new BCBA acquisition restricted since 2023 |
| Service delivery & quality management | CPT codes (97151-97158) claims/review; OIG audits | Independent intake (AccessOAP); college ethics/discipline regulation | Registered and unregistered providers coexist, but specialist behavior support requires provider registration, practitioner suitability, practice standards, and reporting | Direct public provision; NAFO academic exchange and professional development; Nordic joint professional-recognition discussions | Municipally designated providers and behavioral development centers; absence of a national quality-management system (staffing/supervision standards, treatment fidelity) |