Penguin Health
Connecticut · HUSKY · ASD services
Connecticut prosecutes ABA fraud, and its note rule is in regulation
Connecticut's ABA enforcement is criminal, not just administrative: a $1.8 million federal fraud case, a state sentence over $102,000 in false claims, and more charges in 2026. The documentation standard those cases get measured against sits in regulation: Conn. Agencies Regs. 17b-262-1063 requires a clinical progress note for each ASD treatment service, enumerates its elements, and provides recoupment when documentation is missing. The matching rule set lives in the rules library in the Penguin Health app.
DSS policy 14-07, adopted as regulation.
17b-262-1063(b)(3)(A) through (F).
The technician signs; the performing provider co-signs when present or supervising.
Federal and state prosecutions, 2024 through 2026.
The regulation
What 17b-262-1063 requires in the record
The regulation requires a clinical progress note for each ASD treatment service rendered and spells out who signs: the technician who delivered it, and the performing provider when present at or supervising the service. Supervision itself must be documented with exact time, location, and format, and records are kept five years.
- The types of ASD treatment services provided; the date and time; the length of time for each treatment; the location and type of setting; which individuals participated; and which individuals were present in the location.
- Signed by the technician, co-signed by the performing provider when present at or supervising the service.
- Documented with the caregiver's name and relationship to the member.
- Documented with the exact time, location, and format.
- Five-year retention, and recoupment for missing documentation.
- A $1.8M federal ABA fraud case, a state case over $102K with a sentence, and 2026 state charges against a third provider.
The checklist
What a Connecticut ASD note has to show
Each item below cites 17b-262-1063(b)(3) and names the Penguin rule that checks it. Connecticut sets no note-completion deadline, so none is claimed.
| The note shows | What that means in practice | Source | Rule |
|---|---|---|---|
| The types of services provided | What was delivered, named. | (b)(3)(A) | CT-1 |
| Date, time, and length per treatment matching the billing | When, and for how long, agreeing with the claim. | (b)(3)(B)-(C) | CT-2 |
| The location and type of setting | Where, consistent with the billed place of service. | (b)(3)(D) | CT-3 |
| Participants and persons present | Who took part, and who was in the room. | (b)(3)(E)-(F) | CT-4 |
| Technician signature plus co-signature | The co-signature applies when the performing provider was present or supervising. | (b)(3) | CT-5 |
| Caregiver participation with name and relationship | Or a note showing no caregiver was involved. | treatment notes | CT-6 |
In the rules library
Six Connecticut rules, ready to turn on
Open the rules library in the Penguin Health app, choose Connecticut Medicaid ASD Services, and click Add to organization. Rules your organization already has are left alone, so adding the set twice only fills gaps. After adding, edit any rule or add your own alongside them.
Each rule runs only on notes billed to Connecticut Medicaid (HUSKY) payers. Penguin checks the CentralReach payer name, so a Connecticut rule never fires on a commercial note in the same organization, and an organization whose payer names differ edits that match after adding the set.
Penguin reads signed session notes from CentralReach, read-only, after signature and before the claim, and runs the set on every note. Deterministic rules compare record fields. AI rules are read by the AI, which returns a pass or fail with a one-sentence reason.
Six rules for HUSKY ASD services under 17b-262-1063: the progress-note elements, dual signatures, and caregiver participation.
- reviewed
- Oct 26, 2026
- runs on
- Notes billed to Connecticut Medicaid (HUSKY) payers
- sources
- Conn. Agencies Regs. 17b-262-1051 to -1065 (DSS policy 14-07)
- watching
- The DSS policy document
Every failure ships with QA guidance for that program code: an educational email, numbered action steps, and a QA email pre-filled with the date of service and a link to the note. Each reviewer action is written to a write-once audit log with seven-year retention. Billing Medicaid in more than one state? The rules library covers twenty-nine, including Massachusetts and New York.
Maintained by Penguin
We watch DSS so the rules never go stale
Connecticut's rule has been stable since 2015; its enforcement has not. The Connecticut set is tied to the regulation, not to a template written once.
The DSS 14-07 policy document and the codified regulation. Penguin fetches the sources on a schedule and archives every revision.
We rewrite the affected rule, cite the document that changed it, and date the review. The set shows its sources and review date in the library.
An updated rule runs in the next scheduled validation and on demand against notes you have already reviewed, so a changed requirement shows you exactly which past notes it touches.
- The ASD payment policy takes effect
Enumerated progress-note elements and the co-signature rule, later adopted as regulation.
LibraryCT-1 through CT-6 are built against it.
- The federal ABA fraud case resolves
A $1.8M scheme against Connecticut Medicaid ends in federal pleas.
- New state charges
The Division of Criminal Justice charges another ABA provider.
- Connecticut set reviewed
Checked against the regulation. Current.
- WatchingPolicy revisions and the CTBHP layer
When DSS or its behavioral health ASO updates ASD documentation policy, the set is updated and every organization using it gets the change.
State alerts
Get an email when Connecticut changes its documentation rules
We fingerprint 56 official payer documents every week, Connecticut's among them. When one changes, a person verifies what changed and writes a short plain-language summary before anything is sent. A few emails a year, not a newsletter. Unsubscribe anytime.
Check your inbox: confirm your email and you are on the list.
You will get a confirmation email first. Watching more than one state? Pick your states here.
Next step
Run a month of Connecticut notes through Penguin
Bring one month of session notes. We add the Connecticut set from the rules library, run it, show every finding beside the source it maps to, and hand your QA lead the fix for each one. Or get a demo account and click through Penguin on your own time first.