Tier 2 — BACB Regulatory Track: Congress, FTC & DOE Referrals (21.7% NOT FOUND Rate)

Author: Minnesota Medicaid Transparency Project | Last updated: May 19, 2026

814 Minnesota NPPES-enrolled ABA providers cross-checked against the BACB public registry: 177 (21.7%) NOT FOUND. The BACB — sole national credentialing body for BCBAs, BCaBAs, and RBTs — provides no machine-readable API for real-time credential verification. Four certified first-class referral letters sent May 19, 2026 to Senate HELP Committee, House Education & Workforce Committee, Federal Trade Commission, and DOE Office of Special Education Programs documenting the structural verification gap and requesting legislative, regulatory, and competition-policy intervention.

Part of the Minnesota Medicaid Transparency Project — an independent, data-driven investigation of $23 billion in annual Medicaid spending across 87 counties.