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Can I Use FES-UA for ABA Therapy? Approved Providers and Invoices Explained

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By the Hope Center clinical team · Clinically reviewed by Aisha Albright-Jourdan, MSW, LCSW, BCBA · Updated October 20, 2026 · Facts current as of October 20, 2026

The short answer

Yes. Florida's FES-UA scholarship (s. 1002.394) can pay for applied behavior analysis from an "approved provider": one approved by the Agency for Persons with Disabilities, a health care practitioner under s. 456.001, an FDOE-approved s. 1002.66 provider, or a Florida hospital. Step Up pays providers directly only after services are rendered, or reimburses you if invoices on letterhead show the provider's name and license number.

Florida's Family Empowerment Scholarship for Students with Unique Abilities (FES-UA) can pay for applied behavior analysis. But the money can only go to an "approved provider," and Step Up For Students, which runs the scholarship, has specific rules for how providers get paid and what invoices must show. This guide explains the three approved-provider routes in the statute, the two ways to pay, the invoice checklist, and the questions to ask any ABA provider before you count on scholarship funds. For eligibility, amounts and the trade-offs of taking the scholarship, start with our FES-UA explainer.

Does FES-UA cover ABA?

Yes. Section 1002.394(4)(b)3, Florida Statutes, lists among authorized uses: "Specialized services by approved providers or by a hospital in this state which are selected by the parent. These specialized services may include, but are not limited to: a. Applied behavior analysis services as provided in ss. 627.6686 and 641.31098." Step Up's 2026-27 FES-UA Family Handbook (last modified September 16, 2026) lists applied behavior analysis under specialized services, payable by direct pay or reimbursement.

Who counts as an "approved provider"?

Section 1002.394(2)(a) defines it:

"Approved provider" means a provider approved by the Agency for Persons with Disabilities, a health care practitioner as defined in s. 456.001, or a provider approved by the department pursuant to s. 1002.66.
The routes to "approved provider" status for specialized services
RouteWhat the statute saysWhat it means for ABA
APD-approved provider"a provider approved by the Agency for Persons with Disabilities"Some ABA providers hold approval through Florida's Agency for Persons with Disabilities. Ask the provider for documentation.
Health care practitioner"a health care practitioner as defined in s. 456.001"Section 456.001(4) lists people licensed under named chapters, such as psychologists (chapter 490) and clinical social workers, marriage and family therapists and mental health counselors (chapter 491). Behavior analysts are not on that list because Florida certifies them through s. 393.17 rather than licensing them.
FDOE-approved under s. 1002.66"a provider approved by the department pursuant to s. 1002.66"Section 1002.66 is the Specialized Instructional Services program for VPK. Providers on FDOE's approved list for that program fit this route.
Florida hospital"or by a hospital in this state"ABA delivered by a Florida hospital program.

Which route a given ABA agency uses, and how Step Up treats sessions delivered by an RBT under a BCBA's supervision, is something to confirm with the provider and with Step Up. We could not confirm Step Up's vetting rules for RBT-delivered hours from its published handbook, so ask before services start.

How can scholarship money reach the provider?

The handbook describes two routes for services such as therapy:

  • Direct pay through EMA. Providers who want direct billing "must set up a provider account in EMA and submit a service catalog." Families find them through "Find Providers" on the EMA Marketplace. The handbook adds: "Requests for payment directly to a provider may only be approved after the service has been rendered."
  • Reimbursement. You pay the provider yourself, then submit proof of payment and an invoice that meets the handbook's documentation rules. Reimbursements "cannot be approved for amounts that are higher than your available balance."

Two cautions from the handbook. First, "Schools and providers cannot request or use your EMA login credentials," and letting anyone else access your account "could result in the loss of the scholarship." Second, reimbursement requests for cash purchases from private sellers "that are not affiliated with a company or institution," which the handbook says includes private therapists, "will be denied."

What must an ABA invoice show?

For specialized services, the handbook says the invoice or receipt "on business letterhead must include":

  • the scholarship student's first and last name;
  • the time period of service rendered (for example, a date range);
  • the type of service rendered;
  • the amount due for the service;
  • the first and last name of the service provider who rendered the service;
  • the service provider's license number; and
  • the method of payment, with proof of payment.

It warns: "If the invoice includes medical billing codes rather than the type of service rendered, it may result in delays in processing." Insurance-style statements that only show CPT codes may need to be rewritten as plain service descriptions. The handbook also says "The provider's name on the invoice or receipt must match their submitted credentials," and costs must be broken down, including taxes and fees.

Proof of payment can be a receipt with the full transaction date and amount, or an invoice marked paid in full or showing a zero balance.

Questions to ask any ABA provider

Use this checklist before you plan your budget around the scholarship:

  1. Which approved-provider route do you qualify under (APD approval, a s. 456.001 health care practitioner, FDOE approval under s. 1002.66, or a hospital)? Can you show documentation?
  2. Are you set up for direct billing in Step Up's EMA Marketplace, or will I need to pay and request reimbursement?
  3. Can your invoices meet the handbook's specialized-services list, including the rendering provider's name and license number, on letterhead, with a plain description of the service?
  4. How will sessions delivered by an RBT be shown on the invoice, and has Step Up accepted that format?
  5. Will you bill my health insurance for any of the same services? (Ask Step Up how it treats services insurance also pays for.)
  6. Can you give me a written estimate of monthly costs so I can check it against my available balance?

A firm rule applies to every provider: the statute treats a parent "accepting any payment, refund, or rebate, in any manner, from a provider of any services" paid by the scholarship as fraud or abuse that can end eligibility.

Step by step

  1. Confirm your child's scholarship is active and check the available balance in EMA. New 2026-27 applications are accepted through November 15, 2026; see the FES-UA deadline guide.
  2. Check the Purchasing Guide. Step Up says "items or services approved in the past may not be approved currently." Use a pre-authorization request if you are unsure.
  3. Ask the provider the questions above and keep their answers in writing.
  4. Choose direct pay or reimbursement. For direct pay, reserve funds for the provider in the EMA Marketplace. For reimbursement, pay and keep receipts.
  5. Review every invoice against the checklist before submitting it.
  6. Keep copies of invoices, receipts and approvals for your records.

Step Up's family phone line, listed in the handbook, is 1-877-735-7837.

Is Hope Center an approved FES-UA provider?

We have not confirmed Hope Center's FES-UA approved-provider status, so we do not state it here. If you are planning to use scholarship funds, ask us directly, and confirm with Step Up For Students before services start. Many families use health insurance as the main way to pay for ABA; Hope Center works with Florida Blue, Aetna, Cigna (Evernorth), UMR, Personify Health and TRICARE East, offers a free benefits check, and offers self-pay for all services with a sliding scale. To talk about your options, contact us or call 561-337-8865.

Common questions

Can I use FES-UA to pay my insurance copays for ABA?+

The statute and handbook describe paying approved providers for specialized services; they do not address copays specifically. Ask Step Up For Students how it treats charges for services your health plan also pays for before you submit them.

My provider is a BCBA. Is that enough?+

The statute's routes do not name behavior analyst certification on its own. BCBAs are certified, not licensed under the chapters listed in s. 456.001, so a provider may need another route, such as APD approval. Ask the provider which route applies and confirm with Step Up before relying on it.

How long do reimbursements take?+

We did not find a fixed reimbursement processing time in the handbook sections we reviewed. Submit complete invoices with plain service descriptions, not just billing codes, to avoid delays, and check the request status in your EMA account or call Step Up.

Can I switch ABA providers mid-year?+

The handbook does not limit you to one therapy provider. Any new provider has to meet the approved-provider rules and invoice requirements, so ask them the same questions before you start, and check your remaining balance.

This guide is general information for Florida families, not medical, legal or financial advice for your child. Laws, plan rules and program amounts change; check with your plan, the agency named, or a Florida attorney before you act.

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