Facts, Not Narratives: The Reality for Responsible Providers

At the recent “This Is Medicaid” event, MAC Midwest Chief Compliance Officer Jen Diederich spoke about what Medicaid integrity looks like from the perspective of a nonprofit provider serving hundreds of Minnesota families. Her remarks address recent public narratives, clarify the realities providers are facing, and reaffirm our commitment to responsible, accountable care. We invite you to watch her message and read the full context below.

My name is Jen Diederich, and I serve as the Chief Compliance Officer of MAC Midwest, formerly Minnesota Autism Center. We are a nonprofit organization with 18 locations throughout Minnesota, serving families in both metro and greater Minnesota communities.

For 30 years, MAC Midwest has provided a full continuum of mental health services and in-home and center-based autism services. Today, hundreds of children and families rely on us for medically necessary care.

Medicaid Integrity Matters — and Providers Agree

The autism provider community understands the importance of Medicaid integrity. Responsible, trusted providers support clear standards, accountability, and oversight.

In fact, our field has supported — and even led — efforts to strengthen regulation. We worked alongside legislators to establish state licensure for Board Certified Behavior Analysts (BCBAs), which went into effect last year. Provisional agency licensure begins this year, with permanent licensure to follow.

Across Minnesota, providers have invested heavily in:

• Compliance infrastructure

• Internal auditing systems

• Strengthened supervision ratios

• Updated documentation and billing practices

These investments reflect a shared commitment to ethical, accountable care.

Addressing a Harmful Narrative

During a February 23 House committee hearing, a statement was made that only 6 of approximately 500 unlicensed autism treatment centers had applied for the new mandatory state license. The implication was that perhaps others had not applied because they were fraudulent.

That narrative is not only inaccurate — it is harmful.

Here is our reality.

MAC Midwest is a nonprofit. We operate on razor-thin margins. At the end of December, a Medicaid prepayment review process went into effect. As a result, we were not paid the full amount owed to us for two revenue cycles. That created a significant financial shortfall.

At the same time, we made a clear commitment:

• We would not discharge clients — approximately 300 receiving center-based services and another 300 receiving assessment services annually.

• We would not lay off staff — approximately 550 professionals who show up every day to support Minnesota families.

To sustain operations, we secured a line of credit and cut all non-essential expenses.

The Financial Reality of Compliance

Within this already strained financial environment, we were required to:

• Revalidate all 18 of our locations

  • Hundreds of pages of documentation

  • $700 per location, totaling $12,600 within 30 days

• Apply for provisional licensure before May 31

  • Extensive administrative documentation

  • $1,200 per location, totaling $21,600

Between February and the May 31 deadline, that represents nearly $35,000 in fees alone, not including the administrative labor required to complete the applications.

For a nonprofit provider that had just experienced interrupted Medicaid payments, those costs are significant.

We completed revalidation. We are proceeding with licensure. But we are doing so in a phased manner — not because we are fraudulent, but because we must responsibly spread those costs across revenue cycles in order to ensure payroll stability and continued care.

That is not avoidance. That is financial stewardship.

What EIDBI Really Is

Early Intensive Developmental and Behavioral Intervention (EIDBI) is not:

• An enrichment program

• A daycare service

• PCA services

EIDBI is a prior-authorized, medically necessary Medicaid service. It is delivered through evidence-based, scientifically validated interventions under the supervision of licensed professionals.

The children we serve are not casually enrolled. Many cannot safely attend traditional school settings. In fact, schools often refer families to us because their needs exceed what schools can provide.

Without access to EIDBI services:

• Some parents would be forced to leave the workforce.

• Some children would regress without structured support.

• Emergency rooms — already understaffed and overburdened — could become the last resort.

This is not theoretical. It is the lived reality of Minnesota families.

Keeping the Focus Where It Belongs

Minnesota’s children with autism deserve access to medically necessary treatment delivered by accountable providers under clear and enforceable standards.

We support strong standards.
We support oversight.
We support Medicaid integrity.

What we ask is that the conversation remain grounded in facts and focused on people — not politics.

Because at the end of the day, this is Medicaid.

And Medicaid, when it works as intended, keeps children safe, families stable, and communities strong.