Approximately one in 68 children has been identified with autism spectrum disorder (ASD). In July 2014, the Centers for Medicare and Medicaid Services (CMS) issued a letter to state Medicaid directors advising that treatment for ASD should be considered covered under the Early and Periodic Screening, Diagnostic, and Treatment (EPSDT) benefit. Historically, treatment of ASD has been confined to Medicaid waivers. The main emphasis of CMS’s guidance encourages each individual state to submit a state plan amendment, detailing how it will provide ASD treatment services. From a fiscal and rate-setting perspective, there are numerous challenges with the CMS guidance on ASD treatment.