Colorado
What the auditors found in this state's Medicaid autism-therapy spending, and who owns the clinics here. The two are shown side by side and are not joined.
This audit blames no owner, and neither does this page
The report audits Colorado's Medicaid program, not any company. It names no provider and no ownership type, and the findings apply across every ABA provider billing the state. Nothing below should be read as saying private equity caused any part of it. The two facts are published together because they describe the same market, not because one explains the other.
The audit
Colorado Made at Least $77.8 Million in Improper Fee-for-Service Medicaid Payments for Applied Behavior Analysis Provided to Children
U.S. Department of Health and Human Services, Office of Inspector General · report A-09-24-02004 · issued 2026-02-25 · payments examined: 2022-2023
- Every one of the 100 sampled enrollee-months contained at least one improper or potentially improper claim line.
- Payments for care delivered by behavioral technicians who were not credentialed as required.
- Billing for time that may not qualify as ABA therapy, including recreation, day care, custodial care, meals, breaks and naps.
- Session notes that did not support the billed CPT codes.
The report also records how fast this spending grew: $60.1M in 2019 to $164M in 2023. That growth is the reason the programme is being audited at all, and it is the same growth that made the sector attractive to buyers.
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Who owns the clinics in Colorado
| Brand | Owner | Clinics |
|---|---|---|
| Action Behavior Centers | Charlesbank | 40 |
| Trumpet Behavioral Health | KKR | 10 |
| Behavioral Innovations | Tenex Capital Management | 8 |
| Blue Sprig | KKR | 3 |
| Monarch Behavioral Therapy | Tenex Capital Management | 3 |
| ACES 2020 | General Atlantic | 2 |
| Autism Learning Partners | FFL Partners | 1 |
Measured against the federal registry, private equity holds 7.8% of Colorado's 688 ABA locations. That share is a floor, for the reasons in the methodology.
Of the 67 clinics above, the federal provider registry can see 54. The rest appear only in the operators' own published directories. An auditor or a regulator working from federal data alone would not know the others exist, which is the practical case for ownership transparency and is documented in full on the reconciliation page.
The largest finding in the series, in the state with our largest tracked private-equity footprint outside Texas.