ABA Self-funded plans under section 1557

[justasking]

I am familiar with the new regs about adding ABA to all fully insured plans. Our self-funded plan currently offers some ABA therapy for speech, etc. However, we don't cover the full ABA treatments such as diagnosis, therapy, etc. since it would cost the plan $500,000-$1,000,000 a year for mid size company. In your professional opinion, could this be treated like OT/PT with number of visits being limited (20 visits a year) or maybe some other kind of other limit? Also can we limit it by age such as for children 5 and under since they would get free services through public schools (depending on the state)?