Important Information for Documenting and Billing for Applied Behavior Analysis Services
Documenting Applied Behavior Analysis (ABA) Services
In the participant’s record, providers must note the exact start and stop times for each ABA service. Writing "8:00 AM to 4:00 PM (32 units)," sometimes referred to as ‘block billing,’ without showing breaks, makes it appear that you billed for naptime and lunch. Providers should clearly subtract all non-therapy time (e.g., naps, meals, routine bathroom breaks).
If therapy stops, the billing clock stops. Units billed must match the total time of providing services based on the exact start and stop times documented in the participant’s record.
Billing ABA Services
The MO HealthNet Division (MHD) only pays for active, face-to-face behavioral assessment, treatment, and caregiver treatment guidance. Some codes include necessary non-face-to-face with the client work: 97151 covers data analysis and report/plan preparation, and 97156 is delivered face-to-face to caregivers with or without the client present. What is never billable is time when no service is being delivered. This resource covers accurately documenting billable time and is not intended to cover all adequate documentation requirements. Failure to adequately document services, including subtracting non-billable time from units billed, may result in post-payment recoupment. Routine childcare, resting, and standard daily routines are not billable unless they are part of a specific assessment goal or individualized Behavior Intervention Plan (BIP) protocol.
Below are tips for providers billing ABA services:
- Naps and sleeping are never billable. If enuresis is being treated, bill only for time the BIP protocol is being actively delivered, not for time between trials when the child is sleeping.
- Free play and ‘down time’ (e.g., waiting periods, transitions, administrative paperwork) are never billable.
- Meals and snacks are billable only when covered ABA services are actively being provided for a specific assessment or BIP goal.
- Toileting and hygiene are only billable with a specific assessment or BIP goal.
- Arrival and departure time – conversations with caregivers during drop off/pick up are only billable if the behavior analyst or assistant behavior analyst is providing guidance, not just providing a status update.
- Rounding each small session up before adding them together overbills for services. Sum all active minutes for a given procedure code from the entire day first, then perform a single unit conversion.
- Providers should add up all billable minutes for the procedure code for the entire day. They should then convert the total net active minutes into 15-minute units and submit one single line with the total daily units per procedure code on the claim. Submitting multiple lines for the same procedure code on the same day will cause the claim to be denied as a duplicate claim in eMOMED.
- Recording trial-by-trial data while delivering a BIP protocol is billable, but time spent completing a progress note after a session has ended is not billable.
Below is an example of a six-hour day that would result in billing 18 units (270 minutes) of 97153 on one single line of the claim.
| Time | Activity | # of Minutes | # of Units |
| 8:30 AM - 11:30 AM | Direct 1-on-1 ABA therapy targeting communication and social goals | 180 Billable Minutes | 12 units |
| 11:30 AM - 12:00 PM | Lunch (Routine feeding; no active behavioral targets) | 30 Non-Billable Minutes | N/A |
| 12:00 PM - 1:00 PM | Nap time / quiet rest | 60 Non-Billable Minutes | N/A |
| 1:00 PM - 2:30 PM | Direct 1-on-1 ABA therapy targeting daily living and focus goals | 90 Billable Minutes | 6 units |
Note: 97153 is used in the above example, but the rule applies to all ABA codes. In addition, if a Behavior Analyst provides concurrent protocol modification (CPT 97155) during part of this session (e.g., 1:00 PM – 2:00 PM), the behavior analyst must document their own discrete start/stop times in the participant record and bill their units on a single, separate line under CPT 97155.
15-Minute Unit Conversion Quick Guide
Providers should sum all active therapy minutes across the entire day first, then use this standard conversion table to calculate total daily units to bill:
| Total Active Minutes in Day | Number of Units to Bill |
| Less than 8 minutes | 0 units (does not qualify for billable unit) |
| 8 to 22 minutes | 1 unit |
| 23 to 37 minutes | 2 units |
| 38 to 52 minutes | 3 units |
| 53 to 67 minutes | 4 units |
| 68 to 82 minutes | 5 units |
| Each additional unit requires at least 8 minutes of active therapy into the next 15-minute increment | +1 units |
For additional resources refer to the Education and Training Resources page and/or sign up for a live webinar by accessing our Provider Training Calendar. Email MHD.Education@dss.mo.gov for more information.