IHCP issues additional ABA guidance for providers - Indiana Health Coverage Programs bulletin BT202662 - April 28, 2026

Sep 20, 2026

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Indiana Health Coverage Programs (IHCP) issues additional ABA guidance in response to provider questions and stakeholder feedback following Bulletin BT202627. The bulletin clarifies how Indiana’s ABA supervision and caregiver involvement expectations, including UA modifier direction, are applied, monitored, and documented. It specifies the clinical supervision scope, the 1:8 supervision ratio measurement, member-specific documentation requirements, telehealth supervision using modifier 95, and how billable versus nonbillable supervision counts toward compliance.

LanguageEnglish

CategoryHealthcare

FormatPDF

Pages4

Reading Time10 min

AccessFree to download

Additional ABA supervision

Scope of supervision requirement

Measurement of the 1:8 supervision requirement

Nonbillable case supervision services that count toward compliance

Nonbillable administrative supervision that does not count toward compliance

Billable supervision services

IHCP bulletin INDIANA HEALTH COVERAGE PROGRAMS BT202662 APRIL 28 , 2026 IHCP issues additional ABA guidance for providers The Indiana Health Coverage Programs (IHCP) is issuing additional guidance in response to questions and stakeholder feedback received following the publication of IHCP Bulletin BT202627, which established a minimum supervision requirement for applied behavior analysis (ABA) therapy services , caregiver involvement expectations and UA modifier direction. This bulletin further expands on how these requirements are applied, monitored and documented and how they relate to applicable Current Procedural Terminology (CPT®1) codes. Additional ABA supervision The following sections provide additional guidance on supervision requirements for ABA therapy services. Scope of supervision requirement The supervision requirement applies to clinical case supervision and includes direct oversight of treatment implementation for a specific member. It applies to both individual and group technician-delivered ABA therapy services billed under CPT codes 97153 – Adaptive behavior treatment by technician using an established plan, each 15 minutes and 97154 – Adaptive behavior treatment by technician with multiple patients using an established plan, each 15 minutes. The supervision requirement is intended to support clinical quality and patient safety by ensuring appropriate oversight and direction of technician-delivered services. The requirement that supervision be provided at a ratio of one hour of supervision for every eight hours (1:8) of Registered Behavior Technician (RBT)-delivered services is not based solely on a ratio of billed units of CPT code 97155 – Adaptive behavior treatment by professional using an established plan, each 15 minutes to units billed under CPT codes 97153 and 97154. Not all supervision activities are separately reimbursable. However, all supervision activities , both billable and nonbillable, count toward meeting the 1:8 supervision ratio requirement, provided the activities are appropriately documented and clinically relevant to the member’s services. Supervision services may be rendered via synchronous telehealth and billed using modifier 95 – Synchronous telemedicine service rendered via real-time interactive audio and video telecommunications system. The IHCP reinforces that telehealth supervision is intended to supplement, not replace, the majority of in-person services, and supervision models should reflect clinically appropriate use of in person oversight. 1CPT copyright 2026 American Medical Association. All rights reserved. CPTis a registered trademark of the American Medical Association Measurement of the 1:8 supervision requirement During each calendar month in which technician-delivered ABA therapy services are billed for a member, providers must maintain documentation of at least one hour of supervision for every eight hours (1:8 ratio) of technician delivered services provided to that member during that same month. Effective April 1, 2026 , compliance with the 1:8 supervision requirement will be: ◼ Measured on a monthly basis ◼ Subject to claim audit and postpayment review The requirement is member-specific and is not aggregated across technicians or across Medicaid members. This means that for each Medicaid member receiving technician-delivered ABA therapy services (services billed under CPT code 97153 or 97154), providers must ensure that the required supervision ratio is met for that individual member. Failure to meet this requirement may result in claim adjustments, recoupment or other administrative action following an audit. The supervision requirement is proportional. In instances where a member receives fewer than eight hours of RBT delivered services in a given calendar month under CPT codes 97153 or 97154, the supervising clinician must still provide a medically appropriate, proportiona

FAQs

What does the IHCP require regarding ABA supervision scope for technician-delivered services?

Supervision applies to clinical case supervision and includes direct oversight of treatment implementation for a specific member, for both individual and group technician-delivered ABA services billed under the specified CPT codes.

How is the 1:8 supervision requirement measured starting April 1, 2026?

It is measured on a monthly basis for each calendar month in which technician-delivered ABA services are billed for a member, and it is subject to claim audit and postpayment review.

Do nonbillable supervision activities count toward the 1:8 supervision ratio requirement?

Yes. Both billable and nonbillable supervision activities count toward meeting the 1:8 ratio when appropriately documented and clinically relevant to the member’s services, including member-specific fidelity review and review of technician session notes.

Sep 20, 2026

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