If your ABA practice bills concurrent 97153 (behavior technician time under BCBA direction) and 97155 (BCBA protocol modification) simultaneously, 2026 is the year the rules got harder — and different in every state.
The biggest news: Vermont Medicaid, effective January 2026, discontinued reimbursement for concurrent billing of 97153 and 97155, restricted telehealth ABA delivery, and introduced new supervision terminology. Michigan, Virginia, and Texas have imposed their own restrictions with different rules.
What Vermont Just Did
Before January 2026: Vermont Medicaid reimbursed concurrent billing of 97153 (technician time) and 97155 (BCBA supervisory time) when both providers were engaged in distinct clinical activities during overlapping time.
After January 2026: Vermont Medicaid no longer reimburses concurrent billing of 97153 and 97155 for the same child. Their guidance: “billing both simultaneously does not meet AMA coding guidance. We will only reimburse for the child’s face-to-face time.”
ABA orgs that structured their revenue model around concurrent billing lost 8-15% of billable revenue overnight. Vermont also restricted telehealth delivery — direct treatment (97153) via telehealth is now much more limited than post-COVID rules.
Michigan, Virginia, Texas: What They’re Doing
Michigan Medicaid PIHP redesign — creating denial cliffs on autism ABA (H0031 and H2019 assessment codes) that most in-house teams are treating as one-off denials when they’re actually systemic policy changes.
Virginia Medicaid requires HCPCS provider-level modifiers (HO, HN, HM) on concurrent 97153/97155 billing to identify the specific provider level delivering each service. Missing the modifier = denial.
Texas Medicaid requires U-series modifiers (U1, U2, U3, etc.) that vary by service type on concurrent billing.
Commercial payer patterns in 2026: Anthem BC/BS requires modifier 59 on secondary code. United Healthcare documentation review requests are spiking. Aetna now requires prior auth for some 97155 combinations. Cigna announced Q3 2026 rate cuts on concurrent 97153/97155.
Documentation Standards That Protect Concurrent Billing
For payers that still allow concurrent billing, documentation standards have tightened. Your notes must include:
- Distinct provider timestamps — Provider A (behavior technician) start/end times; Provider B (BCBA) start/end times; overlap window if present, with justification
- Distinct clinical activities — Behavior technician: “Delivered protocol X to reduce target behavior Y”; BCBA: “Modified protocol X after observing new response pattern during minutes 30-35”
- Prior authorization explicit coverage — Save documentation showing concurrent billing was pre-authorized specifically
- Session notes match billed time — Most common recoupment trigger in 2026
- Payer-specific modifier application — Correct modifier for correct payer for correct state
The Revenue Protection Playbook
Step 1: Build a payer/state matrix spreadsheet. Rows = every payer you bill. Columns = every state you operate. Cell contents = current concurrent billing rules + modifier requirements + last updated date. Refresh quarterly.
Step 2: Documentation templates by payer/state. For each combination that allows concurrent billing, build a note template that captures required documentation. Use these in your EHR.
Step 3: Real-time denial tracking. Track concurrent-billing denials by payer/state/reason code weekly. When patterns emerge, respond immediately across the whole account.
Step 4: Appeal playbook. Cite AMA CPT guidance, MHPAEA parity, state-specific provider manual references.
Step 5: Contract renegotiation signals. If a payer’s rules materially reduce reimbursement, that’s a contract renegotiation trigger.
When to Outsource
If your practice bills ABA across 3+ payers or 2+ states, concurrent billing compliance alone is a full-time RCM job. Specialty ABA billing firms have payer/state matrix already built and maintained quarterly, documentation templates for every common combination, denial tracking dashboards with automated alerts, and appeal templates cited to CPT/AMA/MHPAEA/state manuals.
The 6-10% of collections most ABA specialty firms charge is typically recovered 2-3x over through preventing recoupments on improperly documented concurrent billing, recovering denials in-house teams don’t have bandwidth to appeal, and optimizing modifier application per payer per state.
The Bottom Line
Vermont’s January 2026 concurrent billing changes are the leading edge of what’s happening to ABA reimbursement everywhere. Michigan, Virginia, and Texas are moving in different directions with different requirements. Commercial payers are following state Medicaid changes with their own modifier updates.
Your protection is systematization: payer/state matrix, documentation templates, denial tracking, appeal playbook.
If you want an outside audit of your specific ABA billing patterns — payer-by-payer, state-by-state — we do free 30-day denial audits at Revenant Care Group. Book 15 minutes: calendar.app.google/zF3c44hYGRjEf5U26
— KD, Founder, Revenant Care Group | Specialty BH/ABA/SUD RCM | revenantcare.com | (346) 476-4453