STXBI Operations: Internal Financial & Audit Reference ← Back to Command Center

ABA Clinic Revenue Cycle: Intake to Cash

A step-by-step operating flowchart for the Finance Director. It follows one client from first inquiry through client-submitted paperwork, insurance verification, authorizations, sessions, documentation, CPT billing, claims, payment posting, denials and month-end close.

Built around five payer lanes: Texas Medicaid (managed-care plans such as Community First Health Plans, and TMHP rules), TRICARE West (TriWest), CHAMPVA, Aetna, and BCBS Texas, with CentralReach as the system of record.

How to read this

Each phase below is a collapsible flowchart. Solid boxes are actions, amber boxes are decisions, green and red branches show the “good” and “problem” paths, and purple dashed boxes jump to another phase. Colored tags show who owns the step. Red boxes at the bottom of each phase are the Finance Director’s watch-outs. Unfamiliar acronym? See the glossary at the end.
Action Decision Start / end Good path Stop / exception INT Intake FIN Billing FD Finance Dir. OPS Ops Dir. CD BCBA Clinic Dir. BCBA BCBA RBT RBT FAM Family

The whole journey at a glance

↺ Feedback loop: every denial, rejection and write-off is coded to a root cause (Phase 13) and sent back to Intake, Authorization, Documentation or Scrub (Phases 1 to 10) so the same error is not repeated.

Time-sensitive: ABA CPT code set changes on January 1, 2027

Dates of service on or after 1/1/2027 use a revised code set. Dates of service in 2026 still bill under the current codes, even if the claim is sent in 2027. See the 2027 transition checklist below before building authorizations that run past December 31.

Audit system for the Finance Director

How to use this audit system

  1. Part 1 is the repeating audit cycle, what to do with a serious finding, and the weekly to annual questions to ask Operations.
  2. Part 2 has eleven operations audits (A1 to A11) that follow a client from intake to cash. Part 3 has nine business-structure audits (S1 to S9): governance, controls, contracts, workforce, compliance, systems, vendors, insurance and policies.
  3. Open a module, follow its flow, then work the question cards. Each card says whom to ask, what evidence to request and what the red flag looks like. Mark Pass, Fail or N/A and add a note.
  4. The scoreboard and findings log below update as you mark cards, with a suggested severity and response time for each failed item. Marks stay in this browser only; use Copy summary to keep a record. No client information should be typed into notes.
  5. In the PDF every card prints with empty boxes so it can be used as a paper checklist.

Thresholds, sample sizes and response times are suggested starting points. Have health care counsel confirm anything involving overpayments, self-disclosure or record retention. This is a process-design aid, not legal advice.

Scoreboard

Findings log (built from your Fail marks)

Payer playbook (five lanes)

ItemTexas MedicaidTRICARE WestCHAMPVAAetnaBCBS Texas
Who qualifiesMembers 20 and younger with autism who meet Texas Medicaid Autism Services criteria (THSteps-CCP benefit, effective 2/1/2022). Most members are in an MCO such as Community First.Eligible beneficiaries with a definitive ASD diagnosis, enrolled in the Autism Care Demonstration (ACD)Spouse or child of a veteran who is permanently and totally disabled from a service-connected condition, or a survivor of one. Not for anyone eligible for TRICARE.Depends on plan. Fully insured Texas plans fall under the state autism mandate; self-funded plans can differ.Same as Aetna. If the member is on a BCBSTX Medicaid plan, use the Texas Medicaid column.
Entry paperworkDiagnostic report and an MCO authorization request with a treatment planReferral with ASD diagnosis, severity level and DSM-5 checklist; renewed every 2 yearsAutism diagnosis, treatment plan and medical-necessity documentationDiagnostic report and the Aetna ABA treatment request form with clinical recordsDiagnostic report, order if the plan requires one, treatment plan
AuthorizationRequired from the MCO before services, for both evaluation and treatmentRequired through TriWest (Availity); review quoted at about 5 business daysTreatment needs pre-authorization; the evaluation does not. Waived when other insurance already authorized it.Precertification required for the ABA codes, initial and ongoing, through AvailityCheck per code and plan; some codes were exempted from PA in 2022 unless the plan requires it
Provider setupEach LBA enrolled with TMHP, then credentialed with each MCOTriWest ACD certification (about 10 business days after a complete application) and annual educationConfirm provider requirements and claims route with the VA CHAMPVA officeParticipation contract and credentialing for the group and each BCBABCBSTX network contract and credentialing
Special billing ruleThe supervising LBA is the rendering provider on claims for all ABA services, including technician-delivered. MCOs set daily unit caps (Community First: 32 units or less per day). Telehealth modifier 95 applies to certain codes.TriWest publishes billing guidance for concurrent care and overlapping session timesGenerally pays after other coverage, so bill the other insurer firstUse benefit and service-type codes in Availity to read the ABA benefit before quotingConfirm commercial versus Medicaid product on the member card
Claims route837P to the member’s MCO (confirm payer ID and portal for each MCO)837P through AvailityConfirm the current route with the VA CHAMPVA office; TriWest does not process CHAMPVA837P through Availity837P through Availity or the BCBSTX portal
Patient cost-shareNone. Never balance-bill a Medicaid member.Plan copay or cost-share (separate from ECHO)Primary: $50 individual or $100 family deductible, then 25%. Secondary: usually nothing.Deductible, copay, coinsurance per planDeductible, copay, coinsurance per plan
Timely filing (typical, confirm)95 days from date of service for most MCOs1 year from date of serviceTypically 1 year from date of servicePer contract; commonly 90 to 180 daysOften 180 days
Setup note for STXBICommunity First has been a slow payer rather than a denial problem. Track days-to-pay by MCO.TriWest has been a slow payer rather than a denial problem.Set up days-to-pay tracking from the first claimSet up days-to-pay tracking from the first claimLow volume

ABA CPT code reference (2026 dates of service)

CPTServiceTypical rendering providerUnitFinance note
97151Behavior identification assessment (includes face-to-face and non-face-to-face analysis and report writing)BCBA / QHP15 minInitial assessment and reassessment. Needs its own authorization. Report-writing time counts here.
97152Supporting assessment, administered by technician under directionRBT15 minOnly where payer allows technician assessment support.
97153Treatment by protocol, one-to-oneRBT15 minThe volume code. Most revenue and most auth units.
97154Group treatment by protocolRBT15 minGroup sizes and payer coverage vary.
97155Treatment with protocol modification (through 2026, may include directing a technician)BCBA / QHP15 minCommon denial when billed for routine supervision with no protocol change. Narrows in 2027.
97156Family / caregiver guidance, with or without the clientBCBA / QHP15 minNote must name who attended and what was taught.
97157Multiple-family group guidanceBCBA / QHP15 minLow volume.
97158Group treatment with protocol modificationBCBA / QHP15 minLow volume.
0362T / 0373TSevere-behavior supporting assessment / treatment (Category III)Technicians, BCBA on site30 minDeleted effective 1/1/2027. Needs a specially set-up environment and two or more technicians.

Modifiers, place-of-service and technician-level modifiers differ by payer. Confirm against each payer’s current provider manual and fee schedule before loading CentralReach.

2027 code transition checklist (for dates of service on or after 1/1/2027)

SituationThrough 12/31/2026From 1/1/2027
RBT delivers 1:1 treatment9715397153 (unchanged)
BCBA directs the RBT during a session9715597155 (descriptor narrowed to direction of technician with analysis)
BCBA treats the client directly9715597173 (new)
Initial assessment9715197151 (wording revised)
Caregiver guidance9715697156 (wording revised)
Harmful-behavior assessment0362T97148 + add-on 97149
Harmful-behavior treatment0373T97159 + add-on 97160
Professional work away from the clientBundled into treatment codesNew code 97180 (confirm payer coverage)

Action list for the Finance Director (suggested deadlines)

Who owns what

FunctionIntakeBillingRBTBCBAClinic Dir.Ops Dir.Finance Dir.
Referral and paperwork packetRCIAI
Eligibility and benefitsCRA
Assessment and treatment planIRA
Authorization request and trackingRCCIA
Scheduling and sessionsRRCAI
Session notes and QACRRAI
Charge capture, scrub, claimsRA
Payment posting and reconciliationRA
Denials and appealsRCCIA
Patient balancesRA
Month-end close and KPIsCICR / A

R = does the work, A = accountable, C = consulted, I = informed. Adjust to your actual org chart.

Glossary: acronyms and terms

Programs, payers and agencies

TermStands forWhat it means here
ACDAutism Care DemonstrationTRICARE program that covers ABA for eligible beneficiaries with autism. Requires a referral, diagnosis and DSM-5 checklist.
ASNAutism Services NavigatorCare coordinator assigned to a TRICARE family in the ACD.
BCBSTXBlue Cross and Blue Shield of TexasCommercial payer, and also administers Texas Medicaid plans. Check which product the member has.
CHAMPVACivilian Health and Medical Program of the Department of Veterans AffairsVA health program for spouses and children of certain disabled or deceased veterans. Not for anyone eligible for TRICARE.
CMSCenters for Medicare & Medicaid ServicesFederal agency that sets the 8-minute rounding convention many payers copy and runs the CMS-1500 claim form standard.
DEERSDefense Enrollment Eligibility Reporting SystemDatabase that confirms TRICARE eligibility.
DoDDepartment of DefenseSponsor of TRICARE. The DoD benefit number identifies the beneficiary.
ECHOExtended Care Health OptionTRICARE benefit for beneficiaries with qualifying conditions. ABA cost-share under the ACD is separate from ECHO.
ERISAEmployee Retirement Income Security ActFederal law that governs self-funded employer plans. These plans may not follow state autism mandates.
HHSCTexas Health and Human Services CommissionState agency that runs Texas Medicaid and publishes the Medicaid autism services policy.
MCOManaged care organizationHealth plan that administers Medicaid for a member (for example, Community First Health Plans). Medicaid ABA authorization and claims go through it.
OIGOffice of Inspector General (HHS)Publishes the exclusion list used to screen staff.
PCMPrimary care managerThe TRICARE Prime member’s assigned primary care provider, who issues the referral.
THSteps-CCPTexas Health Steps Comprehensive Care ProgramTexas Medicaid program for members 20 and younger. ABA became a covered benefit under it on 2/1/2022.
TMHPTexas Medicaid & Healthcare PartnershipState contractor that handles Texas Medicaid provider enrollment and publishes the Medicaid manuals.
TriWestTriWest Healthcare AllianceThe TRICARE West Region contractor. Handles authorizations and claims for TRICARE West.
VADepartment of Veterans AffairsAdministers CHAMPVA.

Clinical and credentials

TermStands forWhat it means here
ABAApplied Behavior AnalysisThe therapy being billed.
ASDAutism spectrum disorderThe qualifying diagnosis for ABA coverage.
ARDAdmission, Review and DismissalTexas school committee that decides special-education services. Its documents can support the assessment.
BACBBehavior Analyst Certification BoardCertifies BCBAs and RBTs and sets the RBT supervision minimum (about 5% of monthly hours).
BCaBABoard Certified Assistant Behavior AnalystAssistant-level certification, supervised by a BCBA.
BCBABoard Certified Behavior AnalystGraduate-level clinician who assesses, writes treatment plans and supervises RBTs.
BHECTexas Behavioral Health Executive CouncilTexas board that licenses LBAs.
DSM-5Diagnostic and Statistical Manual of Mental Disorders, 5th editionSource of the ASD diagnostic criteria. TRICARE requires a DSM-5 checklist with the referral.
IEPIndividualized Education ProgramSchool plan for a student with a disability. Supports the assessment.
LBALicensed Behavior AnalystTexas license for behavior analysts. Texas Medicaid requires the supervising LBA to be enrolled and to serve as the rendering provider.
QHPQualified health care professionalTerm in CPT descriptors for the BCBA-level rendering provider.
RBTRegistered Behavior TechnicianTechnician who delivers direct 1:1 treatment (97153) under BCBA supervision.

Billing and revenue cycle

TermStands forWhat it means here
ARAccounts receivableMoney owed to the clinic by payers and families. Aged in buckets (0–30, 31–60, 61–90, 91–120, 120+ days).
CAQHCouncil for Affordable Quality HealthcareOnline profile that many payers use for credentialing. Keep it current.
CARCClaim Adjustment Reason CodeCode on a remittance that explains why a payer adjusted or denied a line (for example CO-197).
COContractual obligationAdjustment group code. The clinic cannot bill the patient for it (for example CO-45).
COBCoordination of benefitsThe order in which multiple coverages pay.
CPBClinical Policy BulletinAetna’s medical policy document. CPB 648 covers autism and ABA.
CPTCurrent Procedural TerminologyThe AMA procedure codes used on ABA claims (97151 to 97158 and others).
DOSDate of serviceThe day the session happened. It drives which code set, rate and authorization apply.
EFTElectronic funds transferThe payment itself, matched to the ERA by trace number.
ERAElectronic remittance adviceThe electronic explanation of payment (the 835).
ICD-10International Classification of Diseases, 10th revisionDiagnosis code set. F84.0 is the common ASD code.
KPIKey performance indicatorA tracked metric, such as days in AR or clean claim rate.
LEIEList of Excluded Individuals/EntitiesOIG exclusion list. Screen all staff monthly.
NPINational Provider Identifier10-digit provider ID. Type 1 is an individual, Type 2 is an organization.
NPPESNational Plan and Provider Enumeration SystemRegistry where NPIs are issued and updated.
PAPrior authorizationPayer approval before services. Aetna calls it precertification.
PIPayer initiatedAdjustment group code for reductions the payer decides on its own.
PRPatient responsibilityAdjustment group code for amounts the family owes: PR-1 deductible, PR-2 coinsurance, PR-3 copay.
RARCRemittance Advice Remark CodeSupplemental code that gives more detail than the CARC.
SLAService level agreementIn this guide, an internal target turnaround time for a step.
TINTaxpayer Identification NumberFederal tax ID of the billing entity.

Billing terms in plain language

TermStands forWhat it means here
8-minute (midpoint) ruleRounds minutes to 15-minute units: 8 to 22 minutes is 1 unit, 23 to 37 is 2, and so on. Some payers bill only full 15-minute units.
Billing provider vs rendering providerBilling provider is the entity paid (the clinic). Rendering provider is the clinician credited with the service. Texas Medicaid requires the LBA as rendering provider.
Clean claimA claim with no errors that is accepted and paid without rework.
Contractual adjustmentThe difference between the clinic’s charge and the payer’s contracted rate. Written off by contract, not collected.
Corrected (replacement) claimA fixed claim sent with frequency code 7 and the original claim number. Code 8 voids a claim.
Denial vs rejectionA rejection never enters payer processing (data error) and has no appeal. A denial is a processed decision that can be appealed.
ModifierTwo-character add-on to a CPT code, for example 95 for synchronous telemedicine or a technician-level modifier some payers require.
Peer-to-peerPhone review between the BCBA and the payer’s clinical reviewer to contest a denied or reduced authorization.
PrecertificationAetna’s term for prior authorization.
RecoupmentPayer takes back money previously paid, usually by reducing a later payment.
Retro-authorizationAuthorization requested after services began. Allowed by only some payers and only within a short window.
ScrubAutomated check of a claim for errors before it is sent.
Timely filingThe deadline to submit a claim after the date of service. Late claims are denied (CO-29).
Unapplied cashMoney received but not yet matched to a claim.
Write-offBalance removed from AR as uncollectible. Needs a root cause and approval.

Electronic transactions (EDI)

TermStands forWhat it means here
270 / 271Eligibility inquiry and response.
276 / 277Claim status inquiry and response.
277CAClaim acknowledgement from the payer. Shows accepted or rejected and is your proof of timely filing.
835Electronic remittance advice (ERA).
837PElectronic professional claim, the electronic version of the CMS-1500.
999Acknowledgement that the clearinghouse or payer received the file.
CMS-1500Standard professional claim form (paper layout used as the basis for the 837P).

Staff tags used in the flowcharts

TermStands forWhat it means here
INTIntake Coordinator
FINBilling staff
FDFinance Director
OPSOperations Director
CDBCBA Clinic Director
BCBABoard Certified Behavior Analyst
RBTRegistered Behavior Technician
FAMFamily or guardian

Place-of-service codes

TermStands forWhat it means here
POS 02Telehealth, patient not at homeTelehealth delivered when the patient is somewhere other than home.
POS 03School
POS 10Telehealth, patient at home
POS 11OfficeClinic-based sessions.
POS 12HomeIn-home sessions.
POS 99Other place of service