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.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
Audit system for the Finance Director
How to use this audit system
- Part 1 is the repeating audit cycle, what to do with a serious finding, and the weekly to annual questions to ask Operations.
- 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.
- 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.
- 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.
- 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)
| Item | Texas Medicaid | TRICARE West | CHAMPVA | Aetna | BCBS Texas |
|---|---|---|---|---|---|
| Who qualifies | Members 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 paperwork | Diagnostic report and an MCO authorization request with a treatment plan | Referral with ASD diagnosis, severity level and DSM-5 checklist; renewed every 2 years | Autism diagnosis, treatment plan and medical-necessity documentation | Diagnostic report and the Aetna ABA treatment request form with clinical records | Diagnostic report, order if the plan requires one, treatment plan |
| Authorization | Required from the MCO before services, for both evaluation and treatment | Required through TriWest (Availity); review quoted at about 5 business days | Treatment needs pre-authorization; the evaluation does not. Waived when other insurance already authorized it. | Precertification required for the ABA codes, initial and ongoing, through Availity | Check per code and plan; some codes were exempted from PA in 2022 unless the plan requires it |
| Provider setup | Each LBA enrolled with TMHP, then credentialed with each MCO | TriWest ACD certification (about 10 business days after a complete application) and annual education | Confirm provider requirements and claims route with the VA CHAMPVA office | Participation contract and credentialing for the group and each BCBA | BCBSTX network contract and credentialing |
| Special billing rule | The 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 times | Generally pays after other coverage, so bill the other insurer first | Use benefit and service-type codes in Availity to read the ABA benefit before quoting | Confirm commercial versus Medicaid product on the member card |
| Claims route | 837P to the member’s MCO (confirm payer ID and portal for each MCO) | 837P through Availity | Confirm the current route with the VA CHAMPVA office; TriWest does not process CHAMPVA | 837P through Availity | 837P through Availity or the BCBSTX portal |
| Patient cost-share | None. 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 plan | Deductible, copay, coinsurance per plan |
| Timely filing (typical, confirm) | 95 days from date of service for most MCOs | 1 year from date of service | Typically 1 year from date of service | Per contract; commonly 90 to 180 days | Often 180 days |
| Setup note for STXBI | Community 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 claim | Set up days-to-pay tracking from the first claim | Low volume |
ABA CPT code reference (2026 dates of service)
| CPT | Service | Typical rendering provider | Unit | Finance note |
|---|---|---|---|---|
97151 | Behavior identification assessment (includes face-to-face and non-face-to-face analysis and report writing) | BCBA / QHP | 15 min | Initial assessment and reassessment. Needs its own authorization. Report-writing time counts here. |
97152 | Supporting assessment, administered by technician under direction | RBT | 15 min | Only where payer allows technician assessment support. |
97153 | Treatment by protocol, one-to-one | RBT | 15 min | The volume code. Most revenue and most auth units. |
97154 | Group treatment by protocol | RBT | 15 min | Group sizes and payer coverage vary. |
97155 | Treatment with protocol modification (through 2026, may include directing a technician) | BCBA / QHP | 15 min | Common denial when billed for routine supervision with no protocol change. Narrows in 2027. |
97156 | Family / caregiver guidance, with or without the client | BCBA / QHP | 15 min | Note must name who attended and what was taught. |
97157 | Multiple-family group guidance | BCBA / QHP | 15 min | Low volume. |
97158 | Group treatment with protocol modification | BCBA / QHP | 15 min | Low volume. |
0362T / 0373T | Severe-behavior supporting assessment / treatment (Category III) | Technicians, BCBA on site | 30 min | Deleted 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)
| Situation | Through 12/31/2026 | From 1/1/2027 |
|---|---|---|
| RBT delivers 1:1 treatment | 97153 | 97153 (unchanged) |
| BCBA directs the RBT during a session | 97155 | 97155 (descriptor narrowed to direction of technician with analysis) |
| BCBA treats the client directly | 97155 | 97173 (new) |
| Initial assessment | 97151 | 97151 (wording revised) |
| Caregiver guidance | 97156 | 97156 (wording revised) |
| Harmful-behavior assessment | 0362T | 97148 + add-on 97149 |
| Harmful-behavior treatment | 0373T | 97159 + add-on 97160 |
| Professional work away from the client | Bundled into treatment codes | New code 97180 (confirm payer coverage) |
Action list for the Finance Director (suggested deadlines)
- By Nov 30: Ask each payer (your Texas Medicaid MCOs such as Community First, TriWest, CHAMPVA, Aetna, BCBSTX) in writing which 2027 codes they will accept, the effective date they will adopt, and the rate for
97173,97155and any new code. Payers often lag the AMA schedule. - By Dec 15: Pull every active authorization that lists
97155,0362Tor0373Tand decide whether a modification request is needed so BCBA direct treatment can bill as97173. - By Dec 20: Add 2027 service codes, fee schedules and unit rules to CentralReach with an effective date of 1/1/2027. Do not overwrite 2026 codes, because 2026 dates of service will still be billed in 2027.
- By Dec 31: Train BCBAs to document “directing a technician” and “treating the client directly” as separate time blocks, because they will bill under different codes.
- Jan 2027: Hold and review the first week of 2027 claims before release (extra scrub step) to catch code and modifier mismatches.
Who owns what
| Function | Intake | Billing | RBT | BCBA | Clinic Dir. | Ops Dir. | Finance Dir. |
|---|---|---|---|---|---|---|---|
| Referral and paperwork packet | R | C | I | A | I | ||
| Eligibility and benefits | C | R | A | ||||
| Assessment and treatment plan | I | R | A | ||||
| Authorization request and tracking | R | C | C | I | A | ||
| Scheduling and sessions | R | R | C | A | I | ||
| Session notes and QA | C | R | R | A | I | ||
| Charge capture, scrub, claims | R | A | |||||
| Payment posting and reconciliation | R | A | |||||
| Denials and appeals | R | C | C | I | A | ||
| Patient balances | R | A | |||||
| Month-end close and KPIs | C | I | C | R / 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
| Term | Stands for | What it means here |
|---|---|---|
| ACD | Autism Care Demonstration | TRICARE program that covers ABA for eligible beneficiaries with autism. Requires a referral, diagnosis and DSM-5 checklist. |
| ASN | Autism Services Navigator | Care coordinator assigned to a TRICARE family in the ACD. |
| BCBSTX | Blue Cross and Blue Shield of Texas | Commercial payer, and also administers Texas Medicaid plans. Check which product the member has. |
| CHAMPVA | Civilian Health and Medical Program of the Department of Veterans Affairs | VA health program for spouses and children of certain disabled or deceased veterans. Not for anyone eligible for TRICARE. |
| CMS | Centers for Medicare & Medicaid Services | Federal agency that sets the 8-minute rounding convention many payers copy and runs the CMS-1500 claim form standard. |
| DEERS | Defense Enrollment Eligibility Reporting System | Database that confirms TRICARE eligibility. |
| DoD | Department of Defense | Sponsor of TRICARE. The DoD benefit number identifies the beneficiary. |
| ECHO | Extended Care Health Option | TRICARE benefit for beneficiaries with qualifying conditions. ABA cost-share under the ACD is separate from ECHO. |
| ERISA | Employee Retirement Income Security Act | Federal law that governs self-funded employer plans. These plans may not follow state autism mandates. |
| HHSC | Texas Health and Human Services Commission | State agency that runs Texas Medicaid and publishes the Medicaid autism services policy. |
| MCO | Managed care organization | Health plan that administers Medicaid for a member (for example, Community First Health Plans). Medicaid ABA authorization and claims go through it. |
| OIG | Office of Inspector General (HHS) | Publishes the exclusion list used to screen staff. |
| PCM | Primary care manager | The TRICARE Prime member’s assigned primary care provider, who issues the referral. |
| THSteps-CCP | Texas Health Steps Comprehensive Care Program | Texas Medicaid program for members 20 and younger. ABA became a covered benefit under it on 2/1/2022. |
| TMHP | Texas Medicaid & Healthcare Partnership | State contractor that handles Texas Medicaid provider enrollment and publishes the Medicaid manuals. |
| TriWest | TriWest Healthcare Alliance | The TRICARE West Region contractor. Handles authorizations and claims for TRICARE West. |
| VA | Department of Veterans Affairs | Administers CHAMPVA. |
Clinical and credentials
| Term | Stands for | What it means here |
|---|---|---|
| ABA | Applied Behavior Analysis | The therapy being billed. |
| ASD | Autism spectrum disorder | The qualifying diagnosis for ABA coverage. |
| ARD | Admission, Review and Dismissal | Texas school committee that decides special-education services. Its documents can support the assessment. |
| BACB | Behavior Analyst Certification Board | Certifies BCBAs and RBTs and sets the RBT supervision minimum (about 5% of monthly hours). |
| BCaBA | Board Certified Assistant Behavior Analyst | Assistant-level certification, supervised by a BCBA. |
| BCBA | Board Certified Behavior Analyst | Graduate-level clinician who assesses, writes treatment plans and supervises RBTs. |
| BHEC | Texas Behavioral Health Executive Council | Texas board that licenses LBAs. |
| DSM-5 | Diagnostic and Statistical Manual of Mental Disorders, 5th edition | Source of the ASD diagnostic criteria. TRICARE requires a DSM-5 checklist with the referral. |
| IEP | Individualized Education Program | School plan for a student with a disability. Supports the assessment. |
| LBA | Licensed Behavior Analyst | Texas license for behavior analysts. Texas Medicaid requires the supervising LBA to be enrolled and to serve as the rendering provider. |
| QHP | Qualified health care professional | Term in CPT descriptors for the BCBA-level rendering provider. |
| RBT | Registered Behavior Technician | Technician who delivers direct 1:1 treatment (97153) under BCBA supervision. |
Billing and revenue cycle
| Term | Stands for | What it means here |
|---|---|---|
| AR | Accounts receivable | Money owed to the clinic by payers and families. Aged in buckets (0–30, 31–60, 61–90, 91–120, 120+ days). |
| CAQH | Council for Affordable Quality Healthcare | Online profile that many payers use for credentialing. Keep it current. |
| CARC | Claim Adjustment Reason Code | Code on a remittance that explains why a payer adjusted or denied a line (for example CO-197). |
| CO | Contractual obligation | Adjustment group code. The clinic cannot bill the patient for it (for example CO-45). |
| COB | Coordination of benefits | The order in which multiple coverages pay. |
| CPB | Clinical Policy Bulletin | Aetna’s medical policy document. CPB 648 covers autism and ABA. |
| CPT | Current Procedural Terminology | The AMA procedure codes used on ABA claims (97151 to 97158 and others). |
| DOS | Date of service | The day the session happened. It drives which code set, rate and authorization apply. |
| EFT | Electronic funds transfer | The payment itself, matched to the ERA by trace number. |
| ERA | Electronic remittance advice | The electronic explanation of payment (the 835). |
| ICD-10 | International Classification of Diseases, 10th revision | Diagnosis code set. F84.0 is the common ASD code. |
| KPI | Key performance indicator | A tracked metric, such as days in AR or clean claim rate. |
| LEIE | List of Excluded Individuals/Entities | OIG exclusion list. Screen all staff monthly. |
| NPI | National Provider Identifier | 10-digit provider ID. Type 1 is an individual, Type 2 is an organization. |
| NPPES | National Plan and Provider Enumeration System | Registry where NPIs are issued and updated. |
| PA | Prior authorization | Payer approval before services. Aetna calls it precertification. |
| PI | Payer initiated | Adjustment group code for reductions the payer decides on its own. |
| PR | Patient responsibility | Adjustment group code for amounts the family owes: PR-1 deductible, PR-2 coinsurance, PR-3 copay. |
| RARC | Remittance Advice Remark Code | Supplemental code that gives more detail than the CARC. |
| SLA | Service level agreement | In this guide, an internal target turnaround time for a step. |
| TIN | Taxpayer Identification Number | Federal tax ID of the billing entity. |
Billing terms in plain language
| Term | Stands for | What it means here |
|---|---|---|
| 8-minute (midpoint) rule | Rounds 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 provider | Billing 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 claim | A claim with no errors that is accepted and paid without rework. | |
| Contractual adjustment | The difference between the clinic’s charge and the payer’s contracted rate. Written off by contract, not collected. | |
| Corrected (replacement) claim | A fixed claim sent with frequency code 7 and the original claim number. Code 8 voids a claim. | |
| Denial vs rejection | A rejection never enters payer processing (data error) and has no appeal. A denial is a processed decision that can be appealed. | |
| Modifier | Two-character add-on to a CPT code, for example 95 for synchronous telemedicine or a technician-level modifier some payers require. | |
| Peer-to-peer | Phone review between the BCBA and the payer’s clinical reviewer to contest a denied or reduced authorization. | |
| Precertification | Aetna’s term for prior authorization. | |
| Recoupment | Payer takes back money previously paid, usually by reducing a later payment. | |
| Retro-authorization | Authorization requested after services began. Allowed by only some payers and only within a short window. | |
| Scrub | Automated check of a claim for errors before it is sent. | |
| Timely filing | The deadline to submit a claim after the date of service. Late claims are denied (CO-29). | |
| Unapplied cash | Money received but not yet matched to a claim. | |
| Write-off | Balance removed from AR as uncollectible. Needs a root cause and approval. |
Electronic transactions (EDI)
| Term | Stands for | What it means here |
|---|---|---|
| 270 / 271 | Eligibility inquiry and response. | |
| 276 / 277 | Claim status inquiry and response. | |
| 277CA | Claim acknowledgement from the payer. Shows accepted or rejected and is your proof of timely filing. | |
| 835 | Electronic remittance advice (ERA). | |
| 837P | Electronic professional claim, the electronic version of the CMS-1500. | |
| 999 | Acknowledgement that the clearinghouse or payer received the file. | |
| CMS-1500 | Standard professional claim form (paper layout used as the basis for the 837P). |
Staff tags used in the flowcharts
| Term | Stands for | What it means here |
|---|---|---|
| INT | Intake Coordinator | |
| FIN | Billing staff | |
| FD | Finance Director | |
| OPS | Operations Director | |
| CD | BCBA Clinic Director | |
| BCBA | Board Certified Behavior Analyst | |
| RBT | Registered Behavior Technician | |
| FAM | Family or guardian |
Place-of-service codes
| Term | Stands for | What it means here |
|---|---|---|
| POS 02 | Telehealth, patient not at home | Telehealth delivered when the patient is somewhere other than home. |
| POS 03 | School | |
| POS 10 | Telehealth, patient at home | |
| POS 11 | Office | Clinic-based sessions. |
| POS 12 | Home | In-home sessions. |
| POS 99 | Other place of service |