ABA Coding Coalition Requests Reconsideration of NH Medicaid Proposal to Discontinue Coverage of Code 97155

August 20, 2025

On June 26, 2025, the New Hampshire Department of Health and Human Services (DHHS), Division of Medicaid Services issued a news alert indicating that DHHS was proposing several changes to Medicaid coverage of the CPT® codes for adaptive behavior/ABA services effective July 1, 2025. The key changes were

• Discontinuation of reimbursement for CPT® code 97155 for “supervision” of technicians by qualified health care professionals (QHPs). The notice stated that  NH Medicaid does not allow for reimbursement solely for supervision, so the 97155 service was being reclassified as non-covered.
• Addition of CPT code 97154 for treatment of a group of patients by a technician. Previously all direct treatment to patients was reported using code 97153 regardless of the number of patients receiving treatment. The notice indicated that the change was intended to support effective and efficient care delivery, while mitigating overutilization of individual services.

The Coalition wrote to NH Medicaid immediately asking them to reconsider the decision to discontinue coverage of 97155, with supporting rationale and sources. On June 27 the agency announced it would delay the proposed changes to September 1, 2025, to allow public comment and stakeholder engagement.  On August 5, NH Medicaid issued a notice indicating that upon further review the agency was formally retracting the proposal to discontinue reimbursement of code 97155. The notice stated that the code “…will continue to be a covered and reimbursable service under NH Medicaid, including when appropriately billed for supervision activities as defined under applicable clinical and billing guidelines.” The Coalition is thrilled with the Department’s decision regarding code 97155 and appreciates its receptiveness to input. Subsequently we offered written comments and suggestions regarding other proposed changes to the codes on the fee schedule for adaptive behavior/ABA services that were outlined in the Department’s June 27 State Plan Amendment (SPA) public notice. We hope to have further opportunities to collaborate with NH Medicaid and stakeholders on appropriate implementation of the adaptive behavior/ABA services code set.