ABA Coding Coalition Urges CMS to Add ABA CPT Codes to the Approved Telehealth List

The Centers for Medicare and Medicaid Services (CMS) publishes a list of services and the corresponding billing codes that are payable under the Medicare Physician Fee Schedule when furnished via telehealth. Many payers use that list to determine whether to authorize telehealth delivery of services. Although CMS approved the 8 Category I CPT codes for adaptive behavior/ABA services for telehealth temporarily during the COVID-19 public health emergency, those codes have not yet been approved for telehealth on a permanent basis. The ABA Coding Coalition recently submitted a formal application to CMS for continued, permanent telehealth approval of the ABA CPT codes for which there is scientific evidence of efficacy. In preparing the application the Coalition analyzed controlled, peer-reviewed studies that evaluated the effects on patients with various diagnoses and/or caregivers of telehealth delivery of ABA services represented by each of the codes. Based on that analysis, we have asked CMS to add codes 97151 through 97156 to its list of codes that are approved for telehealth permanently. Our application outlines rationale for approving those codes for telehealth to facilitate access to services and mitigate service disruptions for patients living in rural and other underserved areas, military personnel, and during natural disasters. It describes research on the efficacy of ABA interventions for reducing rates of injuries and health problems requiring medical services, ameliorating symptoms and secondary conditions that jeopardize health and safety, and developing adaptive behaviors to prevent deterioration and regression and enhance safe, healthy functioning. A summary of studies supporting telehealth delivery of services represented by each of the CPT codes is also included.

Requests for telehealth approval that are submitted to CMS by the end of a calendar year are typically considered for the following year’s proposed rules. In light of ongoing effects of the pandemic on ABA providers and service recipients, the Coalition has asked CMS to expedite its review of our application. At this point we do not know if that request will be honored, but we will keep our constituents apprised of the status of our application. In the meantime, for resources on delivering and advocating for payer coverage of ABA services via telehealth, please see the Model Coverage Policy, the APBA Guidelines for Practicing Applied Behavior Analysis During the COVID-19 Pandemic, and our guidance on Reporting CPT Codes for Telehealth Delivery of Adaptive Behavior (ABA) Services on our Resources page.