CMS Releases Proposed 2027 Medicare Physician Fee Schedule (MPFS)
July 15, 2026
On July 14, 2026, the Centers for Medicare & Medicaid Services (CMS) issued the Notice of Proposed Rulemaking for the 2027 Medicare Physician Fee Schedule (MPFS). Here are the key provisions pertaining to ABA services:
CMS Announces 2027 New and Revised CPT Codes for Adaptive Behavior Services
Within the proposed rule (see pages 146-149), CMS comments on the new and revised CPT codes for Adaptive Behavior Services, approved by the CPT Editorial Panel in September 2025. The codes and their descriptors are listed below. Please note that the codes are not official until they are released in the 2027 CPT(R) Professional Edition code book by the AMA later this year. Additionally, this is a PROPOSED rule from CMS which is subject to a 60-day public notice and comment period. All proposals are subject to change and are not final policy until they are issued in the 2027 MPFS final rule which will be released in November. As such, the Coalition cautions providers and payers against making any changes to their EMR systems or otherwise until the official publication is released by the AMA.
| Current work RVU | RUC work RVU | CMS Work RVU | CMS time refinement | ||
| HCPCS | Descriptor | ||||
| 97151 | Behavior identification assessment, administered by a physician or other qualified health care professional (QHP), each 15 minutes of the physician’s or other QHP’s time face-to-face with patient and/or caregiver(s) administering assessments and discussing findings and recommendations, and non-face-to-face analyzing past data, scoring and/or interpreting the assessment, and preparing the report and/or treatment plan | C | C | C | No |
| 97152 | Behavior identification–supporting assessment, administered by technician, face-to-face with the patient, each 15 minutes | C | C | C | No |
| 97153 | Adaptive behavior treatment by protocol, administered by technician, face-to-face with 1 patient, each 15 minutes | C | C | C | No |
| 97154 | Group adaptive behavior treatment by protocol, administered by technician, face-to-face with 2 or more patients, each 15 minutes | C | C | C | No |
| 97155 | Adaptive behavior direction of technician and analysis by physician or other qualified health care professional, face-to-face with a patient, each 15 minutes | C | C | C | No |
| 97156 | Family adaptive behavior treatment guidance with analysis, administered by physician or other qualified health care professional (with or without the patient present), including discussing protocols and treatment targets and/or training the caregiver(s) to implement assessment or treatment protocols with the patient, face-to-face with caregiver(s) for 1 patient, each 15 minutes | C | C | C | No |
| 97157 | Multiple-family group adaptive behavior treatment guidance with analysis, administered by physician or other qualified health care professional (without the patient present), face-to-face with multiple sets of caregivers for multiple patients, each 15 minutes | C | C | C | No |
| 97158 | Group adaptive behavior treatment with analysis, administered by physician or other qualified health care professional, face-to-face with multiple patients, each 15 minutes | C | C | C | No |
| 97X1X | Behavior identification–supporting assessment of harmful behavior; each 15 minutes of technician time face-to-face with a patient, requiring the following components:delivered by 2 technicians,for a patient who exhibits harmful behavior,conducted in an environment that is customized to the patient’s behavior. | NEW | C | C | No |
| 97X2X | Behavior identification–supporting assessment of harmful behavior; additional technicians present, each 15 minutes | NEW | C | C | No |
| 97X3X | Adaptive behavior non-face-to-face services, personally performed by a physician or other qualified health care professional, each 15 minutes, with any of the following elements, when performed:review and analysis of data and session notes on patient treatment targets,clinical decision-making regarding the need to modify treatment targets, goals, or protocols and/or making those modifications,clinical decision-making regarding the need for additional assessment and developing or modifying assessment protocols,developing discharge or transition plan,training on or reviewing treatment targets and/or revised assessment or treatment protocols with technician(s). | NEW | C | C | No |
| 97X4X | Adaptive behavior treatment of harmful behavior; each 15 minutes of technician time with a patient, requiring the following components:delivered by 2 technicians,for a patient who exhibits harmful behavior,conducted in an environment that is customized to the patient’s behavior. | NEW | C | C | No |
| 97X5X | Adaptive behavior treatment of harmful behavior; each additional technician present, each 15 minutes | NEW | C | C | No |
| 97X6X | Adaptive behavior treatment with analysis, administered by physician or other qualified health care professional, face-to-face with 1 patient, each 15 minutes | NEW | C | C | No |
Carrier Pricing of ABA CPT Codes
CMS extended carrier pricing of the CPT codes for adaptive behavior/ABA services through 2027. This applies to the existing CPT codes as well as the six new codes that will take effect in 2027. That means that providers will need to continue negotiating reimbursement rates with payers.
Medicare Telehealth Coverage List and Process
CMS proposes to maintain CPT codes 97151-97158 on the “permanent” telehealth coverage list for 2027. CMS did not comment on whether the six new codes (97X1X-97X6X) would be included. The Coalition plans to comment on this in our letter to CMS, and request that the six new adaptive behavior services codes be added to the Medicare telehealth list within the 2027 final MPFS rule, with a “permanent” designation for 2027.