Coalition Advocates for Changes in TRICARE Autism Care Demonstration Billing Code Policies

November 18, 2021

In March the Defense Health Agency (DHA), which manages the TRICARE Autism Care Demonstration (ACD) program, issued revised policies for that program. They included policies on billing with the CPT codes for adaptive behavior/ABA services that are inconsistent with the code descriptors and related documents published by the American Medical Association as well as the code authors’ intended use. The policies also excluded some codes and set restrictions and limitations on some services, including numbers of units authorized and telehealth delivery. In July the ABA Coding Coalition wrote to the Director of the DHA to offer clarifications and resources. We also requested changes in the policies to make them comport with the AMA-approved code descriptors, intended use of the codes (including implementation of the full 2019 code set), and Medicaid rather than Medicare Medically Unlikely Edits (MUEs). Having received no reply to that letter, the Coalition sent a followup letter to the DHA Director this month to ask when a reply to our July letter might be forthcoming and to reiterate our previous request for the DHA to allow telehealth delivery of certain ABA services to ACD beneficiaries. If we learn of any changes in the policies around the CPT codes, we will post announcements here and under Advocacy Efforts/Other Outreach to Payers.