This bulletin replaces in full the Reminder: Requirements for Research-Based Behavioral Health Treatment Service Delivery bulletin published on July 21, 2026.
This bulletin applies to NC Medicaid Direct and NC Medicaid Managed Care.
This bulletin clarifies and emphasizes key requirements under the Clinical Coverage Policy (CCP) 8F, Research-Based Behavioral Health Treatment (RH-BHT) Services.
RB-BHT CCP 8F Changes Effective Aug. 1, 2026
NC Medicaid recently published an updated version of CCP 8F, effective Aug. 1, 2026. Providers are encouraged to review the updated policy for awareness of the new policy requirements.
Key changes implemented in the policy which impact RB-BHT providers are:
- Requirements for existing and new paraprofessionals providing RB-BHT services to obtain at least one qualifying certification in order for services provided to Medicaid beneficiaries to be reimbursed.
- Qualifying certifications are:
- The Registered Behavior Technician certification from the Behavior Analyst Certification Board (BACB); or
- The Applied Behavior Analysis Technician (ABAT) certification from the Qualified Applied Behavior Analysis Credentialing Board (QABA).
- For existing paraprofessionals without a qualifying certification, the 120-day grace period starts on Aug. 1, 2026.
- New paraprofessionals will be required to obtain a qualifying certification within 120 days of hire.
- Any paraprofessionals without a qualifying certification require direct oversight by a Licensed Qualified Autism Service Provider (LQASP) any time they are providing a service until they are fully certified. Per the updated 8F CCP, telehealth may be used up to a maximum of 50% of total 97155 billing per beneficiary per 180-calendar day period.
- Qualifying certifications are:
- Removal of telehealth for paraprofessional RB-BHT services (Current Procedural Terminology [CPT] codes 97152-97154).
- Requirements for RB-BHT treatment plans involving more than 16 hours of services per week to be reauthorized every three months.
- Providers do not need to take any action on existing authorizations; no actions will be taken to reduce the existing prior authorization (PA) duration.
- The new requirements for treatment plan durations will be enforced upon reauthorization.
- All RB-BHT services count towards the 16 hours of services per week when determining the duration of an RB-BHT authorization.
- Requirements for service hour ratios for LQASP to Paraprofessional-delivered services, when paraprofessionals provided more than 200 hours of RB-BHT services over a six-month period.
- Requirements that at least 10% of all RB-BHT services provided by a paraprofessional involve the observation and direction of the paraprofessional by a LQASP.
- Updated requirements for treatment plans, diagnosing and service documentation.
Covered RB-BHT Activities and Treatments
The RB-BHT benefit covers a range of autism spectrum disorder (ASD) treatment and intervention models, including but not limited to Applied Behavioral Analysis (ABA). Covered treatment and intervention models must be supported by credible scientific or clinical evidence as appropriate for preventing and minimizing disabilities and behavior challenges associated with ASD. In addition to ABA, examples of covered models include:
- Early Start Denver Model (ESDM)
- Play and Language for Autistic Youngsters (PLAY) Project
- Early Social Interaction (ESI)
- Pivotal Response Training (PRT)
- Improving Parents as Communication Teachers (ImPACT)
- Joint Attention Symbolic Play Engagement and Regulation (JASPER)
- Enhanced Milieu Teaching (EMT)
- TEACCH/Structured Teaching
Activities and Treatments That Are Not Covered Under RB-BHT
The RB-BHT benefit does not cover treatments and interventions that are not supported by credible scientific or clinical evidence as being appropriate for ASD. Specific activities that are not covered by Medicaid under RB-BHT include:
- attending or participating in recreational activities, unless the activity is tied to a specific, medically necessary, therapeutic goal in an authorized treatment plan;
- nap time, break time or transportation to or from the RB-BHT site of service;
- childcare services or services provided as a substitute for the parent or other individuals responsible for providing care and supervision to the beneficiary;
- custodial, respite or personal care services;
- teaching academic subjects or as a substitute for educational support personnel (e.g., teacher, teacher’s aide, paraprofessional/aide, academic tutor);
- services available through the Individuals with Disabilities Education Act (IDEA) or other educational programs that are duplicative of or supplant services identified in the beneficiary’s authorized treatment plan;
- staff-only meetings and training; or
- administrative tasks and documentation.
Diagnosis Requirements
Beneficiaries receiving RB-BHT services must have received an ASD diagnosis from a licensed qualified provider as defined in the CCP. Diagnoses must be completed using clinically appropriate, scientifically validated tools. Diagnosing ASD must be within a provider’s license, training and experience, including being appropriately trained on the diagnostic tool(s) the provider uses. A provisional diagnosis is acceptable for beneficiaries younger than age 3. However, a final (non-provisional) diagnosis must be received within six months of the provisional diagnosis to maintain eligibility for RB-BHT.
Assessment Requirements
All beneficiaries must receive a behavioral, adaptive or functional assessment that is informed by the beneficiary’s developmental and medical history as well as all available and relevant supplementary information (e.g., interviews, chart reviews). Assessments should be completed using documented, clinically appropriate, scientifically validated tools, please refer to CCP 8F for assessment tools which can be used.
Treatment Planning
All treatment plans must be based on an assessment that meets the assessment standards as defined in the CCP. All treatment plans must be person-centered, developmentally appropriate and individualized to the beneficiary’s strengths, functional impairments, adaptive skill levels and developmental profile.
Treatment intensity (i.e., total weekly or monthly hours requested) must be individualized, medically necessary, and at a level that is scientifically demonstrated to be clinically effective at promoting adaptive functioning and preventing and minimizing disabilities associated with ASD. Treatment intensity and duration must not be in excess of the beneficiary’s needs. Treatment intensity should take into account all Medicaid-covered and non-Medicaid covered services the beneficiary receives or will receive on a regular/ongoing basis, not limited to services and supports for ASD and ASD-related symptoms (e.g., RB-BHT, school and school-based services, respite, occupational, physical and speech-language therapy, social skills training).
Excessive intensity and duration may be indicated by a beneficiary falling asleep during service delivery interventions. Reports of waking beneficiaries who have fallen asleep during treatment or forcing beneficiaries to stay awake in order to receive treatment may be interpreted as patient harm and prompt a provider investigation.
Provider Standards
All Licensed Qualified Autism Service Providers (LQASPs) and Certified Qualified Professionals (C-QPs), including Board Certified Behavior Analysts and Board Certified Assistant Behavior Analysts, seeking to enroll in the NC Medicaid program must do so as an in-state provider (S.L. 2026-1, 3C.18.(c)). This requirement is effective Aug. 2, 2026.
Additionally, all RB-BHT services must be delivered by providers that meet the minimum standards described in the CCP as well as all relevant state licensure, certification, supervision and scope of practice standards. Paraprofessionals must carry out treatment interventions and activities in accordance with the beneficiary’s authorized treatment plan and under the supervision of a Licensed Qualified Autism Service Provider (LQASP) or Certified Qualified Professional (C-QP). Eligible providers (LQASP or C-QP) must directly observe paraprofessionals at a clinically appropriate frequency while they are providing direct treatment to ensure fidelity to treatment protocols in the treatment plan.
Administrative activities and incidental supervision completed to ensure the paraprofessional is adhering to the policies and procedures of their employer and certification standards are not billable.
Use of Telehealth
Reminder: The updated CCP 8F removes telehealth for paraprofessional RB-BHT services (CPT codes 97152-97154).
When allowed under the CCP, delivery of RB-BHT services via telehealth must be delivered safely, effectively and with consideration for the beneficiary’s and caregiver’s ability to participate. Telehealth may not be used solely for the convenience of the provider, beneficiary or the beneficiary’s caregiver.
In addition, all services delivered via telehealth must be done in accordance with the guidelines in the CCP 1H: Telehealth, Virtual Patient Communications, and Remote Patient Monitoring, which can be found on the NC Medicaid Program Specific Policy page, including the following:
- Providers must ensure that services can be safely and effectively delivered using telehealth, virtual communications or remote patient monitoring.
- Providers must consider a beneficiary’s behavioral, physical and cognitive abilities to participate in services provided using telehealth, virtual communications or remote patient monitoring.
- The beneficiary’s safety must be carefully considered for the complexity of the services provided.
- Beneficiaries are not required to seek services through telehealth, virtual communications or remote patient monitoring, and must be allowed access to in-person services if the beneficiary requests.
Providers must ensure that beneficiary privacy and confidentiality is protected to the best of their ability.
Service Setting
Treatment must be provided in the setting most appropriate to the beneficiary’s individual treatment goals. Decisions regarding treatment setting(s) should be made on an individualized basis, in collaboration with the beneficiary’s family, and may include clinic-based, home-based, school-based or community settings, or any combination.
Transitions of Care
Treatment plans should contemplate appropriate reduction in service intensity and generalization of skills across settings; and transition to natural and other paid supports (as needed, including any needed training). Additionally, if a provider is no longer able to provide services under NC Medicaid, they must, per provider contracts with NC Medicaid Managed Care, inform health plans and develop a transition plan for each impacted beneficiary.
Caregiver Involvement
Caregivers should be involved in assessment, treatment planning and treatment delivery (unless clinically contraindicated). Providers should contemplate caregiver participation needs to achieve the beneficiary’s goals and objectives.
State Monitoring and Investigations into Inappropriate Billing and Other Potential Indicators of Fraud, Waste or Abuse
NC Medicaid is continuing to monitor service delivery to ensure RB-BHT services meet all state coverage policy requirements as well as all applicable state and federal rules and guidelines. Monitoring efforts will include random onsite visits as well as desk reviews of medical records. NC Medicaid will investigate any suspected instances of inappropriate billing and other activities that may indicate fraud, waste or abuse. Such activities include but are not limited to:
- Inappropriate use of concurrent billing.
- Billing practices that appear to be clinically unlikely or medically unnecessary.
- This could be indicated by caseload size, service utilization patterns or supervision hours that are inconsistent with expected clinical practice and provider operations.
- Excessive or exclusive use of telehealth to deliver services.
- Services delivered by providers that are not located near the beneficiary.
- Treatment planning that appears to be non-individualized or lack variability in treatment intensity across the provider’s practice.
- Lapsed provider credentials.
- A lack of discharges, service intensity titration and/or care transitions across the provider’s practice.
Contact
For information on NC Medicaid Managed Care health plan billing and requirements, please contact health plans leveraging the information on the Health Plan Contacts and Resources page.