1. Certification
BACB
- BCBA, BCaBA or RBT certificate current
- RBT is a paraprofessional credential practicing under close supervision [8]
Top row: the sequence. Lanes: payer applications that run in parallel.
BACB
Where required
Per payer
Group record
Payers set the processing time. The practice controls packet completeness on day one and how often each application is touched.
Source for 22 days: our BCBA credentialing case study.
| Rule | Who it hits | Date | What happens if missed |
|---|---|---|---|
| Georgia Medicaid revalidation [4] | Every enrolled provider | Jul 1, 2026 | Later dates of service not paid; effective date resets to submission date, no retro-enrollment; termination 30 days after the suspension letter |
| North Carolina technician certification [5] | Paraprofessionals delivering RB-BHT | Aug 1, 2026 | RBT or ABAT certification required; 120-day grace for existing staff, 120 days from hire for new |
| Indiana IHCP specialty and modifier [6] | RBT 625, BCaBA 624, BCBA and HSPP 615 | Feb 26, 2026 | Modifier U1, U2 or U3 must match the enrollment specialty on the rendering record |
| Point32Health ABA accreditation [7] | Center-based MA and RI first, then all others | Jan 1, 2027 Jan 1, 2028 | Accreditation becomes a network condition |
| Medicare enrollment proposals, CY 2027 Home Health PPS rule [3] | All providers, owners and managing employees | Proposed Jul 1, 2026 | All revocation grounds retroactive; denial grounds extended to owners and managing employees. Proposed, not final |
| CMS withdrawal reporting [1] | Providers leaving Medicare | 90 days 30 days DMEPOS | Late reporting of a licence surrender or retirement becomes an enrollment finding |
Certificate, supervision structure or taxonomy missing; group and individual out of order.
Technicians bill under a BCBA; a pending BCBA holds every RBT hour beneath it.
North Carolina's RBT or ABAT requirement from August 1, 2026, 120-day grace [5].
Five-year cycles slip on a growing roster; Georgia paid nothing for post-deadline dates of service [4].
Point32Health: center-based MA and RI by January 1, 2027, all others by January 1, 2028 [7].
A credentialing timeline is a revenue clock. Every day a BCBA sits in a payer queue is a day of sessions held or unbilled.
They take a BCBA, BCaBA or RBT from certification and licensure through payer enrollment and linking, for every payer the practice bills. That includes the document pre-check, parallel submission to Medicaid and commercial payers, follow-up on each application, capture of the effective date, release of held claims, and ongoing roster and revalidation maintenance.
Payers set their own processing times and most publish none. Practices commonly report 90 to 120 days per payer. Our published case study shows a timed pipeline averaging 22 days for BCBA enrollment when the packet is complete on day one, submissions run in parallel and every application is followed up on a fixed cadence.
With most payers, technician services are billed under a supervising BCBA, so a pending BCBA enrollment holds the RBT hours beneath it. Enroll the BCBA first and link technicians the day the approval arrives. States are also tightening technician credentials; North Carolina requires RBT or ABAT certification for paraprofessionals from August 1, 2026 with a 120-day grace period.
Georgia's July 1, 2026 deadline is the current example: claims with dates of service on or after the deadline are not paid, the new effective date is the date the revalidation is submitted with no retro-enrollment, and a termination notice follows 30 days after the suspension letter if nothing is filed. Federal rules require state Medicaid revalidation at least every five years.
No. It is a proposal in the CY 2027 Home Health PPS proposed rule issued July 1, 2026, which would make all revocation grounds retroactive and extend denial and revocation grounds to actions against owners and managing employees. Treat it as proposed until a final rule publishes.
Checked October 27, 2026. Rules change; confirm against the source before relying on them. Proposed rules are marked as proposed.
We audit the roster, open applications and held claims together, then run enrollment as a timed pipeline with an owner per application.