Kentucky blinked. South Carolina rewrote the manual.
Kentucky announced a 4 percent Medicaid cut on June 8 and rescinded it on July 23, nine days before it would have hit. South Carolina rewrote its ASD manual: 97151 is in-person only and behavior technicians are barred from home and school until RBT-credentialed. North Carolina wrote ABA rules into statute. CPT 2027 is confirmed: 0362T and 0373T are gone January 1, 2027. And Maryland's RBT deadline is August 1. Every item below carries its primary source.
We promised BHCOE accreditation as the Issue #3 lead. July's regulatory volume bumped it to Issue #4, because five states and CMS moved in one month and four of the changes carry hard deadlines. This issue is a deadline list first and a newsletter second. Every claim links to the statute, bulletin, or Federal Register page it came from.
Lead story · 01Kentucky announced a 4 percent cut, then rescinded it nine days out.
On June 8, Kentucky DMS announced a 4 percent fee-for-service reimbursement cut effective August 1, 2026, covering 46 provider types including Licensed Behavior Analysts. Operators had seven weeks to model it. Then, following the Governor's July 22 action, DMS issued a rescission letter on July 23: the cut will not take effect and rates stay at current levels, described as temporary through the fiscal year.
Read that last clause twice. "Temporary through the fiscal year" is not a repeal, it is a stay. Kentucky's budget pressure did not disappear on July 22, and a cut that got within nine days of effect once can come back in the next budget cycle with less notice.
- Do not unwind the 4 percent reserve if you booked one. Reclass it as a rate-risk reserve and hold it through the Kentucky fiscal year.
- Keep the rescission letter in your payer file. If any KY MCO pays at cut-adjusted rates after August 1, that letter is the appeal exhibit.
- Run a paid-versus-posted variance report on Kentucky remits for August and September. Pass-through errors after a rescission are common.
Sources: KY DMS cut announcement, Jun 8, 2026 · KY DMS rescission letter, Jul 23, 2026
Lead story · 02South Carolina rewrote the ASD manual: 97151 in-person only, RBT or nothing in home and school.
Effective July 1, 2026, SC Healthy Connections published a rewritten ASD Provider Manual. Five changes matter operationally. One, 97151 assessments are in-person only and the GT telehealth modifier is removed from the code. Two, behavior technicians are barred from home and school settings until RBT-credentialed. Three, new supervision rules. Four, expanded documentation requirements on 97155, 97156, and 97157. Five, a new place-of-service prior authorization table plus ORP edit codes 611 through 615, which means claims with an ordering or referring provider problem will now hit named edits instead of paying.
The RBT requirement is the staffing story of the quarter. If your South Carolina roster runs non-credentialed BTs in home programs, every one of those sessions after July 1 is a compliance exposure, not just a billing question. The 97151 change also breaks any intake model that ran remote assessments across a rural caseload.
- Scrub your SC claim templates and clearinghouse maps for the GT modifier on 97151. It should not appear on any claim with a July 1 or later date of service.
- Pull the BT roster against BACB RBT registry status. Reassign non-RBT BTs off home and school cases today and put every affected tech on an RBT completion clock.
- Rebuild your SC prior auth workflow against the new place-of-service table and brief your BCBAs on the expanded 97155, 97156, and 97157 documentation before their next progress reports.
- Watch remits for ORP edits 611 through 615 and fix referring-provider data at the source, not claim by claim.
Source: SC Healthy Connections ASD Provider Manual, eff Jul 1, 2026
Lead story · 03North Carolina wrote ABA rules into statute. That is a different kind of permanent.
Session Law 2026-41 (SB 257), Section 9E.22, signed July 7, moves ABA and RB-BHT program rules out of clinical coverage policy and into the state budget statute itself. The terms: LQASP assessments must be in-person, with telehealth non-reimbursable absent exceptions. Every ISP requires PHP or DHB approval. Treatment plans at or under 16 hours per week get a 6-month review cycle, plans above 16 hours per week get a 3-month cycle. And the law mandates closed networks for RB-BHT.
Why statute matters: a clinical coverage policy can be revised through an agency comment cycle. A statute needs the General Assembly. Operators who assumed the May draft of CCP 8F was the whole fight should note that 8F is still not final, the posted version is still December 2020, and the statute now sits above whatever 8F becomes. A July 21 Medicaid bulletin also reminded RB-BHT providers of standing requirements: direct observation of paraprofessionals, telehealth only per CCP 1H and never for convenience, and LQASPs and CQPs must enroll in-state, effective April 30, 2026.
- Reschedule any telehealth LQASP assessments on the NC calendar to in-person. The statute makes them non-reimbursable absent exceptions.
- Split your NC caseload at the 16 hour per week line and load the 6-month and 3-month review cycles into your reauthorization calendar now, before the review dates arrive unannounced.
- Verify every LQASP and CQP on your NC panel holds in-state enrollment. The April 30 requirement is already live and the July 21 bulletin says it survives the 8F revision.
- If you planned NC expansion, model the closed-network mandate. Entry into RB-BHT networks is no longer open-ended.
Sources: SL 2026-41 (SB 257) Sec 9E.22, pp 274-275 · NC Medicaid RB-BHT bulletin, Jul 21, 2026
Data deep diveCPT 2027 is confirmed: 0362T and 0373T are deleted January 1.
The CY2027 Physician Fee Schedule proposed rule, published in the Federal Register on July 16, confirms the adaptive behavior code overhaul the field has been waiting on. Category III codes 0362T and 0373T are deleted. All eight codes 97151 through 97158 are revised. And six new codes arrive: two-technician harmful-behavior assessment and treatment codes replacing the deleted T codes, a new non-face-to-face QHP code, and a face-to-face analysis code. Effective date is January 1, 2027, and CMS proposes contractor pricing for the new codes, which means your MAC and each state and commercial payer will set values on their own clocks. Comments on the proposed rule are due September 14, 2026.
The Category III behavior-identification-assessment and exposure-treatment codes end December 31, 2026. Every payer contract that names them needs a crosswalk.
All eight adaptive behavior codes carry revised descriptors January 1, 2027. Templates, auth grids, and EHR code tables all touch this.
Two-technician harmful-behavior assessment and treatment, a non-face-to-face QHP code, and a face-to-face analysis code. CMS proposes contractor pricing.
The same rule moves the Medicare behavioral telehealth goalposts: the in-person requirement is delayed to January 1, 2028, audio-only coverage is extended to January 1, 2028, geographic waivers run through December 31, 2027, and the RHC and FQHC mental health in-person requirement is waived through 2027. It is a proposed rule, so hold final-rule confirmation before rewriting policy, but the direction is a full extra year of telehealth room.
Operationally, this is a five-month runway. The practices that hurt in January will be the ones that waited for payers to publish crosswalks in December. Start with our ABA CPT code guide for the current code map, then get your fee schedules and the payer-by-payer rules in one place. The ABA payer matrix covers 52 jurisdictions and 8 payers and is the fastest way to see which of your contracts name the deleted T codes. If you want the crosswalk built for you, that is exactly the kind of January-1 cliff our ABA billing services team runs ahead of the effective date.
- Inventory every payer contract and auth grid that names 0362T or 0373T. Those are your January 1 breakage points.
- File a comment on contractor pricing by September 14, 2026. Two-technician codes priced wrong at the MAC level become a multi-year problem.
- Ask each of your top payers, in writing, for their CPT 2027 crosswalk and effective-date position. Their silence in October is your denial spike in January.
Source: CY2027 PFS proposed rule, Federal Register, Jul 16, 2026
Deadline story · 04Maryland: behavior technicians must be RBTs in ePREP before August 1.
Two Maryland changes stack in the same month. First, effective July 1, MDH via Carelon requires a referring practitioner NPI with active Maryland Medicaid enrollment verification on every monthly ABA claim. A referral from a practitioner whose Medicaid enrollment lapsed now fails the claim. Second, on July 15 MDH directed Behavioral Technicians to upgrade to RBT credentialing through ePREP before the MPRIME application hold begins August 1, 2026. Applications that miss the window sit in the hold.
The August 1 date is the hardest deadline in this issue. An ePREP application takes days you no longer have many of, and a BT stuck in the MPRIME hold is a tech you cannot bill.
- Submit every outstanding BT-to-RBT upgrade in ePREP now. Do not batch them for month-end, the hold starts August 1.
- Verify the referring practitioner NPI and active MD Medicaid enrollment on every open ABA case, and add that check to intake so July's rule does not become September's denial queue.
- Keep screenshots and confirmation numbers for every ePREP submission filed before the hold. That is your evidence packet if an application is mis-sequenced.
Sources: MDH BT-to-RBT ePREP directive, Jul 15, 2026 · MDH/Carelon referring provider requirements, eff Jul 1, 2026
Four of this month's changes are enrollment and credentialing actions, not rate actions. The payers are not cutting what they pay you. They are narrowing who is allowed to bill at all.
The ABA Operator editorial deskAround the statesTwelve more moves, one table.
Everything else verified this cycle, each row with its primary source. States not listed were quiet on ABA policy in our July sweep.
| State | What changed | Effective | Operator action | Source |
|---|---|---|---|---|
| CO | Exempt: HB 26-1410's 2.0% across-the-board Health First Colorado cut takes effect, but Pediatric Behavioral Therapy (ABA) is explicitly exempt. Same bulletin extends ordering practitioner (OPR) NPI requirements to PBT claims. | Jul 1, 2026 | Confirm PBT remits show uncut rates; add enrolled ordering NPI to every claim or expect denials. | HCPF bulletin |
| CO | Recoupment: HCPF will reprocess and recoup 97151 claims paid beyond 1 unit per 365 days (2 units with TJ modifier once per 365), enforcing PM 25-005. | Jun 2026 | Self-audit 97151 utilization per member per 365 days and reserve for the recoupment before it posts. | HCPF bulletin |
| MT | Freeze: DPHHS cancels SFY 2027 provider rate adjustments on a budget shortfall; ABA rates frozen at SFY 2026 levels. The Jul 1 fee schedule applies 2026 RBRVS RVUs budget-neutral, ABA on the affected list. | Jul 1, 2026 | Rebuild the MT fee schedule against the new RVU file even though the net is flat; line items still move. | DPHHS notice · RVU notice |
| AL | Paused: Jun 15 alert required pediatricians to add ABA Specialty 175 to enrollment for autism diagnoses validating ABA referrals, and barred CRNPs from diagnosing for ABA referrals. A Jun 18 alert paused the Jul 1 deadline pending further guidance. | Paused | Track referring physicians' Specialty 175 status anyway; watch for the August follow-up alert. | Alert 16758 · Alert 16764 |
| TN | Documentation: BCBST July BlueAlert requires ASD diagnoses to document DSM-5 criteria, a comprehensive evaluation, and differential diagnosis, not a single screening. Applies to all lines including BlueCare and TennCareSelect. | Jul 2026 | Audit diagnostic files on BCBST members; a screener-only file is now an audit finding. | BlueAlert, Jul 2026 |
| LA | Revalidation: LDH IB 26-10 launches CMS-mandated off-cycle revalidation for all provider types including ABA. Non-response means deactivation. | Jul 10, 2026 | Calendar every provider's revalidation notice and respond early; deactivation stops payment cold. | LDH IB 26-10 |
| RI | Moratorium: 6-month moratorium on newly enrolling HBTS and ABA providers. Existing providers unaffected. | Jun 16, 2026 | If RI entry was on your growth map, the window is closed until roughly December; plan around it. | RI EOHHS |
| MA | Freeze: MassHealth proposes re-adopting 101 CMR 358 ABA rates unchanged from October 2024, a de facto rate freeze for 197 providers. | Dec 1, 2026 | Model FY27 on flat MA rates and put cost inflation into the comment record, not into hope. | Hearing notice |
| VA | Portal cutover: Atrezzo direct access ends July 31; all FFS service authorization, including the ABA per-code-unit process, routes through DMAS MES SSO. A Jul 20 memo also updates DD Waiver Autism Advanced Competencies. | Jul 31, 2026 | Provision MES SSO access for every auth submitter before July 31 or your VA auth pipeline stops. | DMAS memos |
| GA | MCO policy: CareSource GA Medicaid policy MM-0212 realigns to the state ASD manual, splits payment provisions to PY-1634, and caps behavioral assessment PA at 8 hours per 6 months absent justification. | Jul 1, 2026 | Write the justification into every CareSource assessment PA that needs more than 8 hours; do not discover the cap at denial. | MM-0212 |
| FL | Expansion: ICMC (IDD Comprehensive Managed Care) opens transfer enrollment for iBudget waiver and SMMC LTC enrollees; the statewide plan covers behavior analysis for adults 18 and older with IDD. | Jul 1, 2026 | If you serve adults with IDD in Florida, evaluate ICMC network entry; adult behavior analysis coverage is the rare growth headline this month. | AHCA ICMC |
| NJ | Watch: Horizon NJ Health's BH integration transition ends; out-of-network BH providers may be paid below the Medicaid FFS floor. State materials list MH and SUD lines, not ABA specifically, so treat as a watch item. | Jul 1, 2026 | If you bill Horizon NJ Health out-of-network, confirm your line of business before assuming the floor holds. | NJ DHS deck |
| BACB | Certification: Ontario residents can no longer apply for BCBA or BCBA-D certification as of July 1 (current certificants maintain). ACE Provider requirement updates take effect the same date, and Pathways 3 and 4 are discontinued January 1, 2027. | Jul 1, 2026 | If you recruit BCBAs from Ontario pipelines or rely on Pathway 3 or 4 candidates, rework the 2027 hiring plan now. | BACB changes |
Watch list: Arizona's AHCCCS AMPM 320-S ABA policy rewrite is still pending final adoption after the April webinars, comment window closed June 1. North Carolina's rewritten CCP 8F remains unadopted. Aetna CPB 0648's scheduled July 9 review has not yet posted. Quiet in our sweep: CA, OR, WA, NV, NM, UT, ID, AK, HI, WY, NY, CT, PA, VT, NH, ME, DE, DC, TX, OK, AR, MS, WV.
Operator's checklistTen actions, ranked by deadline.
Same rule as every issue: each item is one owner, one defined output, no new software.
MD: file every BT-to-RBT ePREP upgrade
Before the August 1 MPRIME hold. Keep confirmation numbers.
VA: provision MES SSO for auth submitters
Atrezzo direct access ends July 31. No SSO, no auth pipeline.
SC: scrub GT off 97151 and audit the BT roster
In-person-only assessments; RBT-only in home and school.
KY: hold the reserve, file the letter
Rescission is temporary through the fiscal year. Watch August remits.
NC: reschedule telehealth LQASP assessments
Statute makes them non-reimbursable absent exceptions.
NC: load 6-month and 3-month ISP review cycles
Split the caseload at 16 hours per week and calendar both cycles.
CPT 2027: inventory 0362T and 0373T exposure
Every contract and auth grid naming a deleted T code breaks January 1.
CPT 2027: comment by September 14
Contractor pricing on the six new codes is set in this cycle.
LA: calendar the off-cycle revalidation
IB 26-10, all provider types. Non-response equals deactivation.
All states: refresh the payer matrix
Twelve of this month's moves change a row in your payer-rule grid.
Operator Q&AThree questions operators are asking.
Kentucky rescinded the cut. Can we release the reserve?
Not yet. The July 23 letter keeps rates at current levels on terms described as temporary through the fiscal year. Hold the reserve through the Kentucky fiscal year, reclass it as rate-risk rather than a booked cut, and revisit when the next budget cycle publishes. A cut that got within nine days of effect is a live scenario, not a dead one.
Our SC BTs are mid-way through RBT coursework. Can they keep home cases until they finish?
No. The rewritten manual bars behavior technicians from home and school settings until RBT-credentialed, effective July 1, 2026. Sessions delivered by a non-RBT BT in those settings after that date are exposure. Reassign to center-based settings where permitted, put completion dates on a tracked clock, and document the reassignment in each affected learner's record.
Do we really need to act on CPT 2027 five months early?
Yes, for two reasons with dates on them. Comments on contractor pricing close September 14, 2026, and that is your only lever on how the six new codes get valued. And payer crosswalks historically publish late; if your contracts name 0362T or 0373T and you have no written crosswalk by November, your January claims are running on assumptions. The inventory costs one afternoon now and a denial spike later.
Which of these twelve changes touches your book?
Free payer-policy exposure check. Tell us your states and payer mix. We return a one-page read on which of this month's changes hit your billing, credentialing, and authorization workflows, with the primary sources attached. Yours to keep.
Common questionsFrequently asked: July's regulatory wave.
Was the Kentucky 4 percent Medicaid rate cut rescinded?
What changed in the South Carolina ASD provider manual on July 1, 2026?
What does North Carolina SL 2026-41 change for ABA providers?
When do the new CPT codes replace 0362T and 0373T?
What is the Maryland RBT ePREP deadline?
Is the Medicare behavioral telehealth in-person requirement still coming in 2027?
How do I subscribe to The ABA Operator?
That is Issue #3. Issue #4 lands in August with the BHCOE accreditation lead we owe you, plus the Alabama referral-specialty follow-up, the Arizona AMPM 320-S adoption, and NC CCP 8F if it finalizes.
The ASP-RCM team. Call 469-393-0083 or visit asprcmsolutions.com. CASP Business Affiliate, Inc. 5000 firm, only ABA-specialist RCM partner with a BHCOE channel partnership. Founded 2019. Always opt-in.