Telehealth ABA expanded fast during the COVID-19 public health emergency. Payers that had never covered remote services suddenly did. Practices built telehealth workflows almost overnight.

What followed was messier. The PHE ended. Payer policies diverged. Some carriers kept telehealth coverage for behavioral health. Others scaled back. A handful never formalized their policies at all.

The result: a billing environment where the rules depend entirely on which payer you are billing, which state you are in, and sometimes which line of business the member is enrolled in.

Here is what you need to know to bill telehealth ABA correctly.

Which CPT Codes Apply for Telehealth ABA

The standard ABA CPT code set introduced in 2019 applies to telehealth delivery when payers cover it. The codes do not change. What changes is how you report the delivery method.

The core codes:

CPT CodeDescriptionProvider
97151Behavior identification assessmentBCBA
97153Adaptive behavior treatment by protocolRBT/technician
97154Group adaptive behavior treatment by protocolRBT/technician
97155Adaptive behavior treatment with protocol modificationBCBA
97156Family adaptive behavior treatment guidanceBCBA
97157Multiple-family group adaptive behavior treatment guidanceBCBA
97158Group adaptive behavior treatment with protocol modificationBCBA

In practice, telehealth ABA most commonly applies to 97155 (BCBA supervision and protocol modification sessions), 97156 (family guidance), and 97151 (assessment). RBT-delivered direct therapy via telehealth (97153) is where payer coverage is most inconsistent — some payers require a live BCBA present on the call; others allow asynchronous supervision models.

Know your payer’s specific position on each code before you bill it.

Modifier GT vs. 95 vs. GQ: What the Difference Is

This is where most practices make billing errors.

Modifier 95 is the current AMA standard for synchronous real-time telehealth services delivered via interactive audio and video. Most commercial payers and CMS guidance now prefer or require Modifier 95 for live video telehealth.

Modifier GT was the original telehealth modifier, used primarily for Medicare and Medicaid. It indicates services delivered via interactive telecommunications systems. Many Medicaid MCOs and older commercial contracts still require GT. Some payers accept both interchangeably. Some accept only one.

Modifier GQ applies to asynchronous store-and-forward telehealth — video recorded and reviewed separately, not live. This is rarely applicable in ABA. Do not use GQ for live video sessions.

The practical rule: check the payer’s telehealth billing policy before submitting. If the policy is not published, call and document the call. Billing 95 when the payer requires GT — or vice versa — will generate a denial that looks like a credentialing error.

Place the modifier on the claim line for the service delivered via telehealth, not on every line of a split session.

Which Payers Cover Telehealth ABA

Coverage varies significantly by payer and state.

Commercial carriers: Most large commercial carriers — Cigna, Aetna, UnitedHealthcare, and most BCBS plans — extended behavioral health telehealth coverage after the PHE and have maintained it. However, the specific codes covered, the modifier requirements, and prior authorization rules differ by plan. Do not assume a national carrier’s policy is uniform across all of its state-specific plans.

Medicaid: Medicaid telehealth coverage for ABA depends on the state. Many states added ABA telehealth codes to their fee schedules during the PHE and kept them. Others sunset the flexibility. Check your state Medicaid agency’s telehealth policy and the specific managed care plan contracts. Some MCOs have stricter documentation requirements than the state fee-for-service program.

Medicare: Medicare does not cover ABA services. Medicare Advantage plans may. Check the specific plan benefit documents.

Self-pay and private pay: No modifier required. Document the session format in the clinical record and your consent forms.

Post-COVID Payer Policy Changes: What Held, What Didn’t

When the federal public health emergency ended on May 11, 2023, the automatic telehealth flexibilities that had applied to Medicare and many Medicaid programs began to unwind.

Congress extended several key telehealth provisions through 2024 via the Consolidated Appropriations Act, 2023, and further extensions have followed. But those extensions primarily protect Medicare telehealth broadly — they do not cover ABA specifically, since Medicare does not cover ABA in fee-for-service.

For commercial payers, the post-PHE shift has been uneven. Many state mental health parity laws have been interpreted to require commercial payers to cover behavioral health telehealth on the same terms as in-person services — which includes ABA in states with autism insurance mandates. However, enforcement is inconsistent.

The practical implication: do not assume continuity. Re-verify telehealth coverage with each payer at least once per contract cycle and when a client’s insurance changes.

Documentation Requirements for Telehealth ABA

Documentation for telehealth ABA must meet the same clinical standards as in-person documentation — and typically one more: the record must explicitly reflect that the service was delivered via telehealth.

Your session notes should include:

  • Explicit notation that the service was delivered via interactive audio and video telecommunication
  • The platform used (and that it meets HIPAA requirements)
  • Confirmation that the client/family was in an appropriate location and consented to the telehealth format
  • All standard ABA session elements: targets addressed, data collected, prompting levels, reinforcement procedures

Authorization requests for telehealth ABA should match your documentation. If a payer authorized in-person services and you deliver telehealth, document why — and get written payer confirmation that the telehealth substitution is covered under the authorization.

The Most Common Pitfalls

  1. Wrong modifier for the payer. Verify GT vs. 95 per payer before your first telehealth claim.

  2. Billing 97153 via telehealth without checking coverage. Many payers exclude unsupervised RBT-delivered telehealth. Confirm before billing.

  3. Authorization does not specify telehealth. Some payers issue separate authorizations for telehealth and in-person. Billing telehealth against an in-person auth will deny.

  4. No documented consent. Telehealth consent must be in the file. Make it part of your standard intake and re-obtain when a client transitions from in-person to telehealth.

  5. Assuming national policy applies to your state plan. It often does not. Medicaid and commercial plan telehealth rules can vary at the state-plan level even within the same carrier network. When claims do deny, the same root-cause approach used for in-person ABA claim denials applies.

Citations

Not sure which payers cover telehealth ABA in your state — or why your telehealth claims keep denying? See what our ABA practice services include, then book a free 30-minute consultation at abapracticeservices.com. We will audit your telehealth billing and payer coverage gaps.