When can North Carolina Medicaid ABA providers bill 97153 and 97155 at the same time?

Under CCP 8F Attachment A, Section C, as restated in the Oct. 12, 2026 bulletin, CPT 97153 or 97154 may be billed with 97155 when a paraprofessional delivers the technician code while an eligible licensed provider observes, consistent with Attachment B. A single rendering provider may not bill 97153 or 97154 and 97155 for the same period.

Is caregiver training without the beneficiary present concurrent billing in North Carolina?

No. The Oct. 12 bulletin says a licensed provider may bill caregiver training (for example CPT 97156) without the beneficiary present while a paraprofessional bills direct treatment (for example 97153) to the beneficiary at the same time. That is not concurrent billing because the services are to different people.

Does the clarification apply to NC Medicaid Managed Care as well as fee-for-service?

Yes. The bulletin states it applies to NC Medicaid Direct and NC Medicaid Managed Care. Health-plan billing contacts are on NC Medicaid’s Health Plan Contacts and Resources page.

North Carolina: ABA concurrent billing limited under CCP 8F

North Carolina Medicaid limited CCP 8F ABA concurrent billing to listed exceptions on October 12, 2026. Other same-time dual billing of beneficiary-facing codes under research-based behavioral health treatment is prohibited until further notice, for both fee-for-service and managed care.

Direct Support News desk · October 12, 2026 · Updated October 13, 2026 · 2 min read

North Carolina Medicaid told providers on Oct. 12, 2026, that concurrent billing under Clinical Coverage Policy 8F is allowed only in the exceptions listed in Attachment A, Section C, and that all other concurrent billing is prohibited until further notice.

The clarification appears in an NC Medicaid bulletin titled “Concurrent Billing Clarification for Research-Based Behavioral Health Treatment.” It applies to NC Medicaid Direct and NC Medicaid Managed Care. Policy 8F covers research-based behavioral health treatment (RB-BHT) for autism spectrum disorder, including applied behavior analysis service codes used by autism providers serving people with I/DD and related needs.

What counts as concurrent billing

The bulletin defines concurrent billing as two or more providers billing separate CPT codes for beneficiary-facing services to the same beneficiary during the same time period. The example given is a licensed, qualified health care professional (called an LQASP in the bulletin) billing CPT 97155 while a paraprofessional bills CPT 97153 for the same member at the same time.

Allowed exceptions

Under CCP 8F Attachment A, Section C, as restated in the bulletin:

CPT 97153 may be billed with 97155 when a paraprofessional delivers 97153 while being observed by an eligible provider, consistent with Attachment B (ABA service definition and provider roles).
CPT 97154 may be billed with 97155 under the same observation conditions.
A single rendering provider may not bill 97153 or 97154 and 97155 for the same time period.

What is not concurrent billing

Non-beneficiary-facing 8F services are not treated as concurrent when billed at the same time as another clinician’s beneficiary-facing work. The bulletin’s examples include:

Caregiver training (for example CPT 97156) with the caregiver and without the beneficiary present, while a paraprofessional delivers direct treatment (for example 97153) to the beneficiary.
Reassessment analysis and treatment planning (for example CPT 97151) that is non-beneficiary-facing, while a paraprofessional delivers direct treatment to the beneficiary.

When the licensed provider delivers caregiver training with the beneficiary present and caregivers participating, other direct services such as 97153 or 97154 cannot be billed for that same period.

Documentation

Providers must keep service notes that meet CCP 8F Section 5.5.1. For 97151, notes must separate beneficiary-facing from non-beneficiary-facing time. For 97156, notes must show when the licensed provider worked with caregivers alone versus with the beneficiary and caregivers together.

NC Medicaid said the concurrent-billing rules remain subject to future revision for program integrity and accurate attribution of service minutes.

Why this matters for providers

Autism and ABA agencies billing North Carolina Medicaid under 8F need to align schedules, observation protocols, and note templates with the exception list. Same-time dual billing outside those exceptions is off-limits until the state says otherwise, for both fee-for-service and managed care. Supervisors should walk clinicians through the 97151 and 97156 documentation splits so claims and session notes match.