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Industry Update

Updated September 2026 The 2027 ABA CPT Code Changes Are Confirmed: Six New Codes and What They Mean for Your Billing

The six new codes are now final and take effect January 1, 2027. Here's what changes, what stays the same, and how to prepare.

16 min read

Updated September 2026: This article originally covered the anticipated 2027 code changes. The AMA published the final 2027 CPT code set on September 9, 2026, and this post now reflects the confirmed codes and descriptors.

The Biggest Billing Shift Since 2019

The American Medical Association has published six new CPT codes for Applied Behavior Analysis services, effective January 1, 2027. This is the biggest change to ABA billing since 2019, when the current 97151-97158 codes replaced most of the temporary Category III codes the field had used since 2014.

The CPT Editorial Panel approved the changes in September 2025. AMA confidentiality rules kept the final code numbers private until the AMA released the 2027 CPT code book on September 9, 2026. Six of the 299 new codes in that release are for adaptive behavior services. The ABA Coding Coalition, which submitted the code change application with the ABAI ABA Billing Codes Commission, published the full code list and a coding crosswalk within days.

The new structure does three things. It gives BCBAs a code for non-face-to-face clinical work for the first time. It splits 97155 so that directing a technician and treating a client are billed separately. And it replaces the last two temporary codes for severe behavior with permanent ones. The ABA code set grows from 10 codes to 14.

Pricing is still unsettled. CMS has proposed to leave all 14 codes carrier-priced, which means there is no national Medicare rate and each payer will set its own. For providers, the next 100 days are about updating billing systems, sorting out authorizations that straddle January 1, and opening rate conversations with payers.

Key Metrics at a Glance

MetricNew CPT codes introduced
Value6 codes (97148, 97149, 97159, 97160, 97173, 97180)
MetricEffective date
ValueJanuary 1, 2027
MetricCodes revised
Value97151-97158 (97155 substantively redefined; wording changes to the rest)
MetricCodes deleted
Value2 (0362T and 0373T)
MetricTotal ABA codes in 2027
Value14 (up from 10)
MetricCPT Editorial Panel approval
ValueSeptember 2025
Metric2027 CPT code book published
ValueSeptember 9, 2026
MetricMedicare pricing
ValueCarrier-priced (no national rate)
MetricTelehealth status of new codes
ValuePending CMS final rule, expected November 2026

Six New Codes and a Revised Framework

The 2027 changes build on the existing 97151-97158 framework. All eight current codes keep their numbers, and the six new codes fill specific gaps: harmful-behavior assessment and treatment with multiple technicians, direct treatment by a BCBA, and the clinical work BCBAs do outside of sessions.

The code book still files ABA under "adaptive behavior services." The term "destructive behavior" has been replaced with "harmful behavior," which the Coalition defines to include repetitive and stereotypic behaviors as well as behavior that risks physical harm to the patient, others, or property.

Code Structure and Clinical Definitions

Code97148
Service TypeSupporting assessment of harmful behavior
Provider Level2 technicians, QHP on site
Key RequirementsPatient exhibits harmful behavior; customized environment
Code+97149
Service TypeEach additional technician (assessment)
Provider Level3rd through 5th technicians
Key RequirementsAdd-on to 97148; reports combined time of additional technicians
Code97159
Service TypeTreatment of harmful behavior
Provider Level2 technicians, QHP on site
Key RequirementsPatient exhibits harmful behavior; customized environment
Code+97160
Service TypeEach additional technician (treatment)
Provider Level3rd through 5th technicians
Key RequirementsAdd-on to 97159; reports combined time of additional technicians
Code97173
Service TypeAdaptive behavior treatment with analysis
Provider LevelPhysician or QHP (typically BCBA)
Key RequirementsFace-to-face with one patient
Code97180
Service TypeAdaptive behavior non-face-to-face services
Provider LevelPhysician or QHP, personally performed
Key Requirements15-minute units; one or more of five qualifying activities

The + indicates an add-on code. Add-on codes can only be billed together with their primary code on the same date of service. 97149 is billed with 97148, and 97160 is billed with 97159.

Harmful-behavior staffing requirements

The four harmful-behavior codes are each built as a base code that requires two technicians, plus an add-on for the third through fifth technicians. The add-on reports the combined time of the additional technicians in 15-minute units, up to five technicians total. For example, an assessment staffed by four technicians is billed as 97148 for the first two, plus 97149 units covering the combined time of the third and fourth. If only two technicians are present, the base code is billed alone. The descriptors don't mention the supervising clinician, but the Coalition's crosswalk says a physician or QHP must be on site and immediately available. Telehealth can meet that requirement where it is medically necessary and clinically appropriate. Payer policies and state laws vary, so providers should confirm telehealth is allowed for each payer and jurisdiction.

A Code for the Work Between Sessions

97180 is the change most ABA providers will feel. It covers clinical work that BCBAs have always done but have rarely been able to bill:

  • Reviewing and analyzing data and session notes
  • Deciding whether to modify treatment targets, goals, or protocols, and making those changes
  • Deciding whether more assessment is needed, and developing or modifying assessment protocols
  • Developing discharge or transition plans
  • Training on or reviewing treatment targets or revised protocols with technicians.

Under the current code set, the only indirect work billable with a CPT code is the portion included in the assessment code, 97151. Day-to-day treatment planning is bundled into the treatment codes. Some payers have covered it with HCPCS or other supplemental codes, but coverage has been inconsistent.

The code has specific requirements. The work must be personally performed by the physician or QHP, and it is billed in 15-minute units.

The crosswalk defines a QHP broadly, including BCBAs, BCaBAs, BCBA-Ds, and licensed behavior analysts, so this post uses "BCBA" as shorthand for the QHP role.

Weekly reporting

According to the Coalition's crosswalk, 97180 may be reported once a week by adding up the qualifying time from the previous seven days. That puts the burden on documentation. BCBAs will need to log non-face-to-face time as it happens and tie each entry to one of the five qualifying activities. Time that isn't captured during the week can't be reconstructed accurately at billing time.

97155 Splits in Two

The revision to 97155 changes how most BCBA session time is billed today.

Under the current definition, 97155 covers treatment with protocol modification by the clinician, face-to-face with one patient, which may include directing a technician at the same time. In 2027, 97155 becomes direction of technician with analysis, still face-to-face with a patient. When the BCBA is delivering treatment directly, that time moves to the new code, 97173.

In practice, a BCBA session billed as 97155 today may be billed as either 97155 or 97173 in January, depending on what the clinician was doing. Scheduling templates, session documentation, and prior authorizations all need to reflect that distinction.

The panel also made wording changes across the rest of the set:

  • 97156 and 97157 (family guidance) add "with analysis."
  • 97158 (group treatment by a QHP) replaces "with protocol modification" with "with analysis."
  • 97152, 97153, and 97154 (technician codes) drop the phrase "under the direction of" a physician or QHP.
What "analysis" means is still undefined

"Analysis" now appears across the clinician codes, but the Coalition's code page does not define it. The Coalition has said its webinars will cover the CPT definitions providers and billers need to report these services accurately. Until that guidance is published, providers should assume that a familiar code may come with new rules.

0362T and 0373T Retire

The two temporary Category III codes for severe behavior, 0362T (assessment) and 0373T (treatment), are deleted on December 31, 2026. They have been in use since July 2014 and were the only Category III codes to carry over after the 2019 transition. On January 1, the four new harmful-behavior codes replace them.

Authorizations that cross January 1

The largest near-term exposure is authorizations. Any active authorization that runs past December 31 and includes 0362T, 0373T, or 97155 will need to be converted to the new codes. Payers may handle that differently. Some will update authorizations automatically, some will require new requests, and some may not have a process in place by January. Providers should confirm each payer's approach in writing before the cutover.

Carrier Pricing and Rate Negotiation

In its proposed 2027 Medicare Physician Fee Schedule, released July 14, 2026, CMS proposed extending carrier pricing through 2027 for all 14 adaptive behavior codes, including the six new ones. The proposal is not final until the 2027 final rule in November.

Carrier pricing means there is no national Medicare fee for these codes, so providers will continue negotiating rates payer by payer. There is no national benchmark for 97173 or 97180, and a new CPT code does not guarantee coverage. Payers will decide separately whether to reimburse each new code and at what rate.

How Billing Shifts in 2027

Work PerformedBCBA directing a technician in session
Billed Today97155
Billed in 202797155
Rate StatusExisting rate, revised descriptor
Work PerformedBCBA treating client directly
Billed Today97155
Billed in 202797173
Rate StatusSet by each payer
Work PerformedBCBA data review, protocol changes, tech training
Billed TodayBundled, or payer-specific HCPCS
Billed in 202797180
Rate StatusSet by each payer; coverage not guaranteed
Work PerformedHarmful-behavior assessment
Billed Today0362T
Billed in 202797148 + 97149
Rate StatusSet by each payer
Work PerformedHarmful-behavior treatment
Billed Today0373T
Billed in 202797159 + 97160
Rate StatusSet by each payer

The financial impact will vary based on each provider's service mix and payer mix. Providers where a large share of BCBA time goes to direct treatment will see the most change on 97155 and 97173. Providers that do significant severe-behavior work will be most affected by the harmful-behavior codes. For nearly every provider, 97180 is a potential new revenue line, but only where payers agree to cover it at a workable rate.

Regulatory and Compliance Framework

The code transition overlaps with federal rulemaking and payer policy updates, and several key pieces are still open.

Federal Policy

The CMS proposal kept 97151 through 97158 on Medicare's permanent telehealth list but did not say whether the six new codes would be added. The Coalition has said it will push CMS to include them. Comments closed September 14, and the final rule is expected in November 2026. Commercial and Medicaid telehealth policies will follow on their own timelines.

Coalition Guidance

The Coalition scheduled three briefings in September:

  • An ABAI session for providers, billers, and software vendors on September 21
  • An APBA session for providers on September 28
  • An invitation-only CASP session for payers and regulators on September 30

Payer policy updates are expected to follow the September 30 payer briefing. The Coalition's crosswalk and definitions guidance will be the main references for correct reporting.

AMA Guidance

The AMA will hold its CPT & RBRVS 2027 Annual Symposium November 18 to 20, with coding guidance on the 2027 changes. Between the symposium and the final Medicare rule, providers should expect more clarity on the new codes in mid-to-late November.

Payer Medical Policies

Each payer will need to update its medical policies, fee schedules, and claims edits for the new codes. Providers should watch for guidance on whether 97180 is covered, how it interacts with existing supplemental codes, and whether payers add same-day or bundling edits between 97155, 97173, and the technician codes.

What Providers Need to Do Before January 2027

With fewer than 100 days before the cutover, providers need to make changes across billing systems, clinical workflows, and payer contracts at the same time.

Billing Infrastructure Updates

EMR and practice management configuration

Confirm with your vendor when the 2027 code table will be loaded and how the system will handle dates of service before and after January 1. The 97155 and 97173 split and the 97180 weekly roll-up both require configuration changes. Neither is a simple code swap.

Claims testing

Ask your clearinghouse and major payers when test claims with the new codes can be submitted. Build in time to catch rejections before January, especially for the add-on codes, which must be billed alongside their base codes.

Staff training

Billers and clinicians both need training on the revised descriptors. Priorities are the difference between 97155 and 97173, the documentation requirements for 97180, and how "analysis" is defined once the Coalition publishes guidance.

Clinical Workflow Changes

BCBA session documentation

Update session templates so clinicians record whether they were directing a technician or treating the client directly. That distinction now determines the code, and it needs to be clear in the note.

97180 time capture

Set up a way for BCBAs to log non-face-to-face work in 15-minute increments as it happens, tied to one of the five qualifying activities. Decide how weekly reporting will work and who reviews the totals before claims go out.

Harmful-behavior programs

For providers that deliver severe-behavior services, confirm that staffing, on-site QHP coverage, and environment documentation meet the requirements in the new descriptors and the Coalition's crosswalk.

Payer Contract Conversations

National payers

Request 2027 fee schedules for 97173, 97180, and the harmful-behavior codes. Where rates haven't been published, ask when they will be and how authorizations will be converted.

Regional Blue plans

Blue plans set policy at the state level, so timelines and rates may vary across a multi-state footprint. Confirm each plan's approach separately.

Medicaid programs and MCOs

State Medicaid programs will need to add the new codes to their fee schedules. Providers should ask their state agency and MCOs about implementation timing. Where a program currently uses HCPCS codes for indirect clinician work, ask whether those will be retired, kept, or mapped to 97180.

Key Risk Factors

Authorization gaps

Authorizations that include 0362T, 0373T, or 97155 and run past December 31 may not convert cleanly. Services delivered under an outdated authorization risk denial. Providers should get written confirmation of each payer's conversion process.

97155 and 97173 miscoding

Billing direct BCBA treatment under 97155 after January 1, or the reverse, creates denial and audit exposure. Clear documentation of what the clinician was doing is the main safeguard.

Uncovered 97180 time

A CPT code does not guarantee coverage. If payers are slow to add 97180 or set low rates, clinics that change workflows expecting new revenue may not see it right away. Track coverage payer by payer before building 97180 into revenue forecasts.

Rate uncertainty

With all codes carrier-priced, rates for the new codes may vary widely across payers and states. Multi-state and multi-payer providers should expect uneven reimbursement through at least early 2027.

Telehealth coverage for new codes

Until the final Medicare rule is published and payers update their policies, providers should not assume the new codes can be delivered or supervised by telehealth, beyond the on-site QHP allowance described in the crosswalk.

What It Takes to Enter 2027 in a Strong Position

The 2027 code set changes how BCBA time is documented and reimbursed. 97180 creates a new billable path for work that has historically been bundled or unpaid. The 97155 split and new harmful-behavior codes also bring changes to session documentation and authorization requirements.

The remaining weeks of 2026 are a good window to work through those changes: identify the services affected, update documentation and billing workflows, review existing authorizations, and start confirming payer-specific requirements for the new codes and rates.

By January, teams should have a working plan for each major payer: which codes they will bill, what documentation will support them, which services need new or updated authorizations, and what reimbursement to expect. Getting those pieces in place now gives providers a cleaner path into the new year and fewer billing issues to work through once the changes take effect.

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