Attention New Hampshire Medicaid ABA Providers
On Thursday, June 26, 2025, New Hampshire Medicaid released the bulletin "Updates to Applied Behavioral [sic] Analysis Service Codes”, announcing changes to multiple ABA service codes.
The most concerning of the changes announced was "CPT code 97155 will no longer be reimbursable for supervision of a technician...[as] NH Medicaid does not allow for reimbursement solely for supervision." In a move that signals a misinterpretation of the actual use and definition of the CPT code, rather than seek clarification on the distinction between ‘supervision’ and ‘protocol modification,’ NH Medicaid reclassified the code and will no longer cover the services rendered under 97155.
Immediately upon receipt of this bulletin, NHABA had gathered resources and expertise including CASP, The ABA Coding Coalition, past Board members, and representatives from ABA practices across the state. DHHS heard from those groups, and from you, in a truly impactful way.
NHABA met with representatives from DHHS to reiterate your messages and to advocate for a complete reversal of this decision. While we are not quite there yet, we are happy to announce that there is time for us to work together to influence this decision. The timeline for implementation of the changes has been extended to September 1, 2025. Between now and then, there are steps that we can all take to effect change.
First, DHHS is opening a public comment period. See the announcement and more details about the changes that were not included in the original bulletin here.
We encourage all ABA providers to closely monitor the above linked page and to request a copy of the amended state plan when it is available.
We also encourage providers to submit their comments about the actual services provided under 97155 (protocol modification as opposed to “supervision”), and the various consequences of eliminating coverage for BCBA oversight and direction. Consider providing insight into the use of 97154 for multiple patients by one provider and how that differs from serving multiple patients individually at the same time in “group settings.” Clear and descriptive narratives from experienced practitioners will help DHHS to fully understand the services that we provide and how they are captured in the CPT codes that they propose changing.
In addition to comments from provider groups, please spread the word to individual providers, patients, advocates, family members, and friends. CASP has put together a Voter Voice Campaign where stakeholders can easily make their voices heard. Share this campaignwith providers, and this one with other stakeholders. The tools in the Voter Voice Campaigns make communicating with decision makers simple and straightforward.
NHABA is collecting comments from providers and will draft an official response on behalf of members. We invite you to participate by sending along your thoughts to admin@nhaba.net.
We have more meetings scheduled with DHHS between now and the extended implementation date. Expect to hear from us as we know more. Watch our social media and our website, and renew your membership to make sure you keep receiving updates as this campaign unfolds.
