Beginning in January 2026, Blue Cross has updated documentation expectations related to CPT® code 97153 (adaptive behavior treatment by protocol, administered by a technician under the direction of a qualified professional, billed in 15-minute increments). Specifically, progress notes for CPT® 97153 are now limited to 2 hours and 30 minutes (10 units) per progress note.
Blue Cross Blue Shield of Michigan (BCBSM) values our partnership with Applied Behavior Analysis (ABA) providers and recognizes the essential role they play in delivering high-quality, medically necessary care to our members.
Our goal with all policy updates is to support clear clinical communication, appropriate supervision and continuity of care while aligning with established documentation standards across behavioral health.
Purpose of the change
Progress notes serve as more than a billing requirement, they are a clinical record that supports treatment planning, coordination of care and clinical oversight. When a single progress note spans an entire day of services (e.g., eight to 10 hours), it can be challenging for supervising clinicians, reviewers or other treating providers to clearly understand the interventions delivered, patient response and progression of care.
Segmenting documentation into 2.5-hour intervals is intended to:
- Improve clarity and clinical usefulness of notes
- Better reflect changes in skill acquisition, behavior or environment throughout the day
- Support continuity of care when multiple providers or reviewers are involved
This approach is consistent with time-based documentation standards used throughout behavioral health and medical care, including psychotherapy services and Evaluation and Management (E&M) codes, where services are documented in defined service segments.
Impact on provider workflow
We recognize there may be provider concerns regarding administrative burden and documentation time. Our intent is not to increase paperwork, but to encourage documentation that is clearer, more focused and clinically meaningful. Many providers already document in shorter intervals as part of routine clinical practice.
Because ABA treatment is dynamic, multiple shorter notes may more accurately reflect the course of care than a single, lengthy summary. Additionally, segmented documentation can help reduce audit risk by clearly demonstrating:
- What services were delivered
- When they occurred
- How they aligned with the treatment plan
Supervising provider signature requirements
Under Michigan licensing regulations, the Licensed Behavior Analyst (LBA) is the treating professional responsible for supervising ABA services and submitting claims. Requiring the LBA’s signature on technician-rendered service notes supports:
- Appropriate clinical oversight and supervision
- Alignment with state licensing and scope-of-practice requirements
- Accountability for services billed under the LBA’s provider number
While technicians play a critical role in care delivery, they may not independently treat or bill for services. The LBA signature requirement reflects this regulatory framework.
Blue Cross remains committed to ensuring members continue to have timely access to medically necessary ABA services. This documentation update is not intended to create barriers to care or disrupt established treatment models. Rather, it reflects our responsibility to support high-quality, well-documented care that meets professional standards and regulatory expectations.
By aligning ABA documentation with widely accepted, time-based clinical practices across behavioral health and medicine, we aim to strengthen the integrity of the clinical record while preserving continuity of care.
Clear, focused documentation supports treatment planning, supervision, care coordination and medical necessity determinations, ultimately helping ensure services remain accessible and sustainable over time.
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