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Can CPT 97155 and 97153 Be Billed Together? Concurrent ABA Billing Rules, Documentation and Denial Prevention

  • Writer: Anne Scholfield
    Anne Scholfield
  • 22 hours ago
  • 4 min read

Yes. CPT 97155 and CPT 97153 can be billed together for the same client at the same time, as long as two different people deliver two different services and the payer allows it. This is not a loophole. The 97155 descriptor itself names simultaneous direction of a technician, so concurrent ABA billing was written into the code from the start. The problem is almost never the treatment. It is the session note.

CPT 97155 and CPT 97153

Can CPT 97155 and 97153 be billed together in one session?

Yes, when four things are true at once: two separate providers, two separate services, two separate notes and a payer policy that permits concurrent billing.

Here is what a clean hour looks like. An RBT runs the treatment plan with the child for 60 minutes and bills 4 units of 97153. During 30 of those minutes, the BCBA reviews live data, changes a prompting hierarchy, models the change and bills 2 units of 97155. Both people were face to face with the same client. Neither billed the other's work.

What has to be true on every concurrent claim:

  • The technician delivers treatment by protocol. The BCBA changes the protocol.

  • Both providers are physically present with the client.

  • The BCBA is not doing technician work during the billed 97155 minutes.

  • Each provider writes their own note under their own NPI.

One qualified professional cannot report both codes for the same block of time. That is the line payers audit hardest.


What CPT 97153 and 97155 cover in ABA therapy billing

Code

Who renders it

What it pays for

Unit

97153

RBT or technician under QHP direction

Adaptive behavior treatment by protocol, one to one

15 min

97155

BCBA or other qualified health care professional

Treatment with protocol modification, may include simultaneous direction of the technician

15 min

Both codes are time based, both follow the 8-minute rule on the final unit and most plans authorize each one separately. The full set from 97151 through 97158 is broken down in our ABA billing CPT codes guide.


Which payers allow concurrent billing of CPT 97153 and 97155?

There is no national rule. Medicare does not cover ABA for most beneficiaries, so every commercial plan and state Medicaid program writes its own concurrent billing policy.

  • Missouri Medicaid allows it when the BCBA is on site, actively supervising and modifying in real time. The note must show both providers face to face with the client simultaneously.

  • California Medicaid allows it with stricter notes. The record has to separate what the RBT did under 97153 from the exact change the BCBA made under 97155.

  • Virginia DMAS permits concurrent 97155 and 97153 for supervision activity when clinician, technician and client are all present.

  • Texas Medicaid excludes concurrent billing by multiple ABA providers during a single child session, with a narrow exception for family services delivered without the child.

  • TRICARE Autism Care Demonstration pays the higher rate and denies the other line when both codes are billed concurrently.

  • Commercial plans vary. Some pay both without friction. Others flag clinics with a high 97155 to 97153 ratio for review.

Get the policy in writing before you schedule it and confirm the concurrent rule during ABA prior authorization, not after the claim rejects.


Why concurrent 97153 and 97155 claims get denied

Denial code

What triggers it

Fix

CO-97

97155 billed same day as 97153 with no proof of separate work

Appeal with timestamped notes showing two providers, two services

CO-16

Missing HO or HN modifier or wrong rendering provider NPI

Correct at the clearinghouse before submission

CO-197

Concurrent units billed past the authorized balance

Track 97153 and 97155 balances separately, in real time

CO-11

Billed units do not match documented minutes

Match units to start and stop times to the minute

The pattern behind most of these is repetition. Both notes say "worked on tacting targets." A reviewer reads that as one service billed twice. Our breakdown of why ABA therapy claims get denied covers the wider set.


Documentation that protects concurrent ABA billing

  • Exact start and stop times on both notes, not rounded blocks.

  • The specific change: which protocol, what changed and the data that prompted it.

  • How the client responded after the change.

  • Different language in each note. The RBT describes delivery. The BCBA describes the decision.

  • The correct credential modifier on each line, usually HO or HN.

  • Both providers named, each with their own rendering NPI.

Skip observation language. "Observed session" and "provided supervision" are the two phrases that turn a valid 9715 5 into a recoupment. Vague notes are one of the most common ABA billing problems we find in clinic audits.


Frequently asked questions


Can a BCBA bill 97155 while the RBT bills 97153 for the same client?

Yes, when the BCBA modifies the treatment protocol in real time while the RBT delivers treatment, both are present with the client and each writes a separate note. The same person cannot bill both codes for the same minutes. Payer policy still decides whether both lines get paid.


Do you need a modifier to bill 97155 and 97153 concurrently?

Most payers require credential modifiers such as HO for a master's level clinician and HN for a bachelor's level provider, applied per line rather than per claim. Some plans also want distinct rendering NPIs on each line. Missing modifiers trigger CO-16 denials more often than the concurrent rule itself.


Can 97155 be billed without the client present?

No. CPT 97155 requires the client to be face to face with the BCBA. Chart review, treatment planning, team meetings and supervision without the client are not billable under 97155 for most payers. If the client is not in the room, the code does not apply.


Getting concurrent CPT 97155 and 97153 billing right before the claim goes out

Concurrent billing of 97155 and 97153 is legitimate, spelled out in the code set, and worth real money to a growing practice. It is also one of the easiest lines to lose in an audit. Clinics that keep the revenue check payer policy first, write two clearly different notes and watch authorization balances weekly. If concurrent lines are aging in your report, our ABA therapy billing team and AR management process can find where they stall.


 
 

Denied claims, credentialing gaps, or payment delays draining your revenue?

 

Pacemave helps therapy practices fix billing issues before they impact cash flow.

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