MedicaidAdministrativeHigh impact
Mandatory RBT Credential, 90-day Grace Period, and Billing Compliance for ABA
Missouri Medicaid (MO HealthNet)·MO · Occupational Therapy, Speech Therapy·Provider Notice
Effective date
Jun 26, 2026
We identified it
Jun 27, 2026
Summary
MO HealthNet implemented a mandatory credential requirement for Registered Behavior Technicians (RBTs) with a 90-day grace period for new staff to obtain BACB certification. Billing teams must immediately track all uncredentialed behavior technicians, flag their grace period milestones (days 30, 45, 60), and stop submitting claims on day 91 if certification is not obtained. Non-compliant claims submitted beyond the 90-day window are subject to full recoupment.
Action Required
Immediately: (1) Billing team must audit all current uncredentialed BTs on staff and document their initial competency assessment dates. (2) Establish and implement internal tracking system in billing software or spreadsheet to flag each BT at day 30, 45, and 60 of their grace period to ensure exam completion before day 91. (3) Configure billing system rules to prevent claim submission for any BT without active BACB credential verification after day 90 from their initial competency assessment date. (4) Create stop-billing protocols and alerts for BTs reaching day 91 without active RBT status. (5) Verify BACB registry credentials before each claim submission for currently uncredentialed BTs. Consequences of inaction: All claims submitted for services rendered by uncredentialed RBTs beyond day 90 will be denied and subject to immediate, full recoupment by Missouri Medicaid Audit and Compliance (MMAC).