← Back to list
Provider Letter 2026-14: Re: Applied Behavior Analysis Service Quality Reviews
Effective date
Sep 1, 2026
Identified
Jul 31, 2026
Summary
OHCA is implementing a mandatory Service Quality Review (SQR) process for all Applied Behavior Analysis (ABA) providers effective September 2026. Non-compliance may result in penalties, billing retractions, or referrals to Program Integrity. The policy identifies 10 specific compliance concerns including uncertified staff, inadequate documentation, misaligned CPT billing, unsigned treatment plans, and billing-documentation mismatches.
Get alerts when payers change rules like this one
We check Oklahoma SoonerCare and other payers every day and email you when a change matches your specialty and state.
Get Oklahoma SoonerCare alertsPolicy Monitoring is free. No card required.
What to do
Action · 12 steps
01Before September 2026.
02Billing team and clinical staff must conduct a comprehensive internal audit of all ABA member files to verify: treatment plans contain guardian and clinician signatures, documentation supports all hours billed, and CPT codes align with rendered services.
03Verify all RBTs and BCaBAs have current certifications and are contracted with OHCA; remove non-contracted or uncertified staff from billing immediately.
04Review all treatment plans to ensure individualization and alignment with OHCA ABA policy requirements in Oklahoma Administrative Code 317:30-5-318.
05Audit billing records to eliminate charges for non-therapy time (e.g., naps) and ensure start/stop times are clearly documented.
06Verify that services are billed under the correct rendering provider (RBT/BCBA), not incorrectly under BCBA when another provider delivered care.
07Ensure all documentation clearly identifies who rendered each service.
08Review documentation to confirm functional behavioral assessments are completed by qualified personnel, not RBTs or BCaBAs.
09Verify parent training documentation is adequate and documented.
10Update billing software and encounter forms to enforce signature requirements and documentation-to-billing reconciliation.
11When OHCA contacts with SQR date notification, review the OHCA ABA educational materials on the Provider Training webpage and prepare files for review.
12Contact OHCA Behavioral Health Unit at 800-522-0114 (Option 1 > Option 6 > Option 2) with questions.
If missed: Failure to comply during SQR may result in full or partial penalties, required billing retractions, and referral to Program Integrity.
Original notice
Provider Letter 2026-14: Re: Applied Behavior Analysis Service Quality Reviews
oklahoma.gov · Always check the source before changing claims.