Provider Letter 2026-14: Re: Applied Behavior Analysis Service Quality Reviews

Before September 2026: (1) Billing 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. (2) Verify all RBTs and BCaBAs have current certifications and are contracted with OHCA; remove non-contracted or uncertified staff from billing immediately. (3) Review all treatment plans to ensure individualization and alignment with OHCA ABA policy requirements in Oklahoma Administrative Code 317:30-5-318. (4) Audit billing records to eliminate charges for non-therapy time (e.g., naps) and ensure start/stop times are clearly documented. (5) Verify that services are billed under the correct rendering provider (RBT/BCBA), not incorrectly under BCBA when another provider delivered care. (6) Ensure all documentation clearly identifies who rendered each service. (7) Review documentation to confirm functional behavioral assessments are completed by qualified personnel, not RBTs or BCaBAs. (8) Verify parent training documentation is adequate and documented. (9) Update billing software and encounter forms to enforce signature requirements and documentation-to-billing reconciliation. (10) When OHCA contacts with SQR date notification, review the OHCA ABA educational materials on the Provider Training webpage and prepare files for review. Contact OHCA Behavioral Health Unit at 800-522-0114 (Option 1 > Option 6 > Option 2) with questions. Failure to comply during SQR may result in full or partial penalties, required billing retractions, and referral to Program Integrity.