MedicaidCoverageHigh impact
Updated Reminder: Requirements for Research-Based Behavioral Health Treatment Service Delivery – Aug. 31, 2026
NC Medicaid - NCDHHS·NC · Psychiatry, Pediatrics·Specialty Services
Effective date
Aug 1, 2026
We identified it
Sep 1, 2026
Summary
NC Medicaid updated its Research-Based Behavioral Health Treatment (RB-BHT) policy effective August 1, 2026, with critical changes affecting paraprofessional staffing, telehealth delivery, and treatment authorization. Paraprofessionals must obtain RBT or ABAT certification within 120 days or services become non-reimbursable; telehealth is eliminated for paraprofessional-delivered services (CPT 97152-97154); and treatment plans exceeding 16 hours weekly now require reauthorization every three months. Billing teams must immediately stop accepting telehealth claims for these codes and implement staffing verification workflows.
Action Required
REQUIREMENTS:
By September 30, 2026 (120-day grace period deadline): Billing team must verify all paraprofessionals delivering RB-BHT services hold current RBT (BACB) or ABAT (QABA) certification. Update billing software to flag any paraprofessional without certification and block claim submission after grace period expires. Administrative staff must maintain certification tracking database and alert clinical leadership to non-compliant staff.
Immediate (as of policy publication Aug 31, 2026): Billing team must STOP accepting and processing any telehealth claims for CPT codes 97152, 97153, and 97154 submitted for paraprofessional-delivered services, effective retroactively to August 1, 2026. Update billing system to reject these codes for telehealth modality. Contact affected beneficiaries and providers to notify of telehealth elimination for paraprofessional services. CPT 97155 (LQASP supervision) may continue via telehealth if clinically appropriate per CCP 1H.
By October 31, 2026: Billing team must reprogram prior authorization logic to automatically require 3-month reauthorization intervals for any RB-BHT treatment plan authorizing more than 16 combined weekly service hours (all RB-BHT codes counted). Existing authorizations retain current durations; new reauthorization requests must enforce 3-month limits. Providers must be notified via bulletin or portal notice.
Ongoing: Billing team must implement claim validation rules confirming LQASP supervision documentation (minimum 10% observation ratio for paraprofessionals) is attached to claims before payment processing. Deny claims from non-certified paraprofessionals after September 30, 2026. Update encounter forms and provider manuals to clarify non-reimbursable activities (transportation, childcare, nap time, recreational activities without therapeutic goals, academic tutoring, IDEA-duplicative services, staff-only training).
Consequences: Claims billed after grace period expires for uncertified paraprofessionals will be systematically denied. Telehealth claims for CPT 97152-97154 will be denied. Non-compliant authorizations (>16 hours without 3-month reauth) will be subject to recoupment.