Board Certified Behavior Analyst (BCBA) and Telehealth Guidance for Section 28 Providers

This notice contains guidance for providers delivering the services covered in MaineCare Benefits Manual (MBM) Chapter II, Section 28, Rehabilitative and Community Support Services for Children with Cognitive Impairments and Functional Limitations.

BCBA Services No Longer Separately Billable

Providers of Specialized Services for Children with Cognitive Impairments and Functional Limitations (Specialized Services), described in Section 28.04-2, cannot bill for the BCBA Services outlined in Section 28.04-3 because the reimbursement rates for Specialized Services account for the cost of the supervising BCBA who would deliver the BCBA Services.

This notice clarifies and updates the guidance on Section 28 services that the Department issued on January 9, 2023, which stated, “The Department anticipates that providers will bill for a standalone BCBA service (G9007 HA) only in exceptional circumstances where the service was not part of a Specialized Service model.”

Section 28 providers largely stopped billing for BCBA Services as described in 28.04-3 shortly after the January 2023 guidance. Section 28 providers who billed for BCBA services after this January 2023 guidance do not have to adjust or reverse those claims.

The Department will remove the codes for BCBA Services (G9007 HA and G9007 HA AF) from the Section 28 fee schedule and follow up with an amendment to Section 28 to integrate the Specialized Services and BCBA Services provisions so that they do not appear as separate services. The Department will subsequently take into consideration potential future coverage of standalone BCBA services, including the development of appropriate and reasonable reimbursement.

BCBAs Not Allowed to Enroll Independently

To ensure appropriate billing of Section 28 services, BCBAs and BCBA clinician groups are no longer allowed to enroll independently under their certification(s) to deliver Section 28 services. 

As described above, BCBA Services are no longer separately billable under Section 28 and Specialized Services must be delivered by a Behavioral Health Professional (BHP) with a supervising BCBA. Providers seeking to deliver Specialized Services must enroll as a Section 28 provider, employ BHP staff to deliver direct services, and be appropriately licensed in accordance with 10-144 CMR Ch. 123, Behavioral Health Organizations Licensing Rule.

Telehealth Guidance on Section 28 Services

The Department reminds providers that Specialized Services and Treatment Services for Children with Cognitive Impairments and Functional Limitations (Standard RCS), described in Section 28.04-1, must be delivered by BHPs in-person. Section 28.04 states that “treatment is provided in the home and/or community in either individual or group settings…” BHPs may deliver Specialized Services and Standard RCS through telehealth only when unforeseen and uncontrollable circumstances prevent in-person service delivery, such as:

  • Inclement weather
  • When the member leaves on unplanned travel
  • The member’s family experiences an illness that makes it unadvisable to meet in-person

Additionally, the provider must expect that the member will benefit from the service delivered through telehealth. Telehealth delivery cannot be a planned part of treatment and cannot be used for the purpose of the provider’s convenience.

The BCBA supervisor may supervise the BHP and deliver direct services to the member through telehealth. The telehealth services must comply with the telehealth requirements in MBM Chapter I, Section 4, Telehealth Services, including ensuring the service “is of comparable quality to what it would be were it delivered in person.”

For questions about what is allowed for telehealth exceptions or this guidance in general, please contact Pam Grotton, Provider Relations Specialist.