The Biggest ABA Code Change Since 2019 Lands January 1. You Have Until September 14 to Say Anything.

At its September 2025 meeting the AMA CPT Editorial Panel approved the ABA Coding Coalition's application to overhaul the adaptive behavior services code set. Per the Coalition, the approved package is six new CPT codes, revised descriptors for all eight Category I codes (97151–97158), revised guidelines, and deletion of both Category III codes. Everything takes effect January 1, 2027.

That is the largest change to how ABA is billed since the code set left Category III status in 2019.

What the six new codes cover

The Coalition lists the new codes as placeholders — 97X1X, 97X2X, 97X3X, 97X4X, 97X5X, 97X6X — and describes them as introducing services for harmful behavior assessment and treatment, non-face-to-face services, and treatment with analysis.

Non-face-to-face is the line to read twice. Work that has been unbillable overhead — protocol modification away from the client, record review, care coordination — gets a code for the first time. Whether it gets paid is a separate question, addressed below.

The deleted Category III codes are 0362T (behavior identification supporting assessment) and 0373T (adaptive behavior treatment with protocol modification), both of which sit in the high-acuity, two-technician territory the new harmful-behavior codes are meant to replace.

The codes are not final, and the Coalition says so

The Coalition is explicit that the specific changes "remain confidential until released by the AMA," that "codes are not assigned, nor exact wording finalized, until just prior to publication," and that the numbers above are not official until the 2027 CPT® Professional Edition publishes late in 2026.

Anyone selling you a 2027 ABA coding crosswalk today is selling you placeholders.

The part that decides whether the new codes are worth anything

CMS issued the CY2027 Medicare Physician Fee Schedule proposed rule (CMS-1848-P) on July 14, 2026, and it announces the new and revised adaptive behavior codes. But the Coalition's own note on the rule says carrier pricing of the adaptive behavior codes continues through 2027. On the Coalition's RVU table, the "Current," "RUC," and "CMS" work-RVU columns for these codes all read C — carrier priced. There is no national Medicare value.

For an ABA provider that means the practical consequence is not a Medicare rate. It is that six new codes arrive on January 1, 2027 with no benchmark valuation, and every commercial and Medicaid contract you hold has to price them one payer at a time. Contracts that enumerate 97151–97158 by number — most of them — do not contain the new codes at all.

The deadline

The comment period on CMS-1848-P closes September 14, 2026. Comments go to regulations.gov under file code CMS-1848-P. The final rule is expected in November.

There is a second reason to look at this rule. Holland & Knight's summary notes it carries an extensive request for information questioning the CPT Editorial Panel and AMA/RUC processes themselves, asking stakeholders about alternative coding frameworks. The ABA code set was just rebuilt through exactly that process. If CMS is reconsidering the machinery, the field that most recently depended on it has something specific to say.