The 2027 ABA Coding Guide Is Out: 97180 Bills Weekly, and Not for Session Notes

On October 5 the ABA Coding Coalition posted its supplemental guidance for the 2027 adaptive behavior codes, and on October 8 a template letter for providers to send their payers. When we covered the new code numbers on September 16, the descriptors left open who has to be on site, what 97180 actually covers and what happens to 0362T and 0373T. The guidance answers all three, and the new codes take effect January 1, 2027, 83 days from now.

The turn: the new code comes with a list of exclusions

97180 makes the analyst's non-face-to-face work billable for the first time. The guidance is just as specific about what it doesn't cover, and several of those exclusions are things a BCBA does every week. If 97180 goes into authorization requests as a catch-all for indirect time, it'll be billed for work the Coalition says isn't reportable.

What the guidance says

• 97180 covers five things: reviewing and analyzing data and session notes; deciding whether to change targets, goals or protocols (and making the change); deciding whether more assessment is needed; discharge or transition planning; and patient-specific technician training without the patient present.
• 97180 doesn't cover: writing session notes, internal quality assurance or audit review, general technician training (behavior principles, CPR, agency policy), care coordination, or administrative discharge work like payer notices and records transfers. The technician's time in a 97180 training isn't billable either.
• It's billed weekly. Document each date separately, add up a 7-day period (for example, Sunday through Saturday) and report the total on one claim line. The patient's cost share, if any, applies to that one date.
• 97151 and 97180 can't be billed on the same day for the same patient.
• 97155 is no longer a dual-use code. It's only the QHP directing a technician with the patient present, and it's always billed alongside a technician code (97148/97149, 97153, 97154 or 97159/97160). If the QHP treats one patient with no technician, that's 97173. 97173 and 97155 can't be billed concurrently, and neither can 97152 and 97155. If a QHP sits in on a supporting assessment, that time isn't billable.
• Covering for a technician: if a QHP fills in and simply runs the protocol, bill 97153. Use 97173 only when the QHP is also analyzing whether targets or protocols need to change.
• Harmful-behavior codes: for 97148, 97149, 97159 and 97160 the QHP must be on site and immediately available. The Coalition says telehealth can meet that requirement where it's medically necessary and clinically appropriate, but only if the payer and state law allow it. Pulling in a second technician during a scheduled 97151 or 97152 session doesn't turn it into 97148 unless every element, including the customized environment, is there.
• Groups: the 8-patient maximum for 97154, 97157 and 97158 is gone. The QHP sets group size, but payer limits still apply.
• No grace period: 0362T and 0373T are invalid for dates of service on or after January 1, 2027. Payers don't all have to load the new codes on January 1, though.

What an authorization looks like after the split

The guidance includes a sample six-month authorization. In 2026, 312 units of 97155 cover both directing a technician and the analyst's own one-to-one work. In 2027 that becomes 208 units of 97155 plus 104 units of 97173, and 52 units of 97180 (half an hour a week) appear where nothing was reportable before. The Coalition cites CASP's average of 1 to 2 hours of QHP activity for every 10 hours of 97153, and says that isn't a formula for any single code.

The limits

The Coalition says its clinical examples aren't meant to set medical necessity criteria, staffing practices or documentation standards. The binding guidelines are in the AMA's copyrighted CPT 2027 book. HIPAA requires payers that accept electronic claims to use Category I codes. It doesn't decide whether they cover a code, what they pay for it or how they authorize it, so 97180's value is still negotiated one payer at a time. As of October 10, CMS hasn't published the CY2027 physician fee schedule final rule.

What you must know or do

• Owners: send the Coalition's template letter, or your own version, to every payer this month. It asks six questions in writing: the date the new codes load in the payer's claims system; the payer's crosswalk and how it differs from the Coalition's; the contracted rate for each new code; whether current authorizations convert automatically or need new requests, and the submission window; how claims that span the transition will be handled; and when providers will be notified. Keep each payer's answers in one tracker.
• Owners and billers: list every client whose authorization includes 0362T or 0373T after December 31. Those units stop being valid on January 1 with no grace period, so ask for replacement 97148/97149 or 97159/97160 units now.
• BCBAs: log one week of your non-face-to-face time and sort each entry into the five 97180 activities or the excluded list. Note-writing and QA review go in the excluded column.
• Clinical directors: add a 97180 log (date, minutes and activity for each entry) and a weekly roll-up to your documentation before January 1. Make sure 97155 and 97173 note templates have a line for the analysis, including a documented decision when nothing changes.
• Billers: set up edits that block 97151 and 97180 on the same date and 97152 with 97155.