Meridian Recoups 10 Hours of ABA for Every Missing Hour of Supervision

Meridian's Illinois Medicaid plan reviews ABA claims after payment for at least one hour of 97155 per 10 hours of direct treatment. Fall short and it takes back the treatment hours the supervision should have covered.

Meridian Health Plan of Illinois told its ABA network, in a notice dated September 17, 2025, that it “will review claims retrospectively to ensure that there is a minimum of one hour of supervision billed for each 10 hours of direct treatment. If supervision is not provided at the appropriate level, the corresponding treatment services will be subject to recoupment.”

The notice doesn't set a start date or a lookback window. It describes a review that's already running.

The turn: the penalty is ten to one

Meridian's own example: a member receives 100 hours of 97153 and 6 hours of 97155. Meridian “would request repayment of 40 hours of CPT® 97153, as the 10% supervision requirement was not met.” Six supervision hours cover 60 hours of treatment. The other 40 get recouped.

So every supervision hour short costs ten hours of technician time. A client sitting right at the 10% minimum who misses two one-hour supervision sessions puts 20 treatment hours at risk.

What else the notice sets

  • 40-hour weekly ceiling. “Services billed for more than 40 hours in any week will be denied.”
  • Prior authorization for all ABA services.
  • The benchmark. Meridian cites CASP's recommendation of one to two hours of case supervision per 10 hours of direct treatment, and enforces the bottom of that range.

The limits

The notice's example contains two typos: “97513” for 97153 and “CP.BH.10” for the clinical policy, CP.BH.104. It doesn't say whether the ratio is measured per week, per month or per authorization period, and it doesn't define the lookback. Our September 21 article covered how Illinois plans handle prior authorization after the state's outpatient ban. This is a different rule.

What you must know or do

  • Billers: for every Meridian member, divide billed 97155 hours by billed 97153 hours over each authorization period so far. Anything under 10% is exposed.
  • Calculate the exposure the way Meridian does. Multiply the supervision shortfall by ten to get the treatment hours at risk.
  • Clinical directors: schedule supervision to at least 10% of direct hours for Meridian clients from now on, and reschedule missed supervision in the same period.
  • Owners: check your 40-hour weekly edits so no Meridian week goes over.