Indiana Says ABA Clients Can't Be Kept From Napping Because Naps Aren't Billable

Indiana Health Coverage Programs bulletin BT2026159, issued September 29, opens with its reason: “media reports that members receiving [ABA] therapy services are only permitted to nap for seven minutes at a time, if at all.” Its rule: “Members must not be prevented from napping during ABA therapy hours due to it being nonbillable time.” The bulletin gives no separate effective date.

The turn: naps aren't billable, and they're now required

Nap time was already unbillable. North Carolina's August 31 Medicaid bulletin lists “nap time, break time or transportation” among activities RB-BHT doesn't cover, and Indiana keeps it nonbillable too. What's new is that a nap is now something the provider must plan for and document, and a shortfall in 97153 hours has to be explained by it. A CMS official made the same point to Florida's ABA task force on August 31. The approved minutes record Dr. Caprice Knapp's recommendation to “Establish a written policy for naps and breaks.” Indiana has now written one.

What the policy requires

• Age-appropriate nap time, per American Academy of Pediatrics sleep recommendations and coordinated with parents, goes in the schedule of services in the treatment plan.
• Sleep-related comorbidities need coordination with the primary care provider, documented in the plan.
• If naps become necessary mid-authorization, the plan must record their duration, the date they became consistent, each date they titrate and the date they stop. “Robust documentation must explain less 97153-hour utilization.”
• “Members must not be kept awake or woken up by physically moving them, forcing them to engage in activities, tickling or other efforts.” They may be woken after the AAP-based duration, but not by being moved.
• If a child is repeatedly sent home for naps or exceeds recommended nap time, the provider and family must adjust the schedule and hours, and document it.

The limits

The bulletin says not every child who qualifies for a nap by age will need one. It doesn't say how a reviewer will treat unused authorized hours that the nap documentation explains. It's one of four Indiana ABA bulletins issued that day, including the FBA requirement effective October 29.

What you must know or do

• Clinical directors: check every Indiana Medicaid treatment plan for a client young enough to nap. If the schedule of services has no nap block, add one with its duration.
• Center managers: retire any practice of waking or keeping children awake by moving or engaging them. Put the bulletin's wording in staff training this month.
• Billers: when 97153 use runs below authorization, check that the plan records the nap dates and durations that explain it before the next reauthorization.