If You Stopped Billing ABA Alongside Behavioral Health in Maryland, You Read It Backwards — and You May Be Owed Money

Maryland Medicaid's ABA Transmittal No. 8 — PT 42-26, issued December 18, 2025 by Monchel Pridget, Acting Director of the Office of Medical Benefits Management — is widely summarised as restricting concurrent billing. It does the opposite. The operative sentence:

"Effective January 1, 2026, ABA services may be billed on the same date of service as behavioral health services when clinically appropriate, with the exception of the following codes: (1) Therapeutic Behavioral Services (96156, 96158, 96159); and (2) Electroconvulsive Therapy (90870)."

Same-day ABA and behavioral health is permitted. Four codes are carved out. The transmittal adds that this "applies to all ABA procedure codes" and that "all other billing parameters, including unit limits and service requirements, remain the same."

The paragraph worth checking your remittances against

The transmittal does not only change the rule going forward. It undoes the past:

"Any claims adjudicated by Carelon Behavioral Health, which were denied for a combination of services other than those listed above, will be reprocessed and paid as appropriate. No provider action is required, and claims will be processed automatically."

That is a commitment to pay claims that were previously denied, without an appeal, a corrected claim, or a phone call. Which means there is exactly one thing to verify: did it happen? An automatic reprocessing that silently did not run looks identical, from the provider's side, to one that was never promised.

Pull your combination-of-service denials from before January 2026 and confirm each one was either reprocessed and paid, or falls into the four carved-out codes. If a denial is neither, it is the one category the transmittal says should not exist.

H2012 is gone

Effective February 1, 2026, procedure code H2012 (ABA Treatment Planning) was discontinued "to align with national ABA coding standards and other state Medicaid ABA programs." In its place:

• Treatment planning should be incorporated within 97151 as clinically appropriate.
• Coordination of care should be incorporated within 97156 as clinically indicated.

Authorizations for H2012 granted up to and including January 31, 2026 are honoured through their end date. New authorization requests for H2012 submitted on or after February 1, 2026 are administratively denied — though the transmittal is careful to note that other codes in the same request are still reviewed for medical necessity, so one dead code does not stall an entire authorization.

Why a nine-month-old transmittal is worth reading now

Because the misreading is still circulating, and because a provider who restructured scheduling to avoid same-day billing has been leaving revenue on the table every week since January for a rule that says the opposite of what they were told.

It is also a useful corrective to the direction-of-travel story. Most state ABA news this year has been restriction — hour caps, lifetime limits, rate reductions, tighter authorisation. Maryland loosened a billing rule, refunded the claims it had wrongly denied under the old one, and retired a code to match national standards. That is not the pattern, and it is worth knowing the pattern has exceptions.

What you must know or do

• Confirm your billing rules permit same-day ABA and behavioral health except 96156, 96158, 96159 and 90870. If your clearinghouse or scheduler still blocks it broadly, that is your own configuration, not Maryland's rule.
• Audit pre-January combination denials for reprocessing. No action was required of you — verification still is.
• Confirm H2012 is out of your code set and that treatment planning is being captured in 97151 rather than dropped.
• Questions on the transmittal go to Nichole Walsh-Meadows, Division Chief of Children's Services, at the Maryland Department of Health.