Medi-Cal Now Names Eight Things a Parent-Training Note Must Contain

The November 2025 update to the Medi-Cal BHT manual writes the fee-for-service pathway into the rulebook, flags 97153 and 97154 as billable by QAS Paraprofessionals, bars H2014 from group services, and puts S5110 and S5111 under a documentation-and-audit regime.

Medi-Cal opened a fee-for-service route to Behavioral Health Treatment on July 1, 2025: members under 21 can get BHT from an enrolled Medi-Cal fee-for-service provider rather than through a Regional Center. Four months later the Provider Manual's BHT section was rewritten to say how that gets billed. Pages 1 and 4 through 14 carry a November 2025 stamp.

If your California revenue is managed care, stop here — the manual says plainly that managed care members “receive BHT services from their managed care plan,” governed by an All Plan Letter instead. This section is the fee-for-service rulebook.

The turn: the family-training codes got an audit regime

S5110 (home care training, family, per 15 minutes) and S5111 (per session) have been billable for years without scenario-level instruction. Now the manual lists eight things the note must contain:

  • Date and duration of the session
  • Name and credentials of the provider
  • Names and relationships of family members trained
  • Clinical goals and topics covered
  • Method of instruction, for example demonstration, discussion, written materials
  • Member and family engagement and response
  • Link to treatment plan or curriculum, when billing S5111
  • Plan for follow-up or reinforcement

The third one is the one most notes will fail. And the manual is explicit about where this lands: providers must “maintain appropriate documentation and make that documentation available to DHCS upon request and in the event of a state or federal audit.”

Picking between the two codes is now defined by what happened rather than by how long it took. S5110 is “brief, targeted or intermittent training … usually less complex and shorter in duration but may be time-variable.” S5111 is the structured, curriculum-based session. And: “Providers may not bill both HCPCS codes S5110 and S5111 on the same date of service for the same Medi-Cal member for the same service.”

Three footnotes that change who bills what

The code tables carry symbols that are easy to read past:

  • 97153 and 97154 are starred: “Service may be provided by QAS Paraprofessionals.” No other ABA code is.
  • H0031 and H0032 are daggered: “The non-physician provider must be licensed.”
  • H2014 carries a double dagger: “HCPCS code H2014 may only be used for individual services. It may not be used for group services.”

On staffing, the manual removes an enrollment step and replaces it with a list you have to keep: QAS Providers and CBOs “do not need to report QAS Providers, QAS Professionals or QAS Paraprofessionals in Medi-Cal's online enrollment portal,” but must “maintain an active, current list” of all of them and produce it to DHCS on request or in an audit. The roster is the audit defense.

One September 2025 change is worth noting for what it implies: Medi-Cal does not cover “[s]ervices, supplies, or procedures performed in a non-conventional setting, including, but not limited to, resorts and spas.”

The limits

This is fee-for-service only, and only for members under 21 who do not independently qualify for Regional Center services, who have been declined by their Regional Center, or who prefer to go direct. S5111 is described as “typically 60-minute to 90-minute sessions” — a description, not a stated minimum, so do not treat 59 minutes as unbillable.

What you must know or do

  • Open your last ten S5110 or S5111 notes and check them against the eight elements. The one to look for first is whether the note names the family members trained and their relationship to the child. Most templates record that a caregiver attended, not who.
  • Pull any H2014 billed for a group session. The manual now says the code cannot be used that way, and those claims are exposed.
  • Build the QAS roster if you do not have one. Every QAS Provider, Professional and Paraprofessional, current, and producible on request. There is no portal record to fall back on.
  • Check who is delivering 97153 and 97154. Those are the two codes a QAS Paraprofessional may bill; the credential requirements are in California's Medicaid State Plan, and the star does not extend to 97155 or beyond.
  • One rule cuts your way: the provider “must not reduce the number of medically necessary BHT hours that a member is determined to need by the hours the member spends at school or participating in other activities.” Quote it when a plan tries.