Missouri Gives a Behavior Technician 90 Days. Day 91 Is a Full Recoupment.

MO HealthNet ran a series of applied behavior analysis tips this year. They are short, they announce nothing new, and they all land in the same place: the division can take back money it has already paid.

The June 26, 2026 tip is the one with teeth.

“A behavior technician (BT) may render services for up to 90 calendar days from the date they pass their RBT™ initial competency assessment.”

Read where the clock starts. Not the hire date, not the exam registration date, not the date training was completed. The date the technician passed the initial competency assessment — a date that lives in the supervisor's records, not usually in payroll or credentialing.

What day 91 costs

The technician “must successfully pass the national RBT™ examination and be fully credentialed by the Behavior Analyst Certification Board (BACB) by the end of this 90-day grace period.” If they do not, they “must immediately stop providing ABA services to MO HealthNet participants.”

Then the consequence, and it is not a claim denial:

“All paid claims for these unauthorized services are subject to immediate, full recoupment.”

Claims for services past day 90 are “considered non-compliant.” Missouri Medicaid Audit and Compliance is the office that acts on it. A practice that discovers this in an audit is not looking at future revenue it will not collect; it is looking at revenue it has already spent.

Field 24J has two opposite rules

The May 28, 2026 billing tip covers the rendering provider field on the CMS-1500, and it splits by who delivered the service:

• Behavior analysts and assistant behavior analysts enter their own NPI. The tip is explicit: do not use the supervisor's NPI.
• Provisionally licensed practitioners also enter their own NPI, not the supervisor's.
• Behavior technicians and RBTs enter the supervisor's NPI.
• Solo practitioners leave the field blank.

Two of those are the reverse of each other on the same box, sorted by credential. A biller who learned one rule and applied it across the board is wrong on roughly half the claims.

Signatures, and the five-day window

The same tip sets the note rules. “The person who delivered the service must sign the session note,” and “supervisors cannot sign in place of the provider.” For a technician-delivered session the note is signed by the technician and co-signed by the licensed supervisor. Electronic signatures have to securely authenticate the signer and carry a clear electronic notation.

The March 10, 2026 documentation tip adds the timing. Services must be “documented in the health record within five business days to be considered timely,” measured against the adequate-documentation definitions at 13 CSR 70-3.030(2)(A). The division recommends the Council of Autism Service Providers session note templates as a resource and then says plainly that “use of the CASP templates does not guarantee immunity from audits.”

Its consequence line matches the others: “Failure to adequately document services could result in post-payment recoupment.”

The limits

These are hot tips, which the division uses to restate what its Behavioral Health Services Provider Manual already requires. None of the three carries an effective date, and that is the point of them — they describe what MMAC can already recoup against, not a rule starting later. The credential tip cites the manual and Provider Bulletin 47-19 rather than a regulation.

Two things the tips do not settle. The credential tip says nothing about whether a technician who passes day 90 uncredentialed may return to billing after they certify, or on what basis. And the division's ABA rate update document was not reachable on its site when we looked, so nothing here speaks to current rates.

What you must know or do

• Add one column to your technician roster: the date each person passed the RBT initial competency assessment. Day 90 is counted from there, per person, and it is the only date that matters. If that date is not recorded anywhere you can query, reconstruct it from supervisor records this week.
• For anyone past day 60 without a BACB credential, stop scheduling them beyond day 90 now. The tip says immediately stop, and the exposure is everything already paid for that technician, not the next claim.
• Pull ten recent CMS-1500s for technician-delivered sessions and check box 24J. The supervisor's NPI belongs there. Then pull ten for analyst-delivered sessions: the analyst's own NPI belongs there. If both look the same, one set is wrong.
• Pull the matching session notes and check for two signatures. A technician note signed only by the supervisor is the exact defect the May tip names, and it is a documentation finding rather than a billing one, which means it survives a clean claim.
• Check your note lag against five business days. Not five calendar days. If your average is fine but your tail is two weeks, the tail is what an auditor samples.