Missouri Provisional Analysts Without a Degree Can Bill Only Three ABA Codes

A MO HealthNet bulletin posted March 13 but effective February 1 limits provisional licensees who haven't finished their degree to 97152, 97153 and 97154. Anything else they billed is subject to recoupment, and MMAC will ask for the degree date.

MO HealthNet Provider Bulletin Volume 48, Number 50, posted March 13, 2026, took effect six weeks before it was published. From February 1, 2026, provisional licensed behavior analysts and provisional licensed assistant behavior analysts “who have not completed educational requirements consistent with those of the Behavior Analyst Certification Board (BACB) may only render” three services until they complete their degrees:

  • 97152 (supporting assessment)
  • 97153 (treatment by protocol)
  • 97154 (group treatment by protocol)

Billed with modifier HO for a provisional LBA, or HN for a provisional LaBA.

The turn: the recoupment reaches back to February

“Effective for dates of service on or after February 1, 2026, claims paid for services beyond those listed above (e.g., procedure codes 97151, 0362T, 97155, 97156, 97157, 97158, 0373T) that are performed by provisional licensees who have not completed educational requirements as above will be subject to recoupment.”

Those are the codes a provisional analyst is usually hired to bill: assessments, protocol modification, and family guidance. A clinic that learned of the bulletin in March, or hasn't yet, may have up to seven months of exposed claims.

How it will be found

“When conducting post-payment reviews, the Missouri Medicaid Audit and Compliance Division (MMAC) will request documentation of degree completion and date.” The degree date decides which claims are clean. Claims after it are fine, and claims before it on a restricted code aren't.

The limits

The bulletin applies to fee-for-service and says it “may apply” to managed care, where each plan decides. It's titled “Revised,” but we couldn't find the earlier version. Missouri law already makes a provisional licensee practice under a licensed supervisor's “full professional responsibility and control” for at most two years. This bulletin adds a billing limit on top of that.

What you must know or do

  • Owners: list every provisional LBA and LaBA you've employed since February 1, with the date each completed their degree. Put the diploma or transcript in their file, because MMAC will ask for it.
  • Billers: pull fee-for-service claims under each provisional NPI dated between February 1 and that degree date for 97151, 97155, 97156, 97157, 97158, 0362T and 0373T. That's your exposure.
  • Consider a self-disclosure through MMAC's provider self-disclosure process for any you find, rather than waiting for a review.
  • Managed care: ask each Missouri MCO in writing whether it applies the restriction.