Nevada Gives ABA a Floor and a Ceiling, and Caps Supervision at 20%

Virginia capped ABA at 20 hours a week. Florida is studying a cap on months. Nevada did something different: it wrote two bands, and told you which one you are in.

“Focused Delivery Model: 15-25 hours per week for all ABA services. Focused ABA is treatment directly provided to the individual for a limited number of specific behavioral targets.”

“Comprehensive Delivery Model: 25-40 hours per week for all ABA services. Comprehensive ABA is treatment provided to the individual for a multiple number of targets across domains of functioning including cognitive, communicative, social and emotional.”

A band has a floor as well as a ceiling, which a cap does not. Both apply to “total combined number of units of codes 97153, 97155 and 0373T” — so supervision and protocol modification count against the same budget as direct treatment, not alongside it.

The bands are not absolute: “Delivery Model limits may be exceeded with prior authorization and documentation of medical necessity,” reviewed case by case on request. That is a stated route above the number, which Virginia's cap does not offer in the same terms.

Supervision is a ceiling here, not a floor

“Supervision is allowed up to 20% of the treatment hours.”

Read that against the rest of the country and it runs the other way. New York requires a minimum of 5% of a technician's monthly hours. Oklahoma requires a minimum of 5%. North Carolina requires at least 10% observation. Nevada sets a maximum of 20%.

Those are not in conflict — a floor and a ceiling can coexist, and a program at 8% satisfies all four. But a multi-state operator writing one supervision policy has to satisfy the tightest floor and stay under the lowest ceiling simultaneously, and nobody's template does that by accident. The number to check is not whether you supervise enough; it is whether the same number clears both ends.

The assessment clock

• Assessments do not require prior authorization — initial or re-assessment.
• But they are limited to one in every 180 days unless prior authorized.
• Adaptive Behavioral Treatment, individual and group, does require prior authorization.

That combination is easy to misread in the helpful direction. No prior authorization is not the same as no limit — a re-assessment inside 180 days needs authorization it would not otherwise have needed, and the way you find out is a denial.

Two deadlines around the request itself

• Initial request: no more than 15 business days before, and no more than 15 calendar days after, the start date of service. Note the units differ at each end — business days before, calendar days after.
• Continued service: the request “must be received by Nevada Medicaid by the last authorized date,” with 5 to 15 days prior recommended. Received by, not sent by.

The modifier that decides who gets paid

“Claims and prior authorization requests for services provided by a Licensed and Board Certified Assistant Behavior Analyst (BCaBA) and a Registered Behavior Technician (RBT) must include modifier UD.”

Specialty 312 and 314. A BCaBA or RBT service billed without UD is a claim asserting someone else delivered it.

The limits

This is the Provider Type 85 billing guide, updated July 27, 2026, and it says plainly what it is: “It is not possible to provide the most current quarterly or annual changes in this billing guide; for the most current information please reference the website.” Policy lives in MSM Chapter 3700, which we did not read here — the DHCFP link to it currently returns a page rather than the document. Rates are not in the guide either; they sit on the Rates page and in the portal's fee schedule search. Treat the numbers above as the authorization framework, not as the rate schedule, and check Chapter 3700 before relying on any of it in an appeal.

What you must know or do

• Work out which band each Nevada client is in, and whether their hours sit inside it. Focused is 15-25, comprehensive 25-40. A client at 12 hours is below the focused floor, and that is as much a mismatch as one at 45 is above the comprehensive ceiling.
• Count 97155 and 0373T against the band, not on top of it. The limit is the combined units of 97153, 97155 and 0373T. A plan that budgets direct treatment to the ceiling and then adds supervision has already exceeded it.
• Check your supervision percentage against 20%, from above. If you run a multi-state policy built to satisfy a 10% floor elsewhere, confirm it does not drift past Nevada's ceiling on a light-treatment week — the ratio moves when the denominator falls.
• Diary re-assessments at 180 days. No prior authorization is required, right up until it is, and the trigger is the calendar rather than the clinical picture.
• Audit BCaBA and RBT claims for modifier UD. One missing modifier is a claim that says the wrong person delivered the service.