North Carolina Just Did It. Your State Is Reading the Same Memo.
New RB-BHT rules took effect 1 August: mandatory technician certification, telehealth removed for paraprofessional codes, and a hard cap on remote supervision billing.
North Carolina Medicaid's updated Clinical Coverage Policy 8F for Research-Based Behavioral Health Treatment took effect on 1 August 2026, with a new in-state provider enrollment requirement following on 2 August. The changes are specific, dated, and enforceable — the opposite of a toolkit.
Technician certification is now mandatory
Paraprofessionals must hold at least one qualifying certification: RBT (BACB) or Applied Behavior Analysis Technician (QABA). Existing paraprofessionals without one have a 120-day grace period starting 1 August. New hires have 120 days from their hire date.
Telehealth is materially narrowed
- Telehealth is removed entirely for paraprofessional RB-BHT services — CPT codes 97152–97154.
- For Licensed Qualified Autism Service Providers, telehealth may be used for at most 50% of total 97155 billing per beneficiary per 180-day period.
Supervision and authorization
- At least 10% of paraprofessional-delivered services must involve direct observation and direction by an LQASP.
- Treatment plans exceeding 16 hours weekly require reauthorization every three months.
- Service-hour ratio requirements apply once a paraprofessional exceeds 200 hours in six months.
Why this matters outside North Carolina
Look at the CMS toolkit published three days later and the overlap is hard to miss: credentialing, telehealth limits, supervision evidence, progress-based reauthorization. North Carolina is not an outlier — it is an early implementation of a direction being set nationally.
What you must know or do
In North Carolina, the clock is already running. The 120-day grace period for existing paraprofessionals started on 1 August; new hires get 120 days from their start date. Certification has to be scheduled, sat and processed inside that window, so the date you actually need to work back from is earlier than the deadline. Count the paraprofessionals on your roster without RBT or QABA certification today, and give each one a date.
Two more that change how you operate rather than what you file: telehealth is gone entirely for paraprofessional services under 97152–97154, and LQASP telehealth is capped at half of 97155 billing per beneficiary per 180 days. If either carries a meaningful share of your delivery, that is a staffing question this quarter.
If you operate elsewhere, the useful exercise is not to comply with CCP 8F. It is to ask which of these five requirements your documentation would already survive — because the CMS toolkit published three days later points every other state at the same five.