NC Stops Paying for Uncertified ABA Technicians in Late November

On August 14 we reported North Carolina's new ABA rules from NC Medicaid's August 5 bulletin. On August 31, NC Medicaid replaced that bulletin “in full.” The certification clock hasn't moved: existing paraprofessionals without RBT or ABAT certification got a 120-day grace period starting August 1. That ends in late November, November 28 or 29 depending on whether August 1 counts as day one. NC Medicaid hasn't printed an end date. That's about eight weeks from now.

What's new since our first story

• A payment sentence that wasn't there before. “Claims billed for services delivered by non-certified paraprofessionals will not be reimbursed after the uncertified paraprofessional's 120-day grace period expires.”
• The supervision rule was rewritten. August 5 said uncertified staff “require direct oversight by a [LQASP] any time they are providing a service.” August 31 says they “must receive supervision from a [LQASP] when services are provided during the grace period,” with ongoing supervision following “guidance per the accrediting body and CCP 8F.”
• Two billing warnings. “Incidental supervision and training of the paraprofessional are not reimbursable.” And “to bill 97155 all Clinical Coverage Policy and CPT code elements of 97155 must be met, including medical necessity.”

The turn: the oversight is a cost, not a code

The new bulletin puts those two sentences right after the supervision rule. The extra oversight an uncertified technician needs is required, but it isn't billable as 97155 just because a supervisor was present. CCP 8F lists what's non-billable, including incidental supervision to make sure the paraprofessional “engages with and follows the employer's policies and procedures.”

The 50% telehealth cap on 97155 dropped out of the bulletin but not out of the policy. CCP 8F, amended August 1, still allows telehealth “up to a maximum of 50% of total 97155 billing per beneficiary per 180-calendar day period,” with more permitted only with clinical justification in the treatment plan.

New hires run on their own clock

Under CCP 8F, a technician must provide proof of certification “within 120 calendar days from the individual's date of hire; or the date on which the employing provider … first enrolls as a Medicaid provider, whichever is later.” A technician who misses it “must cease rendering services” until certified.

The limits

The bulletin covers NC Medicaid Direct and NC Medicaid Managed Care. It doesn't say how much supervision an uncertified technician needs during the grace period, only that it must come from an LQASP. And there's no printed end date, so the conservative reading is November 28.

What you must know or do

• Owners: list every technician without RBT or ABAT certification, with their hire date. Anyone employed on August 1 needs certification on file by November 28. Everyone else gets 120 days from hire.
• Billers: set a hold on claims for any session an uncertified technician delivers after their own 120-day date. NC Medicaid won't pay them.
• Clinical directors: audit 97155 notes from sessions with uncertified staff. Each one should document protocol modification or direction of the technician, not general oversight. Check telehealth 97155 against the 50% limit for every member's current 180-day period.