Oklahoma's ABA Quality Reviews Start This Month. The Trial Round Found 13 Problems.

The Oklahoma Health Care Authority said on July 29 that, “effective September 2026, OHCA will fully implement the Service Quality Review (SQR) process for all ABA providers.” We're in that month now. The educational version has run since August 2025, and OHCA published what it found.

What a review is

OAC 317:30-5-318, issued September 1, 2025:

• A team of one to three licensed behavioral health professionals or registered nurses.
• It reviews facility and clinical record documentation, staff training and qualifications, including records of members for whom ABA claims have been filed.
• Findings go to the provider in writing, with a copy to Program Integrity and, if applicable, licensing agencies.
• “Deficiencies identified during the SQR may result in full or partial recoupment of paid claims,” at OHCA's discretion based on severity.

OHCA's message adds that non-compliance may bring “full or partial penalties, a request to retract billing and bill correctly, or a direct referral to Program Integrity.” OHCA will contact each provider as its review date approaches.

The 13 findings

• Non-contracted and uncertified RBTs rendering services.
• Documentation not aligned with AMA guidelines for the billed CPT codes.
• Missing guardian or clinician signatures on treatment plans.
• Treatment plans not aligned with policy requirements.
• Treatment plans that aren't individualized.
• Billing for potential non-therapy time such as naps.
• Start and stop times not clearly identified on notes.
• Notes unclear about who rendered the service.
• Inadequate parent training.
• RBTs or BCaBAs completing functional behavior assessments.
• Billing under the BCBA instead of the correct rendering provider.
• Billing with no documentation of services rendered.
• Documented units not matching billed units — OHCA's example is “20 hours billed, but only 10 hours of documentation in the record.”

The turn: two states, one list

Naps and start-and-stop times are the same two items MO HealthNet's September 9 billing tip singled out, one state over. And the first finding matches the rule we covered on September 12: every Oklahoma RBT must hold their own SoonerCare contract, and working under a BCBA's license isn't a substitute.

Two findings are really one rule, and it's the one practices used to other states will trip on. Billing a technician's session under the supervising BCBA is standard practice in some states — Missouri tells billers to put the supervisor's NPI on technician claims. Oklahoma's written rule is the opposite: “All ABA services should be billed under the rendering provider that performed the services” (OAC 317:30-5-314(2)(I)), and “All staff providing ABA services must be contracted with the OHCA” (OAC 317:30-5-311(6)). The RBT “works under the license number of a BCBA” for supervision, but the RBT who delivered the session is the rendering provider on the claim.

The limits

The SQR rule sits in OHCA's fee-for-service ABA policy. The message says “all ABA providers” but doesn't address SoonerSelect plan members. No numbers are published on how many providers the educational reviews covered or how many had each finding.

What you must know or do

• Clinical directors: pull ten member files this week and score them against the 13 findings. Treatment plans signed by the guardian and the clinician, start and stop times on every note, the rendering provider named, FBAs signed by the BCBA.
• Billing: reconcile documented minutes to billed units for those ten members over one month. That's the exact test OHCA's example describes.
• Owners: check every RBT on the schedule against their own SoonerCare contract and current certification. An uncontracted technician is the first item on OHCA's list.
• Billing: pull a week of Oklahoma claims and check the rendering provider on every technician-delivered session. Under OAC 317:30-5-314(2)(I) it should be the RBT who delivered it, under their own SoonerCare contract, not the supervising BCBA.
• Keep the Behavioral Health Unit number handy: 800-522-0114, option 1, then 6, then 2.