South Carolina Counts a BCBA's Caseload Across Every Employer They Work For

South Carolina Medicaid has capped ABA caseloads for years. The manual in force since July 1, 2026 adds the clause that changes who the cap binds:

“[T]hese guidelines represent the collective caseload per ABA provider, regardless of service location or company affiliation.”

A cap counted per clinic is a staffing constraint. A cap counted per person is a limit on the analyst, and a BCBA carrying eight cases at one company and eight at another is now over it.

The numbers

• BCBAs (doctoral and master's): maximum 12 cases without the support of a BCaBA, 16 cases with one.
• BCaBAs: maximum 12 cases. The previously published manual set this at 16.
• Cases are weighted by the hours each member receives: 30–40 hours a week counts as one case, 10–25 hours as half a case, under 10 hours as a quarter case.

The guidelines presume two things at once: that the enrolled provider is delivering the BACB-required professional supervision to the RBT on each case, and, separately, that the BCBA is delivering in-person direct services to every member on the caseload. A caseload built on remote oversight doesn't meet the premise the numbers were set against.

The supervision line, and why it costs money

The manual separates two things practices routinely bill as one. Your professional responsibility to supervise an RBT's work under BACB guidelines is not the same as billable, patient-directed treatment — and indirect BT/RBT case supervision is not reimbursable under 97155. Nor is clinical supervision performed to satisfy board certification requirements. 97155 pays only for direct, patient-focused treatment.

SCDHHS also sets the expected volume: protocol modification “can be rendered at the rate of 10% of the rendered 97153 treatment hours,” and 97155 and 97153 must both be delivered routinely and consistently across the prior authorization period. The manual allows brief documented departures for fade-in and transition periods, but requires the ratio to align with the authorized ratio by the end of the PA period.

The limits

The manual calls these caseload ratio “guidelines,” not an absolute bar, and doesn't state a penalty for exceeding them. It also gives no mechanism by which one employer would learn what an analyst carries at another — which makes this a rule enforced through the analyst's own certification and attestation rather than through a claims edit. The MCOs administer authorization and reimbursement, so their reading arrives first.

What you must know or do

• Practicing BCBAs and BCaBAs: add up your weighted caseload using the 1 / ½ / ¼ bands, across every employer and contract, and compare it to 12 or 16. That is a ten-minute calculation and it either clears or it doesn't.
• BCaBAs specifically: if you sat between 13 and 16 cases under the old number, you are over the current one. Say so to your clinical director now rather than at the next authorization.
• Clinical directors: ask each analyst in writing whether they hold cases at another company, and record the answer. Nothing else tells you whether your 10-case BCBA is actually at 18.
• Billers: pull last month's 97155 units and check each against a note describing direct treatment with the member present. Units resting on indirect RBT supervision are not reimbursable, and post-payment review is where that gets found.
• Everyone: compare your 97155 units to your 97153 hours. If the ratio is materially off 10%, the authorized ratio has to be met by the end of the PA period, so the time to correct it is inside the period, not after it.