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Documentation Requirements for Applied Behavior Analysis (ABA) Services

All ABA services must be documented in accordance with the definitions of adequate documentation and adequate records in 13 CSR 70-3.030(2)(A). Services must be documented in the health record within five business days to be considered timely. 
The licensed behavior analyst must co-sign progress notes for services rendered by behavior technicians (BTs) or registered behavior technicians (RBTs). The rendering provider National Provider Identifier (NPI) submitted on the claim should match either: 

  • The NPI of the person delivering the service, or 
  • The licensed and enrolled supervisor (for services performed by BTs/RBTs) 
     

Under 13 CSR 70-98.030(7), ABA treatment plans must meet specific requirements. ABA intervention services must be rendered in accordance with the individual’s treatment plan, which must: 

  1. Be person-centered and individualized 
  2. Be developed by a licensed behavior analyst or licensed psychologist 
  3. Be based on the ABA assessment for intervention planning 
  4. Include assessment and treatment protocols for addressing each of the target behaviors 
  5. Include training to enable licensed assistant behavior analysts and behavior technicians/RBTs to implement assessment and treatment protocols
  6. Include training and support to enable parents and other caregivers to participate in treatment planning and treatment plan implementation 
  7. Include care coordination involving the parents or caregiver(s), school, state disability programs, and others as applicable
  8. Be consistent with applicable professional standards and guidelines relating to the practice of ABA as well as state Medicaid laws and regulations and applicable Missouri licensure laws and regulations
     

The MO HealthNet Division (MHD) recommends the ABA session note templates developed by The Council of Autism Service Providers (CASP) as a resource to improve quality of documentation. The templates are available for download after completing free online CEU eligible training. 


Use of the CASP templates does not guarantee immunity from audits. Providers are responsible for ensuring documentation meets all MHD regulatory requirements. Templates may need modification to comply fully (for example, adding a licensed behavior analyst co-signature for BT/RBT services as required by MHD). 
 

Providers are encouraged to self-audit to improve documentation quality and compliance. Failure to adequately document services could result in post-payment recoupment. 
 

For questions, contact MHD.BehavioralHealth@dss.mo.gov.