The AMA released the 2027 CPT code set on September 9. ABA gains six adaptive behavior codes, loses 0362T and 0373T, and must be ready by January 1.
Key Takeaways
- The 2019 ABA code set expires December 31. Eight Category I codes and two temporary Category III codes give way to fourteen permanent Category I codes, with 0362T and 0373T deleted and 97155 splitting its treatment component into new code 97173.
- The AMA published the 2027 set on September 9, and CMS has proposed how Medicare will treat it. CMS extended carrier pricing through 2027 and kept 97151 through 97158 on the permanent telehealth list without addressing the six new codes.
- The five-digit numbers are already public, ahead of the Coalition’s own webinars. The ABA Coding Coalition updated its billing codes page on September 12 with 97148, 97149, 97159, 97160, 97173 and 97180.
- Three Coalition webinars run before October, and the Medicare final rule lands in November. That leaves slightly more than fifteen weeks to update EMR code libraries, payer contracts, and authorization templates.
The American Medical Association released its 2027 CPT code set on September 9, and the accompanying announcement read like a tour of contemporary medicine. The rebuilt framework for maternity care retires the decades-old global bundle, adds three new codes for left ventricular assist device procedures, nine for diaphragmatic hernia repair, updates prostate biopsy guidelines, adds a time-based structure for biofeedback, adds new radiology tables, and adds six codes for unattended sleep studies. Ten new codes describe services involving artificial intelligence, bringing that total to 43.
The 2027 edition contains 453 editorial changes by the AMA’s count: 299 new codes, 74 revisions and 80 deletions, all effective January 1. Six of the new codes describe adaptive behavior services, and their publication completes a revision that the CPT Editorial Panel approved in September 2025 and then held under confidentiality for nearly a year. AMA President Willie Underwood III, MD, MSc, MPH, said the code set gives the health system “a clinically grounded foundation for describing new and evolving services.”
For ABA, the code set grows from ten codes to fourteen, and it loses its temporary tier entirely.
The Six New Adaptive Behavior CPT Codes: 97148, 97149, 97159, 97160, 97173 and 97180
When the Centers for Medicare & Medicaid Services issued the proposed 2027 Medicare Physician Fee Schedule on July 14, it printed the full descriptors for the new codes on pages 146 through 149 but left the codes themselves as placeholders: 97X1X through 97X6X. The ABA Coding Coalition’s September 10 notice told the field that the AMA had now assigned the five-digit numbers, and invited providers to three webinars to learn what they were.
Two days later, the Coalition updated its own billing codes page. The numbers are there.
Matched against the descriptors CMS published in July, the six resolve this way.
97148 covers behavior identification supporting assessment of harmful behavior, in 15-minute units of technician time, and requires three components: delivery by two technicians, a patient who exhibits harmful behavior, and an environment customized to that behavior. Add-on code 97149 reports each additional technician present and instructs you to report the summed time for the third through fifth technicians.
97159 mirrors that structure on the treatment side, covering adaptive behavior treatment of harmful behavior under the same three conditions, with add-on code 97160 for each additional technician.
97180 has no ancestor. Titled adaptive behavior non-face-to-face services, it is personally performed by a physician or other qualified health care professional in 15-minute units, and it covers work that has never had a home in the code set: reviewing and analyzing treatment data and session notes, clinical decision-making about whether to modify targets, goals or protocols, decision-making about the need for further assessment, developing a discharge or transition plan, and training technicians on revised protocols.
97173 covers adaptive behavior treatment with analysis, administered by a physician or other qualified health care professional face-to-face with one patient, in 15-minute units.
0362T and 0373T Are Deleted, and CPT 97155 Splits Into Two Codes
The two Category III codes are gone. Introduced in 2014 and carried through the 2019 restructuring, 0362T and 0373T described the highest-acuity ABA services, those requiring two or more technicians and a customized setting for patients with destructive behavior. Their temporary status was a persistent problem because Medicaid programs varied in whether they covered the codes at all. Acuity’s state-by-state Medicaid ABA rate reporting has repeatedly found the T-codes either missing from fee schedules or priced inconsistently against their Category I neighbors. The four new harmful-behavior codes replace them with permanent Category I status.
The change with the widest operational reach may be the one that carries no new number. Under the 2027 descriptors, 97155 becomes adaptive behavior direction of technician and analysis by physician or other qualified health care professional. The direct treatment component that 97155 has carried since 2019 moves to 97173. Organizations that have been using a single code for a Board Certified Behavior Analyst who both directs a technician and works with the patient will be splitting that work across two codes.
Several other descriptors were revised more quietly. Codes 97156, 97157 and 97158 now read “with analysis.” Codes 97152, 97153 and 97154 drop the phrase “under the direction of.” Neither change alters who may perform the service. Both alter the language payers will be reading when they rewrite medical policies.
ABA Reimbursement in 2027: Carrier Pricing, Telehealth and the November Final Rule
Numbers and descriptors are not rates. In the July proposed rule, CMS extended carrier pricing for the adaptive behavior codes through 2027 and applied that treatment to the six new codes as well as the eight existing ones. In practice, no national Medicare rate anchors the process, and providers keep negotiating with each payer individually. That has been the structural condition of ABA reimbursement since the Category I codes took effect, and it is why rates for the same 15 minutes of technician-delivered treatment under 97153 run from $10.00 in Alabama to $17.91 at Arizona’s RBT-level tier under the AHCCCS FY26 fee schedule.
CMS also proposed keeping 97151 through 97158 on the permanent Medicare telehealth coverage list for 2027, but did not address the six new codes. The Coalition said in July that it would ask CMS to add them to the telehealth list with permanent designation in the final rule. That rule is expected in November, alongside the valuation decisions that eventually shape state Medicaid fee schedules.
Medicare is a minor payer for ABA, which is delivered overwhelmingly to children through Medicaid and commercial plans. The federal schedule still matters because state Medicaid fee schedules and commercial medical policies are written against the same CPT descriptors, and those descriptors change on the same date for everyone.
ABA CPT Code Implementation: Fifteen Weeks to January 1
The Coalition spent the summer telling the field not to touch anything. Its July notice cautioned providers and payers against changing EMR systems until the AMA published officially, on the grounds that descriptors in a proposed rule can still change. That condition is now satisfied on the AMA’s side. The CMS final rule is not.
Three webinars are scheduled before the end of September. ABAI sponsors the first, on September 21 from 1 to 2:30 p.m. Eastern, aimed at providers, billers, and EMR vendors. APBA sponsors a session for providers on September 28 from 3 to 4:30 p.m. Eastern. CASP hosts a session for payers and regulators on September 30 from noon to 1:30 p.m. Eastern, by invitation only.
The practical questions are not subtle. Prior authorizations name specific CPT codes and run for fixed coverage periods, which means approvals written this fall under 0362T or 0373T will extend into a year in which those codes do not exist. Payer medical policies, clearinghouse edits, EMR code libraries, scheduling templates and authorization-tracking tools all reference the current set. Rollouts of that kind tend to fail quietly, and one person quietly holding the system together is the failure mode operators report most often.
Providers are absorbing this at the end of a year already heavy with operational change, from a new 40-hour Registered Behavior Technician curriculum and a two-year recertification cycle through the BACB’s portal migration to the BCBA coursework requirements that also arrive on January 1, 2027. The coding transition is one item on a crowded calendar, not a standalone project.
The CPT Copyright Lawsuit and the CMS Review of the AMA Coding Process
A second storyline is running alongside this one, and it concerns who owns CPT at all.
In August, PatientRightsAdvocate.org filed a declaratory judgment action against the AMA in the U.S. District Court for the Northern District of Illinois, asking the court to confirm that it may scan and publish the 2026 CPT codebook without infringing the AMA’s copyright. The nonprofit argues that CPT is not copyrightable because federal law and at least 45 states have incorporated it, and that free publication would qualify as fair use. The AMA has said it will defend its intellectual property rights. According to the complaint, a member of the public pays $137.89 for a physical codebook, and providers pay an annual license fee of $82.50 plus $18.50 per user.
CMS used the same July proposed rule to solicit public comment on federal reliance on CPT, including what it framed as the harms or challenges associated with the AMA’s licensing monopoly and whether licensing costs inhibit innovation. The comment period on docket CMS-2026-2377 ran through September 14. Senator Bill Cassidy, Chairman of the Senate Committee on Health, Education, Labor and Pensions, wrote to the AMA in October 2025 raising similar questions.
None of that changes what takes effect on January 1. It does bear on the machinery behind it. The adaptive behavior code set exists because a coalition of behavior analysis organizations and two consultants carried an application through the AMA’s process across roughly a decade. The Coalition’s roster has moved in the meantime: ABAI joined in July 2026, and Autism Speaks, a member as recently as this spring, is no longer listed alongside APBA, the BACB, and CASP. The same body challenges concurrent billing restrictions and monitors Medically Unlikely Edits on the field’s behalf. Whatever the courts or CMS conclude about who should maintain CPT, that has been the route by which ABA gets codes.
The 2027 codebook is available now. CPT experts will walk through the changes and the associated payment policies at the AMA’s CPT and RBRVS 2027 Annual Symposium from November 18 to 20, by which point the Medicare final rule should be public. For ABA providers, the more immediate calendar is shorter: three webinars this month, and one date in January that does not move.
Frequently Asked Questions
What are the new 2027 CPT codes for ABA therapy?
Six new codes join the adaptive behavior services family: 97148, 97149, 97159, 97160, 97173, and 97180. Codes 97148 and 97159 cover assessment and treatment of harmful behavior delivered by two technicians in an environment customized to the patient’s behavior, with add-on codes 97149 and 97160 reporting each additional technician. Code 97173 covers adaptive behavior treatment with analysis delivered face-to-face by a physician or other qualified health care professional to one patient. Code 97180 covers non-face-to-face services personally performed by a physician or other qualified health care professional. All are reported in 15-minute units. Together with the eight existing codes, 97151 through 97158, they bring the adaptive behavior set to fourteen Category I codes.
When do the 2027 adaptive behavior CPT codes take effect?
January 1, 2027. The CPT Editorial Panel approved the revision in September 2025; the AMA kept the specifics confidential; CMS printed the descriptors in the proposed Medicare Physician Fee Schedule on July 14, 2026; and the AMA released the full code set on September 9, 2026. Some secondary summaries have circulated an effective date of January 1, 2028. That is incorrect. Both the AMA and the ABA Coding Coalition state January 1, 2027.
What happened to CPT codes 0362T and 0373T?
Both are deleted effective January 1, 2027. They were Category III temporary codes, introduced in 2014 and carried through the 2019 restructuring, used to report the highest-acuity ABA services involving two or more technicians and a customized treatment environment. Category III status meant no guarantee of permanence and inconsistent payer treatment: some Medicaid programs covered them fully, some required extra justification, and some declined to recognize them. The four new harmful-behavior codes, 97148, 97149, 97159, and 97160, replace them with permanent Category I status.
What is changing about CPT 97155 in 2027?
Its scope narrows. Under the 2027 descriptor, 97155 becomes adaptive behavior direction by a technician and analysis by a physician or other qualified health care professional, face-to-face with a patient, in 15-minute units. The direct treatment component the code has carried since 2019 moves to the new code 97173. For organizations whose behavior analysts both direct a technician and deliver hands-on treatment in the same session, work reported under one code will need to be reported under two. This change is most likely to require rework in scheduling templates, documentation prompts, and billing rules.
What does CPT 97180 cover, and why does it matter?
Code 97180 covers adaptive behavior non-face-to-face services personally performed by a physician or other qualified health care professional, in 15-minute units. The listed elements include reviewing and analyzing treatment data and session notes, clinical decision-making about whether to modify treatment targets, goals or protocols, decision-making about the need for additional assessment, developing a discharge or transition plan, and training technicians on revised protocols. This matters because behavior analysts have long performed this indirect clinical work without a code to describe it. Whether payers reimburse it, and at what rate, is a separate question from whether the code exists.
Will Medicare set a national rate for the new ABA codes?
Not for 2027. In the July proposed rule, CMS extended carrier pricing for adaptive behavior codes through 2027 and applied it to the six new codes and the eight existing ones, which means there is no published national Medicare rate and reimbursement continues to be negotiated payer by payer. CMS also proposed keeping 97151 through 97158 on the permanent Medicare telehealth coverage list but did not address the six new codes, and the Coalition said it would ask CMS to add them with a permanent designation. The final rule is expected in November 2026.
