CMS’s proposed 2027 Medicare fee schedule adds six new adaptive behavior CPT codes and extends carrier pricing for ABA, keeping rate-setting with payers.
Key Takeaways
- The proposed 2027 Medicare Physician Fee Schedule adds six new ABA CPT codes. Released July 14, 2026, the rule reflects the code changes the CPT Editorial Panel approved in September 2025, with four of the six new codes addressing the assessment and treatment of harmful behavior and two covering analyst work.
- Carrier pricing for adaptive behavior services continues through 2027. The extension covers the existing codes and the six new ones, so Medicare sets no national rate and reimbursement stays a matter of negotiation with payers.
- Telehealth status for the new codes is unresolved. CMS proposed keeping codes 97151 through 97158 on the permanent Medicare telehealth list but did not address the six new codes, which the ABA Coding Coalition says it will ask CMS to add with a permanent designation.
- None of this is final yet. The codes are not official until the AMA publishes the 2027 CPT Professional Edition later this year, and the proposal carries a 60-day comment period closing September 14, 2026, with a final rule expected in November.
On July 14, 2026, the Centers for Medicare and Medicaid Services issued its proposed rule for the 2027 Medicare Physician Fee Schedule. Set for publication in the Federal Register on July 16, the rule runs to hundreds of pages, and for the ABA field the significant provisions sit in the coding section, where they matter more to Medicaid and commercial payers than to Medicare itself. CMS proposed six new adaptive behavior services codes and moved to keep those services carrier-priced through 2027.
Six New ABA CPT Codes for Harmful Behavior and Analyst Work
The rule comments on new and revised CPT codes for adaptive behavior services that the CPT Editorial Panel approved in September 2025. Six carry a new designation and appear under placeholder identifiers until the AMA finalizes them. Four address harmful behavior: an assessment code and a treatment code, each delivered by two technicians in an environment customized to the patient’s behavior, plus companion codes for each additional technician present.
Two-technician services are not new to Medicaid, since states such as Alabama already price them under the temporary codes the new set would replace. A fifth code covers non-face-to-face analyst work, including reviewing session data, modifying protocols, and preparing discharge or transition plans. The sixth covers adaptive behavior treatment with analysis delivered by an analyst face-to-face with one patient. The codes are not official until the AMA releases the 2027 CPT Professional Edition later this year, and as a proposal the rule can still change before it is finalized.
Carrier Pricing for ABA Services Continues, Keeping Rate-Setting With Payers
The more consequential line is a quieter one. CMS extended carrier pricing for the ABA codes through 2027, covering both the existing codes and the six new ones. Carrier pricing means Medicare sets no national rate for these services and leaves the number to its local contractors, which in practice means providers keep negotiating reimbursement with payers.
That reaches well beyond Medicare, which rarely covers pediatric ABA. The codes and pricing conventions CMS adopts flow into Medicaid and commercial systems, and the continued absence of a Medicare benchmark reinforces the state-by-state, payer-by-payer rate landscape this series has tracked across states like Indiana, New York, and Maryland. The conversion factor cut drawing headlines elsewhere in the rule, a reduction driven by an expiring one-year increase, does not set ABA rates precisely because these services are carrier-priced.
Medicare Telehealth Coverage Remains Unsettled for the New ABA Codes
CMS proposed keeping the current ABA codes, 97151 through 97158, on its permanent Medicare telehealth list for 2027, but it did not say whether the six new codes would join them. The ABA Coding Coalition, which flagged the provisions, said it plans to ask CMS to add the new codes to the telehealth list with a permanent designation in the final rule.
That request is one thread to watch as the comment window runs, alongside the unsettled telehealth and concurrent-billing questions already pressing on the field, a federal audit wave sharpening documentation scrutiny, and the tighter oversight states such as North Carolina are building around ABA. For providers, the immediate takeaway is not a rate change but a coding one, with comments due September 14 and a final rule expected in November.
