Georgia’s October 1 autism manual and a September banner rework summer ABA integrity rules around licensure, desk reviews, and telehealth audit triggers.
Key Takeaways
- A program under review: Georgia named ABA a high-risk Medicaid service in April, and CMS later reported a 421 percent national rise in Medicaid and CHIP ABA spending from 2021 to 2025.
- Two banners, two approaches: A May 29 notice set 1:12 or 1:8 supervision ratios and a residency deadline; a September 22 notice replaced the ratio formula with desk reviews.
- Telehealth measured, not barred: Remote services now need a readiness checklist, and providers above 25 percent of assessments or 50 percent of units by telehealth face more frequent audits.
- Deadlines still ahead: An abandoned-care report template is due by January 1, 2027, the first report by February 1, 2028, and new ABA CPT codes take effect January 1.
Among the questions Georgia now asks before it pays for autism therapy delivered by video is whether the child can sit independently at a computer for eight to ten minutes. The question appears on a Telehealth Readiness Checklist that the Georgia Department of Community Health (DCH) added to its Medicaid autism services manual on October 1, alongside questions about joint attention, motor imitation, reliable internet access, and whether a caregiver is available when clinically necessary. Answering them is only the first step. The checklist has a general section and a separate section for each billing code, and the manual requires both to be completed and submitted with the prior authorization request.
The checklist is one of sixteen changes logged on October 1 in the manual, formally titled Part II Policies and Procedures for Autism Spectrum Disorder (ASD) Services. It arrives at the end of a five-month sequence. In April, DCH named Applied Behavior Analysis (ABA) a high-risk service and proposed a set of program integrity measures. On May 29, it told providers in a Banner message that most of those measures would be enforced from July 1, including supervision ratios tied to claims accuracy and a residency requirement for analysts who supervise technicians remotely. On September 22, a second Banner message described what would take effect on October 1 instead. Read in order, the documents show the state moving away from fixed formulas and geography and toward licensure, desk reviews, and audit triggers.
Georgia Medicaid ABA Program Integrity: From the April Proposal to the May Banner
DCH set the agenda in a press release dated April 28. It identified ABA and Structured Family Caregiving as high-risk service categories and listed six ABA policies the department proposed to make effective July 1: additional prior authorization requirements, Registered Behavior Technician (RBT) oversight ratios based on claims accuracy, remote supervision of RBTs by a provider located in Georgia or within 50 miles of its border, capacity requirements for larger agencies, an annual report on abandoned care, and greater emphasis on the prohibition of member solicitation. Final details, the release said, would reach providers through Banner messages, the notices DCH posts on its Georgia MMIS provider portal.
The first of those notices, dated May 29, filled in the numbers. Any utilization above 30 hours a week would require additional authorization consideration. Each ABA provider would have a random sample of its claims reviewed every year, likely through DCH’s Performance Management Office, the message said; providers whose sampled claims were correct would operate at a ratio of one Board Certified Behavior Analyst (BCBA) to twelve RBTs, and those with errors would drop to one to eight. A provider held at the one-to-eight ratio for three successive years would be suspended automatically. Providers serving high-risk populations, including foster youth and members receiving care in what the message called a Psychiatric Rehabilitation Treatment Facility, would have all of their claims reviewed annually rather than a sample.
The May message also set the geographic condition. BCBAs providing remote supervision to RBTs had to be in Georgia or within 50 miles of its border, be fully licensed, and be able to conduct on-site reviews the same day. Enrolled BCBAs living farther away would be disenrolled if they could not demonstrate qualifying residency by March 31, 2027. Agencies employing more than five BCBAs would need capacity to serve high-acuity members older than five. Providers would file an annual report on abandoned cases, which DCH said it might publish after removing protected health information, and a one-year ramp-up would begin on approaches to increase family participation, ending in a published guide. The message stated that its provisions applied only to full-time-equivalent staff delivering ABA services.
What the September 22 Banner and the October 1 Georgia ASD Manual Changed
The September 22 message took a different approach on several of those points. On enrollment, it announced the new text of Section 601.1.2: a BCBA or doctoral-level BCBA-D enrolling as a Georgia Medicaid provider must hold active certification from the Behavior Analyst Certification Board (BACB) and a valid license from the Georgia Behavior Analyst Licensing Board. The July edition of the manual had required the same license but added that the practitioner “must reside in Georgia or within 50 miles of the Georgia border,” a condition the revision log traces to 2024. The October manual drops that clause, adds the licensure requirement to the credentials section, and places the word “licensed” before each behavior analyst tier on the list of authorized practitioners.
The September message does not repeat the remote supervision residency condition, the March 31, 2027 disenrollment deadline, the capacity requirement for larger agencies, or the family participation ramp-up. On supervision, Section 601.3.1 of the October manual now says a supervisor need not be present at the work site, but that in-person supervision “must be performed at a frequency to ensure quality of the services being provided.” The manual does not define that frequency.
The supervision ratio formula changed as well. Under the September message, all ABA providers are subject to a desk review of compliance with RBT oversight standards set by the BACB and DCH policy. Providers found out of compliance face increased reporting, minimum supervision ratios set by the department, and focused claims review. The message does not mention the one-to-twelve and one-to-eight ratios or the three-year suspension trigger. Indiana, by comparison, wrote a fixed one-to-eight supervision ratio into its April 2026 Medicaid bulletin.
The 30-hour threshold moved from authorization to audit. The manual has sent requests above 30 hours a week to an enhanced authorization review since July, and the September message adds that providers demonstrating multiple such requests will be subject to increased audit frequency. CMS has taken up the same question; its August toolkit says 40 hours a week is not a best practice and that higher intensity should not be authorized by default, as Acuity reported last month. The abandoned-care report survives with a timeline: DCH will provide a template no later than January 1, 2027, and the first report, covering calendar year 2027, is due by February 1, 2028. Suspected solicitation of members will now be referred to the DCH Office of Inspector General, with member placement suspended upon verification.
Georgia’s Telehealth Readiness Checklist and the 25 and 50 Percent ABA Audit Thresholds
The telehealth rules sit in a new Section 903.3. Members and caregivers must be able to participate actively in remote sessions, and the manual says settings with significant distractions, interruptions, privacy concerns, or safety risks “may not be clinically appropriate.” The September message specifies that the checklist must be completed before an assessment, reassessment, or treatment is delivered by telehealth. Both documents set the same numeric thresholds: providers conducting more than 25 percent of assessments via telehealth, or more than 50 percent of units of service, are subject to more frequent audits to ensure oversight of supervisees and appropriate care. Neither specifies the measurement period or how much more often those audits would occur.
Payment does not vary with the modality. Appendix A lists the same rates for telehealth as for in-clinic delivery: $15.58 per 15-minute unit for 97153 delivered by an RBT, and $30.91 for 97155 delivered by a BCBA. Out-of-clinic services pay more, at $18.69 and $37.78. The schedule reflects a 3 percent increase that DCH proposed in May 2025 under the fiscal year 2026 budget, House Bill 68, at an estimated total cost of about $16 million, and that the revision log shows entering the rate table in October 2025.
Behavior Analyst Licensure Now Carries Georgia’s Medicaid Enrollment Test
With residency gone from the enrollment section, licensure is the remaining state-specific gate. Georgia enacted House Bill 412 in 2022, creating the licensing board under Chapter 7A of Title 43 of the state code. The board’s rules took effect in December 2024, and its website set April 1, 2026 as the deadline for behavior analysts to apply. Board rules allow licensure by reciprocity for analysts licensed in states with comparable requirements, and a temporary license covers services delivered for no more than 30 days in a calendar year. Behavior analysis has no interstate licensure compact, so an analyst serving families across state lines needs a license from each regulated state, as Acuity reported in September.
The enrollment section also restates who sits on a claim. For services delivered by an RBT or Board Certified Assistant Behavior Analyst (BCaBA), the supervising BCBA must appear as the rendering provider, and Section 601.2 states that the department provides no grace period for certification or enrollment.
Progress Note and Documentation Requirements in the October ABA Manual
The longest addition in the October edition concerns records. Section 602.3.3, a single sentence in July, now spans several pages. Progress notes must be completed no later than one business day after the date of service, may not be backdated, and must identify the member, date, location, start and stop times, CPT code, and the provider’s name and credentials.
The section ends with a list of prohibited practices: pre-written or pre-signed notes, backdating, signing notes completed by another person, copying documentation from a previous session without revising it, and vague entries such as “worked on goals.” For continued authorizations, a new Section 803.10 requires skill acquisition line graphs and states that narrative descriptions or percentage summaries alone are insufficient. Section 802 adds the Early Start Denver Model as an accepted skill assessment for children 12 through 60 months old.
Documentation has been the recurring subject of federal review. Federal auditors examining state Medicaid ABA payments have repeatedly flagged session notes that fail to support billed codes, missing signatures, and services delivered without proper credentials or supervision, as Acuity has reported. On August 4, the Centers for Medicare & Medicaid Services (CMS) released its State Medicaid and CHIP ABA Toolkit, reporting that ABA spending in the two programs rose 421 percent between 2021 and 2025 while the number of children with an autism diagnosis receiving services grew 67 percent. CMS said the toolkit creates no new federal requirements. The toolkit describes in-person assessment as best practice and says telehealth, where used, should be a small part of the assessment process. Neither Georgia Banner message cites it.
How Georgia’s ABA Policy Compares With North Carolina, South Carolina, and Indiana
Neighboring states have answered the geographic question differently. North Carolina’s House Bill 696, which Governor Josh Stein signed on April 30, bars BCBAs from enrolling in the state’s Medicaid program as out-of-state providers and caps telehealth supervision at half of services for any one recipient, as Acuity has detailed; parts of the law take effect only after state rulemaking. South Carolina’s rewritten provider manual, effective July 1, removed behavior identification assessment (97151) from telehealth. Indiana ended telehealth billing in April for five ABA codes, including assessment and direct technician treatment.
Georgia’s October rules take a different combination: no residency test for enrollment, a state license as the condition, and telehealth permitted across codes subject to readiness documentation and audit thresholds. Its rates sit in the middle of the region. In a MediRate comparison Acuity published in June, Georgia’s in-clinic 97155 rate of $30.91 ranked above South Carolina’s $21.25 and below North Carolina’s $32.22. The schedule also retains a differential between clinic and home rates that the General Assembly sought to close this year; Governor Brian Kemp vetoed the $15.86 million parity appropriation in May.
What Georgia ABA Providers Should Watch in 2027
The October edition is the fourth version of the manual in 2026, following editions dated January 1, April 1, and July 1, and the revision log has recorded changes in every quarter since July 2024. Several questions remain open in the documents themselves: how DCH will calculate the telehealth audit thresholds, what frequency of in-person supervision it considers sufficient, what minimum ratios it would impose after a failed desk review, and how the May provisions that the September message does not address, including the March 31, 2027 residency deadline for remote supervisors and the capacity requirement for larger agencies, now stand.
The calendar is fixed in other respects. The abandoned-care template is due by January 1. The same day, the 2027 CPT code set takes effect, deleting 0362T and 0373T, which Georgia’s Appendix A still lists, and splitting the treatment component of 97155 into a new code, as Acuity reported in September. The Georgia Behavior Analyst Licensing Board’s next scheduled meeting is December 8.
The October edition leaves those details to later notices. What it settles is narrower and more concrete: before a Georgia child begins therapy on a screen, a provider must now attest in writing that the child can sit in front of one.
