Nebraska Medicaid held every applied behavior analysis code flat for SFY27, and the changes now reshaping provider operations sit in the service definition.
Key Takeaways
- Nebraska has not restored any of the August 2025 rate cut, and the schedule says why: The State Fiscal Year 2027 fee schedule prices 97153 at $18.70 per 15-minute unit and 97155 at $22.72, both unchanged from August 1, 2025, and carries a note stating that rates do not reflect an increase because there were no rate increase appropriations for the fiscal year. The SFY2026 schedule carried the same note.
- The operational rules have tightened since the rate cut: The service definition now posted by the Department holds direct service to 6 hours a day and 20 a week unless a prior authorization is approved, down from the 30-hour figure it published in early 2025, and closes school-based billing to independent providers.
- The reset was justified on regional comparison, and it moved Nebraska from the top of the national range to the middle of its own: Citing 42 CFR 447.200 and a rate analysis of surrounding Medicaid markets, the Department set rates that now place Nebraska above five of its six bordering states on base 97153 rates and below all six on 97155.
- Nebraska’s numbers now shape other states’ rate decisions: Colorado benchmarks its Pediatric Behavioral Therapy rates against a multi-state comparison group that includes Nebraska and reset its own rates to 95 percent of that updated benchmark effective October 1, 2025, so a cut in one state became an input to the next.
Nebraska Medicaid published its Mental Health and Substance Use fee schedule for State Fiscal Year 2027 effective July 1, 2026, and reissued it with a revision dated July 20. Neither version changed a single applied behavior analysis rate. The revision corrected two psychotherapy lines, 90836 and 90837, where the physician column had carried the values belonging to the codes above them. The ABA tab is identical across both files.
That is the whole of the rate news, and the schedule is unusually candid about why. A year after one of the steepest Medicaid ABA reductions any state has enacted, Nebraska is holding the line, and the consequential activity has moved from the rate table to the rulebook.
What Nebraska Medicaid Pays for ABA in SFY27
The ABA tab prices seven codes, each per 15-minute unit except where the description says otherwise. Behavior identification assessment (97151) pays $38.16. Supporting assessment by a technician (97152) pays $25.88. Adaptive behavior treatment by protocol administered by a technician (97153) pays $18.70, or $74.80 an hour. Group treatment by a technician (97154) pays $7.49. Treatment with protocol modification by a clinician (97155) pays $22.72, or $90.88 an hour. Family adaptive behavior treatment (97156) pays $26.06. Social skills group treatment (97158) pays $12.05. Code 97157 does not appear.
Two features stand out. The first is compression: 97155 pays only about 21.5 percent more per unit than 97153, one of the narrowest analyst-to-technician spreads in the series so far. In Iowa the same gap runs to roughly 114 percent. The second is inversion at the top: assessment under 97151 is the highest-priced code on the schedule at $38.16 against $22.72 for clinician treatment, so a Nebraska analyst’s highest-value billable hour is diagnostic rather than therapeutic.
The schedule also sets who may bill what. Codes 97153 and 97154 pay every non-physician tier from Provisionally Licensed PhD down to Registered Behavior Technician. Codes 97155, 97156, and 97158 pay physicians, psychologists, and Board Certified Behavior Analysts, and nothing to assistants or technicians.
How Nebraska Got to $18.70
On July 1, 2025, the Division of Medicaid and Long-Term Care issued Health Plan Advisory 25-08 notifying the Heritage Health managed care plans of revised ABA rates effective August 1. The advisory listed the seven rates that still stand today and grounded the change in 42 CFR 447.200, which requires payments to be consistent with efficiency, economy, and quality of care.
The methodology behind it is now codified. State Plan Amendment NE 25-0020, submitted July 31, 2025, tells federal regulators that the rates were adjusted in alignment with Medicaid agencies in states geographically proximate to Nebraska and reflect a blended average of those states’ rates. The amendment supersedes nothing, so Nebraska had no codified ABA rate methodology before it.
The advisory also directed that managed care rates move to the revised amounts, which matters because Nebraska delivers Medicaid primarily through Heritage Health. A published schedule often works as a floor that plan contracts sit above. Here the state told the plans to move with it.
The scale is the reason. On the Department’s own accounting, Nebraska Medicaid paid roughly $4.6 million for ABA in 2020 and more than $85 million in 2024, an increase it describes as more than 2,000 percent. The announcement ran 31 days ahead of the effective date.
What the reset replaced is as striking as what it produced. The SFY2026 schedule carries both rate blocks. Through July 31, 2025, Nebraska paid a flat $36.11 per 15-minute unit for 97152, 97153, 97154, and 97155, and a flat $54.17 for 97151, 97156, and 97158. Group treatment paid the same as one-on-one, and a technician’s hour paid the same as an analyst’s. The August schedule priced each code separately for the first time, and all seven fell: 97152 by 28 percent, 97151 by 30, 97155 by 37, 97153 by 48, 97156 by 52, 97158 by 78, and 97154 by 79.
The Legislature’s Health and Human Services Committee took up the question under Legislative Resolution 191 and held an invitation-only hearing on September 5, 2025. The Auditor of Public Accounts separately examined ABA claims and reported apparent overpayments, including hours recorded beyond what session notes supported.
Nebraska is not North Carolina, where a court blocked a rate cut and the Governor ordered rates restored, and it is not Oregon, which left its ABA rates untouched through 2026. It is closer to Indiana, which paired reductions with a structural rewrite of the benefit.
The 20-Hour Threshold and the School Billing Change
The second wave arrived without a rate change. Nebraska Medicaid has been drafting a consolidated Mental Health, Substance Use Disorder, and Applied Behavior Analysis Provider Manual to replace its Medicaid Service Definitions, and extended public comment on that draft to January 31, 2026. No bulletin dates the version now posted on the Department’s site, and providers and Nebraska news outlets have described the operative changes as taking effect in July 2026. Two provisions in that document are reshaping operations.
On intensity, the definition states that direct ABA service hours may not exceed 6 hours in a single day or a total of 20 hours per week, with additional daily or weekly hours available only where clinical justification is submitted for prior authorization and approved. The Department’s January 2025 guidance had described hours of service up to 30 hours per week. Twenty hours is now the threshold at which paperwork begins, which places Nebraska alongside Virginia, where a 20-hour weekly cap has been in force, and inside a broader argument about what the evidence actually supports on ABA dosage.
On setting, the definition places school-based ABA inside the Medicaid school-based services program and makes it the school’s responsibility, barring independent providers from billing Medicaid directly for services delivered there. Where ABA is provided in an educational setting, the treatment plan must contain a separate school plan inside the student’s Individualized Education Program, time-limited and carrying a transition plan shifting instructional control to school staff. Shadow or aide work, and general support, are not covered.
Other exclusions track findings from the federal audit series now running through state ABA programs: naps are never reimbursable, services delivered concurrently with speech, occupational, or physical therapy are not covered, and services rendered by someone legally responsible for the individual’s care are excluded.
Who Can Bill Nebraska ABA Codes, and Under What Supervision
Nebraska credentials the analyst tier through the state Department of Public Health. Since January 1, 2025, national board certification alone has not been enough: analysts and assistant analysts must also carry the matching state license. Codes 97153 and 97154 may be billed by licensed assistant analysts and Registered Behavior Technicians, working under a Licensed Behavior Analyst or a psychologist trained in ABA. That is a sharper line than several neighbors draw, including Kansas, which licenses analysts and assistants but has no state credential for technicians.
Supervision requirements are quantified. Observation must cover at least 10 percent of a technician’s weekly direct service hours, with at least an hour of that in person each month, and the treating analyst owes the child a further hour of face-to-face service monthly. No Licensed Behavior Analyst may oversee more than 24 technicians. Audiovisual telehealth is permitted for 97155 and 97156 and barred for 97153, 97154, and 97158.
Nebraska ABA Rates in Regional Context
Measured against its six bordering states, Nebraska now presents a split profile: near the top on technician-delivered treatment, at the bottom on analyst-delivered treatment. Before August 2025 the Department said Nebraska’s rates ran higher than every other state’s. One caveat applies throughout. These comparisons are built from published state fee schedules, so they show what a state posts rather than what a plan pays.
State Rate Comparison: Medicaid ABA Reimbursement, CPT 97153 (Adaptive Behavior Treatment by Protocol), per 15-minute unit. Source: MediRate. For granular state-by-state rate detail across the full ABA code set, MediRate maintains the underlying database.
On 97153, Nebraska’s $18.70 trails only South Dakota’s $21.73 and runs above Colorado at $17.20, Iowa at $17.16, Missouri at $16.37, Kansas at $16.25, and Wyoming at $12.30. One figure understates itself: Wyoming’s $12.30 is its state plan rate, and members enrolled in its developmental disability waivers draw $19.23 for the same code, which would place Wyoming above Nebraska. That aside, this is the comparison the Department pointed to when it said rates remain competitive with surrounding states, and it holds on this code.
State Rate Comparison: Medicaid ABA Reimbursement, CPT 97155 (Adaptive Behavior Treatment with Protocol Modification), per 15-minute unit. Source: MediRate. Missouri publishes two 97155 rates: $27.46 carries the U8 home-setting modifier and applies to the Behavior Analyst and Psychologist tier.
On 97155 the ordering reverses, and no waiver differential softens it. Nebraska’s $22.72 is the lowest figure on the chart, below Kansas at $24.00, Wyoming at $24.60, Missouri at $25.26 and $27.46 in the home setting, Colorado at $25.80, Iowa at $36.81, and South Dakota at $39.00, which pays roughly 72 percent more for the same clinician time. A provider modeling a comprehensive program across state lines will find Nebraska competitive on technician hours and last in the region on analyst hours.
What Nebraska ABA Providers Should Watch
Appropriation language in the next session
The schedule ties the flat rates to the absence of an appropriation, which makes the appropriations process, not the Department, the venue where any restoration begins.
How the 20-hour threshold is administered in practice
A threshold with a medical necessity exception is only as permissive as the authorization process behind it, and that process runs through the Heritage Health plans.
Whether the plans hold at the published floor
The Department directed managed care rates to move with the state schedule in August 2025. Whether any plan has since moved above it is not visible in the schedule.
Federal program integrity attention
Nebraska is among the states Acuity has previously reported as named in the U.S. House Energy and Commerce Committee’s program integrity inquiry, and the state’s own auditor has already examined ABA claims. That pressure moves on a different timeline than rate policy.
Frequently Asked Questions
What does Nebraska Medicaid pay for ABA in 2026?
The State Fiscal Year 2027 fee schedule, effective July 1, 2026, pays $18.70 per 15-minute unit for 97153 and $22.72 for 97155, or $74.80 and $90.88 an hour. Assessment pays $38.16 for 97151 and $25.88 for 97152. Family adaptive behavior treatment under 97156 pays $26.06.
Did Nebraska change ABA rates for State Fiscal Year 2027?
No. Every ABA rate on the SFY27 schedule is unchanged from the rates that took effect August 1, 2025, and the schedule states that no rate increase appropriations were made for the fiscal year. A revision issued July 20, 2026 corrected two psychotherapy codes and did not touch the ABA tab.
How many hours of ABA does Nebraska Medicaid authorize?
The Applied Behavior Analysis service definition currently posted by the Department states that direct ABA service hours may not exceed 6 hours in a single day or 20 hours per week. Additional daily or weekly hours may be requested in certain clinical circumstances, with clinical justification submitted for prior authorization and approved.
Can independent ABA providers bill Nebraska Medicaid for school-based services?
No. The service definition states that ABA services in school settings are covered through the Medicaid school-based services program and are the responsibility of the school, and that independent providers may not bill Medicaid directly for services provided at a school.
Who can deliver ABA under Nebraska Medicaid?
Services must be provided by or under the supervision of a licensed clinician with ABA training, which may include a psychiatrist, physician, psychologist, provisionally licensed psychologist, or Licensed Behavior Analyst. Codes 97153 and 97154 may be billed by Licensed Assistant Behavior Analysts and Registered Behavior Technicians under supervision. Since January 1, 2025, national certification alone is not sufficient: analysts and assistants must hold the corresponding Nebraska credential.
Sources: MediRate; Nebraska Department of Health and Human Services, Division of Medicaid and Long-Term Care; Nebraska Medicaid Mental Health and Substance Use fee schedules for SFY2026 and SFY2027, including the SFY27 revision dated July 20, 2026; Health Plan Advisory 25-08; Nebraska State Plan Amendment NE 25-0020; Nebraska Medicaid Applied Behavior Analysis service definition; Nebraska Auditor of Public Accounts; Nebraska Legislature Legislative Resolution 191.
