Wisconsin pays $11.91 for technician-delivered 97153, unchanged since February 2023, as DHS revisits 97155 billing and enrollment after a federal audit.
Key Takeaways
- The technician rate trails the region: Comprehensive 97153 pays $11.91 per unit, unchanged since February 2023 and below every neighbor charted, and the 2025 to 2027 budget’s rate increases skipped behavioral treatment.
- DHS has promised structural changes: After a 2025 federal audit, the department said it would revisit 97155 reimbursement and verify who renders focused 97153, and it plans agency enrollment in 2026 and 2027.
- The audit found documentation gaps: Federal auditors estimated at least $18.5 million in improper payments for 2021 and 2022, including 97155 notes that showed no protocol change, and flagged $94.3 million more as potentially improper, including claims naming the wrong rendering provider.
- October 14 is the next marker: The OIG tracker expects updates on four open recommendations that day, ahead of January CPT changes that will require Wisconsin to price new codes replacing 97155.
Wisconsin pays $11.91 per 15-minute unit for technician-delivered applied behavior analysis (ABA) under CPT code 97153, the lowest rate among its neighbors, and the figure has not changed since February 1, 2023. The rate sits inside a benefit under active federal and state review. The U.S. Department of Health and Human Services Office of Inspector General (OIG) lists October 14, 2026 as the next expected update on four open recommendations from its 2025 audit of Wisconsin’s ABA payments, and the Department of Health Services (DHS) has told its autism advisory council that it plans to change how ABA providers enroll and bill during 2026 and 2027.
ForwardHealth, the state’s Medicaid program, administers what it calls the behavioral treatment benefit fee-for-service and keeps it separate from managed care. ForwardHealth pays the lesser of the billed amount or its maximum allowable fee for most services, so the published maximum fee caps what ForwardHealth pays rather than setting a floor beneath negotiated plan contracts.
How Wisconsin Medicaid Covers ABA Through the Behavioral Treatment Benefit
ForwardHealth began covering ABA under the benefit on January 1, 2016, after moving the service out of the Children’s Long-Term Support Waiver, and has required CPT codes on claims since January 1, 2019. Payment requires prior authorization, which ForwardHealth reviews itself, approving either comprehensive or focused treatment. Comprehensive treatment is high-intensity early intervention that typically lasts a year or more. Focused treatment is time-limited and targets specific behaviors or skill deficits. OIG’s audit describes initial requests as covering no more than six months, and the prior authorization backlog Acuity reported in September showed how much runs through that single pipeline.
ForwardHealth enrolls five provider specialties: Licensed Supervisors and Treatment Therapists, each in a version for both treatment levels and a focused-only version, plus Behavioral Treatment Technicians. Licensed Supervisors must hold a license from the Department of Safety and Professional Services. Treatment Therapists qualify through Board Certified Assistant Behavior Analyst certification or combinations of education, certification, and supervised hours. Technicians need a high school diploma or equivalent and 40 hours of training, or Registered Behavior Technician certification. Only Licensed Supervisors bill: the supervisor named on the plan of care is the billing provider, and whoever delivered the session is listed as the rendering provider.
Wisconsin ABA Fee Schedule: One Rate for Comprehensive Treatment, Three for Focused
ForwardHealth’s interactive maximum fee schedule prices 97153 by treatment level. Comprehensive treatment, billed with modifier TG, pays $11.91 per unit regardless of who delivers it. Focused treatment, billed with modifier TF, pays by the rendering provider: $41.44 for a Licensed Supervisor, $20.84 for a Treatment Therapist, and $11.91 for a technician, who adds the reduced-services modifier 52. Each of those rates carries a February 1, 2023 effective date.
The other core codes carry single rates. Protocol modification under 97155, delivered by a Licensed Supervisor or Treatment Therapist, pays $22.93. Assessment under 97151 pays $25.90, supporting assessment under 97152 pays $22.93, and family guidance under 97156 pays $28.03.
In hourly terms, technician time pays $47.64 and analyst protocol modification pays $91.72. The focused tier produces an unusual result: a Licensed Supervisor delivering focused 97153 is paid $165.76 an hour, 81 percent more than the same supervisor earns modifying the protocol under 97155. Wisconsin’s behavioral treatment handbook, as OIG described it, also bars billing 97153 and 97155 for the same minutes, a contrast with Hawaii, which allows both codes at once when their criteria are met.
How Wisconsin ABA Rates Reached $11.91
Wisconsin’s technician rate has risen in steps. A September 2018 ForwardHealth Update raised the rate for technician-delivered treatment, then billed under Category III code 0364T, from $14.32 to $19.05 per 30 minutes. OIG’s audit lists the comprehensive 97153 rate at $9.53 per 15-minute unit in 2021 and $10.96 in 2022. ForwardHealth then raised behavioral treatment rates 8.7 percent effective February 1, 2023, producing today’s $11.91.
No increase has followed. 2025 Wisconsin Act 15, the 2025 to 2027 biennial budget, funded rate increases effective January 1, 2026 for dental anesthesia, home health visits, opioid treatment programs, obstetrics, personal care, private duty nursing, and residential substance use disorder treatment. Behavioral treatment was not on the list.
Spending grew anyway. OIG reported that fee-for-service ABA payments rose from $39.9 million in 2018 to $53.7 million in 2022 and $82.3 million in 2023. Code 97153 accounted for 72 percent of the ABA payments OIG reviewed, and 97155 for 22 percent.
Wisconsin ABA Rates Compared to Neighboring States
Wisconsin ranks last in its region on technician time and in the lower half on analyst time.
Medicaid 97153 (adaptive behavior treatment by protocol, technician-delivered), rate per 15-minute unit: Wisconsin and neighboring states. Wisconsin’s figure is its comprehensive-treatment rate, which also applies to technician-delivered focused treatment. Source: MediRate.
On 97153, Wisconsin’s $11.91 trails Illinois at $13.00, Indiana at $16.04, Minnesota at $16.14, Michigan at $16.50, and Iowa at $17.16. Iowa pays 44 percent more for the same 15 minutes of technician time.
Medicaid 97155 (adaptive behavior treatment with protocol modification, analyst-delivered), rate per 15-minute unit: Wisconsin and neighboring states. Michigan publishes no fee schedule rate for 97155; according to MediRate, those rates are negotiated privately with its prepaid inpatient health plans. Missouri publishes two 97155 rates: $27.46 carries the U8 home-setting modifier and applies to the Behavior Analyst and Psychologist tier. Source: MediRate.
On 97155, Wisconsin’s $22.93 runs ahead of Minnesota at $20.17 and Illinois at $20.39, and behind Missouri at $25.26, Indiana at $25.97, Missouri’s in-home rate of $27.46, and Iowa at $36.81. Michigan drops out because it publishes a fee schedule rate only for 97153; MediRate says its other ABA rates are negotiated privately with prepaid inpatient health plans. For granular rate detail across the full ABA code set, MediRate maintains the underlying data.
What the Federal Audit of Wisconsin ABA Found
OIG’s report A-06-23-01002, issued July 10, 2025, estimated that Wisconsin made at least $18.5 million in improper fee-for-service ABA payments in 2021 and 2022, $12.2 million of it federal share, plus about $94.3 million in potentially improper payments. Every one of the 100 sampled enrollee-months contained at least one improper or potentially improper claim line. Wisconsin was the second state published in OIG’s ABA audit series.
Two findings bear directly on the fee schedule. In 75 of the 95 sampled enrollee-months that included 97155, session notes did not show that any issue was resolved or that the protocol changed. In 54 enrollee-months, the rendering provider on the claim did not match the session notes; in four involving focused treatment, the claim generally named a supervisor or therapist, who is paid more per unit than the technician who delivered the service. OIG recommended that DHS verify who rendered focused 97153 and pay at that specialty’s rate.
OIG also found that DHS had not conducted a statewide postpayment review of ABA claims since the benefit began, which state officials attributed to a 2020 Wisconsin Supreme Court ruling, Papa v. Wisconsin Department of Health Services, that limited the department’s ability to recoup overpayments. The report pointed to 2019 supplemental coding guidance from an industry workgroup that, in OIG’s view, may have confused providers about when 97155 applies, a question that also runs through the supervision dispute in Massachusetts.
What DHS Has Committed to Change
In its June 2025 response, signed by Medicaid Director Bill Hanna, DHS agreed with five recommendations and partially disagreed with the refund, disputing OIG’s 97155 finding. It said it would update handbook policy and guidance for 97155, “including reimbursement structures,” and would evaluate reviewing 97153 claims before payment through its Payment Integrity Review program. OIG’s tracker shows two recommendations closed on April 14, 2026, covering 97155 documentation guidance and periodic postpayment review. Four remain open, including the refund and rendering-provider verification. ForwardHealth Update 2025-41, issued December 23, 2025, revised the online handbook to clarify policy based on an audit.
DHS has also previewed changes beyond the audit. At the May 20, 2026 meeting of the Governor’s Autism Council, according to draft minutes, department staff said behavioral treatment updates to be completed in 2026 and 2027 would focus on provider enrollment and billing systems. DHS plans to align enrollment criteria for Board Certified Behavior Analysts with the certification board’s updated standards and to create an agency enrollment structure so families can find ABA agencies through ForwardHealth’s online tool. Staff said the department is studying other states, with options including national accreditation, child care licensure, or state certification, which Wisconsin cannot offer today because its Division of Quality Assurance has no ABA certification. Indiana has set an accreditation requirement for ABA providers. An agency enrollment update was on the council’s August 19 agenda; those minutes were not yet posted.
What Wisconsin ABA Providers Should Watch
October 14. OIG expects updates on the refund, the review of potentially improper payments, documentation guidance, and rendering-provider verification. Prepayment review of focused 97153 could affect agencies that bill that code at supervisor or therapist rates.
The 97155 rate. DHS said it would revisit reimbursement structures for protocol modification, and the 2027 CPT code set splits 97155 effective January 1, so Wisconsin will need to price the replacement codes either way.
Agency enrollment standards. As of May, the project had not reached formal public comment, and the accreditation choice will shape agencies’ compliance work.
Federal guidance. CMS released a State Medicaid and CHIP ABA Toolkit on August 4, 2026, citing a 421 percent increase in Medicaid and CHIP ABA spending from 2021 to 2025. CMS said the toolkit is not a restriction on services; it offers states a menu of payment, enrollment, and diagnosis-related options.
Frequently Asked Questions
What does Wisconsin Medicaid pay for ABA in 2026?
ForwardHealth pays $11.91 per 15-minute unit for comprehensive 97153 and $22.93 for 97155. Focused 97153 pays $41.44 for a Licensed Supervisor, $20.84 for a Treatment Therapist, and $11.91 for a technician. Assessment under 97151 pays $25.90 and family guidance under 97156 pays $28.03. The 97153 and 97155 rates carry a February 1, 2023 effective date on ForwardHealth’s interactive fee schedule.
When did Wisconsin last raise ABA rates?
On February 1, 2023, when ForwardHealth increased behavioral treatment rates 8.7 percent. The January 2026 increases funded by 2025 Wisconsin Act 15 did not include behavioral treatment.
Do Wisconsin Medicaid HMOs pay for ABA?
No. ForwardHealth administers the behavioral treatment benefit fee-for-service, separate from managed care, and handles prior authorization and claims directly.
Why does Wisconsin pay different rates for the same 97153 code?
Focused treatment, billed with modifier TF, pays according to the rendering provider’s specialty, while comprehensive treatment, billed with TG, pays one rate to every provider. OIG has recommended that DHS verify the rendering provider on focused claims and pay at that provider’s rate.
What did the federal audit of Wisconsin ABA find?
OIG estimated at least $18.5 million in improper fee-for-service ABA payments in 2021 and 2022 and about $94.3 million in potentially improper payments, citing session notes that did not support billed codes, units, or dates. DHS agreed with most recommendations and disputed OIG’s 97155 finding.
Sources: MediRate; Wisconsin Department of Health Services, publication P-01175 on the behavioral treatment benefit transition; ForwardHealth interactive maximum allowable fee schedule (behavioral treatment, CPT 97153 and 97155) and maximum allowable fee schedule information page; ForwardHealth Updates 2018-35, 2023-03, 2025-28, and 2025-41; ForwardHealth behavioral treatment benefit resources page; U.S. Department of Health and Human Services Office of Inspector General, report A-06-23-01002 (July 2025) and recommendation tracker; Wisconsin DHS response to OIG (June 3, 2025); Governor’s Autism Council draft minutes (May 20, 2026); Indiana Health Coverage Programs professional fee schedule (updated September 8, 2026); Centers for Medicare and Medicaid Services (August 4, 2026); prior Acuity Media Network reporting.
