Co-signature requirements for ABA session notes have emerged as a significant compliance and documentation challenge for behavior analysts and ABA organizations. Several Medicaid agencies and commercial payers have recently introduced requirements that supervisors or other authorized professionals co-sign session notes completed by Registered Behavior Technicians and other direct service providers.
Provider: CASP CEU Center
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Join Free →Applied Behavior Analysis Co-signature Requirements Best Practices and Legal Considerations Original Air Date: May 29, 2025 Short title: Applied Behavior Analysis Co-signature Requirements CEU offered: 1.0 BACB Learning CEU Webinar Duration: 60 minutes Instructors: Mariel Fernandez, MS, BCBA, LBA Dan Unumb, Esq. Abstract: p.p1 {margin: 0.0px 0.0px 12.0px 0.0px; font: 12.0px Times; -webkit-text-stroke: #000000} li.li2 {margin: 0.0px 0.0px 0.0px 0.0px; font: 12.0px Times; -webkit-text-stroke: #000000} span.s1 {font-kerning: none} ol.ol1 {list-style-type: decimal} Recently, several Medicaid agencies, Medicaid Managed Care Organizations (MCOs), and commercial health insurance payers have introduced co-signature requirements for applied behavior analysis (ABA) session notes. These requirements are often outlined in payer ABA policies or specific documentation guidelines. Other times, requirements emerge as part of feedback during pre- or post-payment claims reviews and audits. In some cases, payers require an authorized Qualified Healthcare Professional (QHP) to co-sign all session notes for services rendered to any client on their caseload (e.g., for all 97153 or equivalent sessions). In other cases, the requirement stipulates that the parent or legal guardian co-sign all session notes for services provided on a given day (e.g., for all billable services related to the full adaptive behavior code set). CASP's session note templates do not currently include a section for co-signatures. This webinar will review the Applied Behavior Analysis Co-signature Requirements: Best Practices and Legal Considerations white paper, developed by the Autism Legal Resource Center and the Council of Autism Service Providers (CASP). The presenters will discuss topics such as the requirements for "incident to" services, whether these standards apply to ABA, contractual obligations, the Wellstone-Domenici Mental Health Parity and Addiction Equity Act (MHPAEA), and faulty assumptions r
| Certification Body | Credits | Type |
|---|---|---|
| BACB | 1 | Ethics |
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All behavior-analytic intervention is individualized. The information on this page is for educational purposes and does not constitute clinical advice. Treatment decisions should be informed by the best available published research, individualized assessment, and obtained with the informed consent of the client or their legal guardian. Behavior analysts are responsible for practicing within the boundaries of their competence and adhering to the BACB Ethics Code for Behavior Analysts.