These answers draw in part from “How To Incorporate Superbills Into Your Practice” by Charity Steele, BCBA (BehaviorLive), and extend it with peer-reviewed research from our library of 27,900+ ABA research articles. Clinical framing, BACB ethics code references, and cross-links below are synthesized by Behaviorist Book Club.
View the original presentation →A superbill is an itemized receipt that an out-of-network provider gives to a client containing all the information the client needs to submit a claim to their insurance company for potential reimbursement. In standard insurance billing, the provider submits claims directly to the insurance company and receives payment from the insurer, with the client paying only their copay or coinsurance. In the superbill model, the client pays the provider directly at the full fee rate, then submits the superbill to their insurance company to seek reimbursement according to their out-of-network benefit terms. The key difference is that the financial transaction occurs between the provider and client rather than between the provider and insurance company, and the client assumes the risk that reimbursement may be partial or denied.
Eligibility to provide superbills depends on state licensing laws, credentialing requirements, and the specific insurance regulations in your jurisdiction. Generally, you must hold a valid state license or certification that authorizes you to provide and bill for ABA services. You must have a National Provider Identifier number. Your practice must have a tax identification number. The services described on the superbill must be within your scope of practice and competence. Some states may have additional requirements specific to out-of-network billing. It is essential to verify the specific requirements in your state, as providing superbills without proper authorization could constitute practicing without a license or insurance fraud.
A complete superbill should include the provider's full name, credentials, NPI number, tax identification number, practice address, and phone number. It must include the client's name, date of birth, and insurance policy information. Each date of service must be listed with the corresponding CPT codes, the number of units, the place of service code, the ICD-10 diagnostic codes, the fee charged per unit, and the total amount charged and collected. Some insurers may require additional information such as the referring physician's name and NPI. The superbill should be clearly formatted and easy for the client to submit. All information must be accurate, as errors can lead to claim denials or fraud liability.
The most commonly used ABA CPT codes include 97151 for behavior identification assessment conducted by a qualified healthcare professional, 97152 for behavior identification supporting assessment typically conducted by a technician under supervision, 97153 for adaptive behavior treatment by protocol which covers direct one-on-one treatment implementation, 97155 for adaptive behavior treatment with protocol modification which covers BCBA-directed treatment services, 97156 for family adaptive behavior treatment guidance, and 97157 for multiple-family group treatment guidance. Each code has specific requirements regarding who can provide the service, what the service entails, and how units are calculated. Using codes that do not match the services actually provided is both an ethical violation and a potential legal offense.
You must decline any request to modify a superbill in a way that misrepresents the services provided. This includes changing CPT codes, inflating the number of units, adding services that were not provided, or altering diagnostic codes. Explain to the client that superbill accuracy is a legal and ethical requirement and that misrepresentation constitutes insurance fraud, which carries serious consequences for both the provider and the client. If the client is frustrated with their reimbursement, help them understand their out-of-network benefits and suggest they contact their insurance company to clarify their coverage. Document the request and your response in the client's record. Maintaining integrity in billing protects both your license and your clients.
Your informed consent for superbill practice should clearly state that you are an out-of-network provider. It should explain your fee schedule including rates for each service type. It should explain that payment is due at the time of service and that you will provide a superbill for the client to submit to their insurance. It should explain that reimbursement is not guaranteed and depends on the client's specific benefit terms. It should recommend that the client contact their insurance company to verify their out-of-network benefits, deductible, and coinsurance before beginning services. It should clarify that the client is responsible for any amount not reimbursed by insurance. And it should be signed and dated by the client or their legal guardian before services begin.
This depends entirely on your state's specific requirements. In states that have licensure laws for behavior analysts, you must typically hold the state license to bill for ABA services, whether in-network or out-of-network. BCBA certification alone may not be sufficient for billing purposes in these states. In states without specific behavior analyst licensure, the requirements may be different and may depend on other professional licenses you hold. Some states also have specific regulations about which provider types can issue superbills. Before providing superbills, verify with your state licensing board and, if necessary, a healthcare attorney that you meet all applicable requirements. Providing superbills without proper authorization can have serious legal consequences.
The legal risks are significant and range from administrative penalties to criminal prosecution. At the federal level, knowingly submitting false claims to insurance companies can violate the False Claims Act and anti-fraud statutes, carrying penalties including fines, exclusion from federal healthcare programs, and imprisonment. At the state level, insurance fraud statutes impose additional penalties. Even unintentional errors, if they form a pattern, can trigger regulatory investigation. Beyond fraud liability, practitioners may face malpractice claims if clients suffer financial harm from inaccurate superbills. Professional consequences include BACB ethics complaints, state licensing board actions, and loss of professional liability insurance coverage. These risks underscore the importance of developing accurate, compliant superbill procedures.
Fee setting for out-of-network practice should consider multiple factors. Research the prevailing rates for ABA services in your geographic market by reviewing what other out-of-network providers charge. Consider your costs including overhead, insurance, continuing education, and desired compensation. Recognize that your fee should be consistent regardless of whether the client has insurance, as charging different rates based on insurance status can create legal and ethical problems. Be aware that insurance companies use usual and customary rate databases to determine their allowed amounts for out-of-network claims, and your fee should be reasonable relative to these benchmarks. Set your fees transparently and apply them consistently across clients. Disclose your complete fee schedule during the informed consent process.
Maintain comprehensive records including copies of all superbills issued, clinical session notes that support the services and codes billed on each superbill, signed informed consent documents including financial disclosures, any correspondence with clients regarding billing or reimbursement, your superbill procedure manual, and records of any billing corrections or adjustments. Session notes should include the date, duration, and type of service, what was addressed during the session, the client's response, and any clinical decisions made. These notes must align with the CPT codes on the corresponding superbill. Retain all billing-related records for at least the period required by your state's record retention laws and any applicable federal requirements, which is typically a minimum of seven years.
The ABA Clubhouse has 60+ on-demand CEUs including ethics, supervision, and clinical topics like this one. Plus a new live CEU every Wednesday.
Ready to go deeper? This course covers this topic with structured learning objectives and CEU credit.
How To Incorporate Superbills Into Your Practice — Charity Steele · 1 BACB Ethics CEUs · $15
Take This Course →We extended these answers with research from our library — dig into the peer-reviewed studies behind the topic, in plain-English summaries written for BCBAs.
279 research articles with practitioner takeaways
212 research articles with practitioner takeaways
195 research articles with practitioner takeaways
1 BACB Ethics CEUs · $15 · BehaviorLive
Research-backed educational guide with practice recommendations
Side-by-side comparison with clinical decision framework
You earn CEUs from a dozen different places. Upload any certificate — from here, your employer, conferences, wherever — and always know exactly where you stand. Learning, Ethics, Supervision, all handled.
No credit card required. Cancel anytime.
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.