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By Matt Harrington, BCBA · Behaviorist Book Club · Research-backed answers for behavior analysts

Frequently Asked Questions About Telehealth ABA Service Delivery and Billing

Questions Covered
  1. What types of ABA services can be delivered via telehealth?
  2. How do I bill for telehealth ABA services?
  3. What technology do I need for telehealth ABA sessions?
  4. How do I maintain confidentiality during telehealth sessions?
  5. Can I conduct a functional behavior assessment via telehealth?
  6. What should I do when there is a technology failure during a session?
  7. How do I train caregivers to serve as implementers during telehealth sessions?
  8. Are there limitations on how much of my service can be delivered via telehealth?
  9. How do I assess whether telehealth is working for a particular client?
  10. What happens to telehealth billing policies after the pandemic emergency provisions expire?

1. What types of ABA services can be delivered via telehealth?

Most ABA service types have been successfully delivered via telehealth, including supervision of RBTs and trainees, caregiver training and coaching, assessment (with adaptations), treatment planning, and program modification. The appropriateness depends on the specific client, caregiver capacity, and the behavioral goals being targeted. Services that require hands-on physical management or specific assessment materials may need in-person delivery. Many practices use a hybrid model, delivering some components via telehealth and others in person based on clinical need.

2. How do I bill for telehealth ABA services?

Billing for telehealth ABA services uses the same CPT codes as in-person services (97151-97158) with appropriate telehealth modifiers. The specific modifiers required vary by payor: some require modifier 95 (synchronous telehealth), others require modifier GT or place of service code 02 (telehealth). Check each payor's telehealth billing guidelines, as requirements differ and are still evolving. Document the delivery modality in your session notes and ensure that billed time reflects actual service delivery time, excluding time lost to technology failures.

3. What technology do I need for telehealth ABA sessions?

At minimum, you need a HIPAA-compliant video conferencing platform, a reliable internet connection with sufficient bandwidth for clear video and audio, a computer or tablet with a camera and microphone, and a private space for conducting sessions. The client side needs similar technology. Some practitioners use additional tools such as screen sharing for visual supports, digital whiteboards for training activities, or picture-in-picture displays for simultaneous observation. Always have a backup communication method, such as phone, in case of video platform failure.

4. How do I maintain confidentiality during telehealth sessions?

Use a HIPAA-compliant video platform with encryption and access controls. Conduct sessions in a private space where conversations cannot be overheard. Ask caregivers to do the same on their end. If sessions are recorded for clinical or training purposes, obtain written consent and store recordings securely with appropriate access controls. Discuss confidentiality expectations with the caregiver at the start of the telehealth relationship, including who else may be present in the room during sessions and how to handle situations where privacy cannot be maintained.

5. Can I conduct a functional behavior assessment via telehealth?

Components of an FBA can be conducted via telehealth with appropriate adaptations. Indirect assessments such as caregiver interviews translate well to video. Direct observation of behavior can occur via live video, with the advantage of observing the client in their natural environment. Functional analysis conditions can be implemented by a trained implementer in the room while the behavior analyst observes and directs via video. This model has research support but requires that the in-room implementer is adequately trained and that safety protocols are in place for managing severe behavior.

6. What should I do when there is a technology failure during a session?

Have a pre-established protocol that both you and the caregiver understand before the first session. Typical protocols include attempting to reconnect within two to three minutes, switching to a phone call if video cannot be restored, and rescheduling if neither option is feasible. Document the technology failure and the response taken. Bill only for the actual service time delivered. If technology failures are recurring, work with the family to identify and resolve the underlying issue, which may involve upgrading internet service, changing platforms, or adjusting session timing.

7. How do I train caregivers to serve as implementers during telehealth sessions?

Begin with a dedicated training session focused on the specific procedures the caregiver will implement, using behavioral skills training: instruction, modeling via video, caregiver practice, and feedback. Start with simpler procedures and gradually increase complexity. During sessions, use clear and concise coaching language, provide immediate positive feedback for correct implementation, and offer gentle corrections with specific guidance. Build in regular fidelity checks by observing the caregiver's implementation and providing structured feedback. Respect the caregiver's learning pace and emotional capacity.

8. Are there limitations on how much of my service can be delivered via telehealth?

Limitations vary by payor, state licensing board, and the BACB. Some payors require a minimum proportion of services to be delivered in person. The BACB has specific requirements for the proportion of supervision that may occur via telehealth. State licensing boards may have additional requirements. Check each applicable body's current requirements, as these have been evolving since 2020. From a clinical perspective, the proportion of telehealth versus in-person services should be determined by what produces the best outcomes for each individual client rather than by a one-size-fits-all policy.

9. How do I assess whether telehealth is working for a particular client?

Use the same outcome measures you would use for in-person services: skill acquisition rates, problem behavior frequency and severity, caregiver implementation fidelity, and session engagement. Compare these metrics to baseline or to what would be expected for this client. Additionally, assess telehealth-specific factors such as session completion rates, technology failure frequency, caregiver satisfaction, and the proportion of session time spent on active clinical work versus technology troubleshooting. If outcomes are not meeting expectations, investigate whether the delivery modality is the issue before changing the treatment approach.

10. What happens to telehealth billing policies after the pandemic emergency provisions expire?

Many of the emergency telehealth provisions have been codified into permanent or long-term policy changes, though the landscape continues to evolve. Some payors have adopted permanent telehealth coverage for ABA services. Others have implemented more restrictive policies now that in-person services are feasible. Stay current by checking your payor contracts and policies periodically, monitoring updates from your state licensing board, and following organizations like CASP that track regulatory changes affecting ABA telehealth delivery. Building telehealth competency now positions you to adapt regardless of how policies evolve.

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Clinical Disclaimer

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.

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