CPT 97180: How to Log and Bill BCBA Non-Face-to-Face Time

CPT 97180 is a new code, for dates of service from January 1, 2027, for 15-minute units of non-face-to-face work a BCBA or other QHP personally performs: data review, protocol decisions, assessment planning, discharge planning and patient-specific technician training. The ABA Coding Coalition says each date is documented and a week’s time may be summed onto one claim.

This page is for BCBAs and billing staff setting up January workflows. It covers what counts and what does not, the weekly reporting rule, a filled-in fictional week, and a blank log to copy. For every ABA code in one table, see ABA CPT codes: every code explained; for how each 2026 code maps to 2027, see the 2026-to-2027 ABA CPT crosswalk. More billing pages are in CPT Codes & Billing.

What does CPT 97180 cover?

CPT 97180 covers five non-face-to-face activities, listed in its descriptor. As the ABA Coding Coalition prints it:

Adaptive behavior non-face-to-face services, personally performed by a physician or other QHP, each 15 minutes, with any of the following elements, when performed:

• review and analysis of data and session notes on patient treatment targets,
• clinical decision making regarding the need to modify treatment targets, goals, or protocols and/or making those modifications,
• clinical decision making regarding the need for additional assessment and developing or modifying assessment protocols,
• developing discharge or transition plan,
• training on or reviewing treatment targets and/or revised assessment or treatment protocols with technician(s).

(Supplemental guidance, p. 10; Coalition crosswalk, p. 2.) The Coalition defines a QHP (qualified health care professional) as a licensed or board-certified behavior analyst, or another credentialed professional whose scope of practice, training and competence includes applied behavior analysis (crosswalk, p. 2, note 2). The July CMS proposed rule, which used the placeholder number 97X3X, omits “training on or” from the last element (91 FR 43891). The Coalition’s later wording is quoted here; the AMA’s CPT 2027 book settles the exact text.

The Coalition’s crosswalk says this work was “Not separately reportable in 2019 code set” (p. 2). In 2027 it gets its own code because, in the Coalition’s words, 97180 is for “patient-specific non-face-to-face analysis activities that do not require the presence of patient(s) or caregiver(s)” (supplemental guidance, p. 2). This is the data-based decision making a BCBA does between sessions, now billed on its own line.

Three details from the guidance shape the log:

• The decision counts even when nothing changes. Adjusting a protocol is not required to report a code that includes analysis, but the analysis must be documented (p. 2). When the BCBA reviews a target and keeps it, “the QHP documents the clinical decision not to adjust” (p. 11).
• Rewriting a written protocol is 97180. “The act of adjusting a written treatment protocol, goal, or target in the treatment plan is reported separately using 97180” (p. 22).
• Only the BCBA’s time is billed during training. When the QHP trains technicians on a patient’s protocol, “only the QHPs time is billed. The technician’s time is not separately reported or billable” (p. 13). Retraining on an existing protocol counts, and the training is “not limited to newly hired technicians” (p. 12).

What can’t you bill with 97180?

You cannot bill 97180 for any non-face-to-face work outside the five listed elements. The Coalition’s table and FAQs mark these as not reportable (supplemental guidance, pp. 4-5, 12-15):

For indirect BCBA work that 97180 does not cover, and an audit checklist, see documenting indirect BCBA time. On care coordination, the Coalition says “care coordination activities are not included in the adaptive behavior code set and require other reporting mechanisms when covered by payer policy” (p. 13). On quality assurance, one distinction matters: reviewing another clinician’s notes and data “for the purpose of clinical decision-making” can be included, while reviewing them “for audit or compliance purposes” cannot (p. 12).

Our reading: billing an excluded activity under 97180 is a form of billing misrepresentation, even when the time was real work for the client. The log’s “activity” column is where a reviewer will check this.

How do you log and bill 97180 each week?

Log each 97180 activity on the date it happens, then total the patient’s 97180 time for the 7-day period and report it on one claim. The supplemental guidance gives the steps: “Each time the QHP engages in non-face-to-face 97180 activities for the patient, they document the date, the time spent, and the activities that occurred. At the end of each 7-day period (e.g., Sunday through Saturday), all 97180 times for the patient are summed, and the total units are reported to the health plan on one claim” (p. 11).

The Coalition’s wording is permissive. Its note reads: “Per CPT® guidance, qualifying non-face-to-face activities may be aggregated and reported for a 7-day reporting period (e.g., Sunday through Saturday) provided that each date of service within the 7-day period is documented individually” (p. 11). Elsewhere it says “97180 may be reported once each week, per patient” (p. 23), and the crosswalk says 97180 “may be reported once per week by summing the time spent on non-face-to-face services during the preceding seven days, e.g., Sunday to Saturday” (p. 2). Our reading: the guidance does not say whether a payer may also accept daily claims, and “once each week” can also be read as a limit of one claim a week. Whether the CPT book itself states the 7-day rule, or only the Coalition’s reading of CPT guidance, is still to be confirmed against the AMA’s 2027 book.

In practice, the weekly routine looks like this:

1. Keep one log per patient per week, Sunday through Saturday, unless the payer defines the week differently.
2. Write an entry for every 97180 activity on its own date, with start and end time, minutes, which descriptor element it was, and the targets or protocols involved.
3. Record the clinical decision, including “no change” when a target is kept.
4. Mark excluded work as not billable rather than leaving it off. A note-writing block or a call with the speech therapist on the same day shows a reviewer the line was drawn on purpose.
5. At the end of the week, total the billable minutes and convert them to units, then report them on one claim line.

What do reviewers flag in a 97180 log?

The Coalition asks for “the date, the time spent, and the activities that occurred” for each 97180 entry (supplemental guidance, p. 11). Our reading of what fails that test:

• an entry with no minutes, or no activity named;
• an excluded task, such as writing session notes, counted as billable;
• a 97180 entry on a date when 97151 is reported for the same client.

How many units is the weekly total?

Each 97180 unit is 15 minutes. The supplemental guidance’s general rule, which it describes for “direct delivery of services”, is that work “lasting 8 - 22 minutes is reportable as one unit. Work lasting less than 8 minutes is not reportable” (p. 31). Its own 97180 example sums the week first: 5 hours across Monday, Wednesday, Thursday and Friday become “20 units of 97180”, billed on Friday (p. 13).

Our reading: apply the 15-minute rule to the week’s summed minutes, the way the Coalition tells billers to sum time and then round for the add-on technician codes (p. 9). Under that reading, 150 minutes is 10 units, 157 minutes is still 10 (the 7 leftover minutes are under 8), and 158 minutes is 11. Payers can set their own counting rules, so confirm before the first January claim.

Which date goes on the claim?

The guidance does not name a required claim date. In the Coalition’s example the week is “billed on Friday”, the last day with 97180 work (p. 13). Our reading: use a date inside the Sunday-to-Saturday period on which 97180 work was logged, and not a date on which 97151 is reported (see below). Ask each payer whether it wants a specific date, such as the last day of the period.

How does cost share work for 97180?

Cost share may apply to 97180, and when the week is reported together it is applied to one date of service. The Coalition says “applicable cost sharing (e.g. deductibles, co-pays, co-insurances, and out of pocket maximums) may apply in accordance with the patient’s health benefit plan”, and that doing the work without the patient present, or on a day with no face-to-face session, “does not determine whether cost sharing applies” (supplemental guidance, p. 13).

When the week is summed, “all units of 97180 services during the 7-day period are reported together on one claim line and patient cost-share will be applied to one date of service, as opposed to each date of service during the 7-day period the 97180 services occurred” (p. 13). Our reading: for families with a per-visit copay, that is the practical reason to report weekly rather than daily. Tell families before January that this line will appear on their statements.

Can you bill 97180 on the same day as 97151?

No. The Coalition’s answer is direct: “Do not report 97180 and 97151 on the same day for the same patient” (supplemental guidance, p. 5). The two codes are “separate and distinct QHP services”: 97151 is for “face-to-face and non-face-to-face assessment and reassessment activities and writing or revising treatment plans and reports”, and 97180 is for non-face-to-face work “during the course of treatment” (p. 5).

So the day-to-day review between reassessments is 97180, and the reassessment itself, including its non-face-to-face scoring and report writing, is 97151 (p. 4). Our reading: on a reassessment day, the log shows any review as part of the 97151 work, not as a 97180 entry. The CPT 97151 documentation guide covers what that note shows.

97180 also connects to the other QHP codes:

• 97155: the BCBA directing a technician with the patient present. Review of that session’s data afterwards is 97180 (p. 22). See CPT 97155 documentation.
• 97152: a BCBA who trains the technician on a supporting-assessment protocol without the patient bills that time as 97180 (p. 32).
• 97156: caregiver training with the BCBA face to face. Rewriting the written protocol afterwards is 97180 (p. 26). See the CPT 97156 caregiver documentation guide.

Fictional example: one week of 97180 for one client

The week below is fictional: client J.R., BCBA “the QHP”, the first full week of 2027 (Sunday, January 3 to Saturday, January 9). It shows billable and non-billable entries side by side and one 97151 day.

Week total: 40 + 50 + 35 + 25 = 150 billable minutes = 10 units of 97180, reported on one claim line dated Friday, January 8 (a 97180 day that is not the 97151 day). Any cost share under J.R.’s plan applies to that one date. The 20 minutes of note writing and the 30-minute call are logged but not billed.

Weekly 97180 log template

Copy this table into your EHR, a spreadsheet or a document, one log per client per Sunday-to-Saturday week. Print the page if you want a paper copy. Use client initials or your system’s ID, never full names, in any file outside the EHR.

Client ID: _____ · QHP: _____ · Week (7 days, e.g., Sun-Sat): _____ to _____ · 97151 dates this week: _____

For the “Descriptor element” column, use one of the five: review and analysis of data; modify targets, goals or protocols; additional assessment or assessment protocols; discharge plan or transition plan; training technicians. If an entry fits none of them, it is not 97180.

What should you check with payers before January?

Payers set their own start dates for the 2027 codes. The Coalition says payers are not all required to implement on January 1, 2027, and that “providers must obtain that information from each payer with whom they work” (supplemental guidance, p. 29). As of October 29, 2026 we found no payer announcement on 97180 rates or rules; the crosswalk’s payer tracker is updated as payers publish.

For 97180, ask each payer:

• whether 97180 is covered and authorized, and how many units (the Coalition’s sample 26-week authorization adds 52 units, 0.5 hours a week, as an illustration, p. 30);
• whether it accepts the weekly total on one claim line, which date it wants, and how it defines the week;
• how it counts units on the weekly total;
• what documentation it wants for each date, and whether it wants a modifier.

On authorization, the Coalition says there is no fixed formula for how much 97180 a client should get: “authorization of 97180 should be based on medical necessity for the individual patient” (p. 11). For Medicare, the CMS proposed rule proposes contractor pricing for the six new codes, 97180 included (91 FR 43891); the CY 2027 Physician Fee Schedule final rule was not in the Federal Register when we checked on October 29, 2026.

Frequently asked questions

Is 97180 a BCBA-only code?

No. 97180 is “personally performed by a physician or other QHP”. The Coalition’s crosswalk lists as QHPs licensed behavior analysts and licensed assistant behavior analysts, BCBA-Ds, BCBAs, BCaBAs, and others whose scope covers ABA (p. 2). Whether an assistant-level clinician can bill it depends on state law and the payer. RBTs and other technicians do not bill it, and their time during 97180 training is not billed.

Do I have to bill 97180 weekly?

Not necessarily. The Coalition says the time “may be aggregated” for a 7-day period, provided each date is documented (supplemental guidance, p. 11). Our reading: whether a payer also accepts daily claims is the payer’s call, so ask before January.

Can I bill 97180 for training a new RBT?

Only for training on a specific client’s targets or protocols, without the client present. General training on ABA principles, CPR, safety or agency policy is not 97180 (supplemental guidance, p. 12). Retraining experienced technicians on a client’s protocol is billable.

Can I bill 97180 on a day with no session?

Yes. 97180 work can happen on the same day as face-to-face services or on a different day (supplemental guidance, pp. 13, 23). The exception is a day on which 97151 is reported for the same client (p. 5).

Is there a minimum or maximum amount of 97180 per week?

No fixed amount. The Coalition cites CASP guidelines of “an average of 1–2 hours of QHP activity (e.g., 97155, 97173, 97180) for every 10 hours of technician-delivered treatment”, covering all QHP codes, and says it “is not intended to prescribe utilization of any single QHP activity or CPT® code” (supplemental guidance, p. 11). Your payer’s authorization sets the units. Under the general unit rule, work under 8 minutes is not reportable (p. 31).

Sources

• American Medical Association. CPT 2027 Professional Edition (owner of the code set and descriptors; quoted here as the sources below print them).
• ABA Coding Coalition. Supplemental Guidance on Interpreting and Applying the Revised 2027 CPT Codes for Adaptive Behavior Services (dated January 2027; posted October 2026). 97180: pp. 10-15; 97151 and 97180: p. 5; units: p. 31; payers: p. 29.
• ABA Coding Coalition. 2027 Adaptive Behavior Assessment and Treatment Code Conversion Table, with cover letter dated September 11, 2026.
• Centers for Medicare & Medicaid Services. CY 2027 Payment Policies Under the Physician Fee Schedule, proposed rule, CMS-1848-P, 91 FR 43842 (July 16, 2026). Adaptive behavior services, p. 43891.

This page is billing information, not legal advice. Check each payer’s policy before you bill. CPT is a registered trademark of the American Medical Association.

Reviewed by the Praxis Notes team on October 29, 2026.