Medicare ABA Billing in 2027: Pricing, New Codes and Telehealth

Medicare does not set a national payment amount for ABA codes: 97151-97158 are contractor priced, so each Medicare Administrative Contractor (MAC) prices them, and CMS proposes the same for the six new 2027 codes (CMS CY 2027 proposed rule, 91 FR 43891). That rule is still a proposal: the final rule was not published as of October 29, 2026.

This page covers only what CMS has published about ABA codes: pricing, the 2027 code changes as CMS describes them, telehealth, and claim details. Medicare’s role in ABA is narrow, but other payers borrow its edits and limits, so its rules travel. For the full 2026-to-2027 code map, see ABA CPT code changes for 2027; for every ABA code in one table, see ABA CPT codes.

How does Medicare pay ABA codes?

Through each MAC, not a national fee schedule amount. The proposed rule says: “The existing CPT codes 97151 through 97158 are currently contractor priced,” and the RUC recommended contractor pricing for the family, which has 14 codes after the 2027 changes (91 FR 43891). Contractor pricing means there are no national relative value units (RVUs) for these codes, so a change to the Physician Fee Schedule conversion factor does not set an ABA rate (our reading). To find what your MAC pays, ask your MAC or check its fee schedule.

Medicare also matters to ABA providers who never bill it, because other payers reuse its edits. Optum’s commercial ABA policy says “MUE’s apply, per CMS guidelines” (Optum ABA reimbursement policy, revised June 2026). The ABA Coding Coalition recommends reporting 97151 on each date of service in 2027 because “the Medicare MUE of 8 units per day for 97151 is less than the number of units typically authorized” (supplemental guidance, p. 5). That is a recommendation, not a CPT rule.

What does the CY 2027 proposed rule say about ABA?

Section “(47) Adaptive Behavior Services” of the proposed rule (CMS-1848-P, published July 16, 2026; comments closed September 14, 2026) describes the CPT changes and proposes how to price them:

• The code changes. At its September 2025 meeting the CPT Editorial Panel “deleted CPT codes 0362T … and 0373T,” revised eight codes (97151-97158) and created six new ones (91 FR 43891). CMS prints the new codes with placeholder numbers (97X1X-97X6X); the published numbers are 97148, +97149, 97159, +97160, 97173 and 97180.
• The pricing. “We propose to contractor price the six new codes and make no change to the status indicator for the eight revised existing codes that are already contractor priced” (91 FR 43891).
• No ABA-specific G-codes. The codes CMS proposes to add to the telehealth list for 2027 are G-codes, none of them ABA (91 FR 43863).

These codes take effect for dates of service from January 1, 2027 (Coalition crosswalk, p. 1). 0362T and 0373T, the codes for assessing and treating destructive behavior, are replaced by 97148 (+97149) and 97159 (+97160), and the Coalition says there is no grace period (supplemental guidance, p. 28). Direct 1:1 treatment by a BCBA moves from 97155 to new code 97173 (p. 23).

When the final rule appears, check whether CMS kept contractor pricing and whether it added the new codes to the telehealth list. We update this page when it publishes.

Are ABA codes on the Medicare telehealth list?

Yes, for the 2019 codes. CMS’s CY 2026 list of Medicare telehealth services marks 97151-97158, 0362T and 0373T “Maintain.” In the CY 2026 rule CMS “removed the distinction between provisional and permanent services,” so “all services we add to the list” are now permanent (MLN901705, December 2025). The Coalition summarizes this as CMS adding the 2019 ABA codes to its permanent list in 2026 (supplemental guidance, p. 30).

The six new codes are not addressed: the proposed rule says “We did not receive any requests to add or remove services from the Medicare Telehealth Services List for CY 2027” (91 FR 43863). Whether 97173, 97180 and the harmful-behavior codes can be billed as Medicare telehealth is open until the final rule (our reading).

The wider telehealth flexibilities run through 2027. “Through December 31, 2027, beneficiaries can receive Medicare telehealth services anywhere in the United States and territories,” and the services provided during the October 2025 shutdown lapse are paid “as if there hadn’t been a temporary lapse” (CMS Telehealth FAQ, updated October 8, 2026). For the remote-session checklist, see telehealth compliance for RBTs and BCBAs.

Which codes and modifiers go on a Medicare telehealth claim?

Place of service, not modifier 95, marks professional telehealth claims. CMS lists “Place of service (POS) 02 – Telehealth Provided Other than in Patient’s Home” and “POS 10 – Telehealth Provided in Patient’s Home” (MLN901705, p. 10). CMS names modifier 95 only for telehealth therapy by hospital-employed physical, occupational and speech therapists (same page). Two new modifiers start in 2027: “Telehealth modifiers BB … and BC … are required beginning January 1, 2027.” BB is for telehealth “furnished through a telehealth virtual platform” owned by an entity the practitioner contracts with, BC for telehealth “furnished incident to a physician’s or practitioner’s professional service,” and CMS says they “do not have payment implications” (Telehealth FAQ, Q17-Q18).

Commercial and Medicaid plans set their own telehealth rules: some want GT or 95, some only a POS code. Use each payer’s policy (the modifier table is on ABA CPT codes).

7-step Medicare ABA billing checklist for January 1, 2027

1. Ask your MAC how it will price the new codes. All 14 codes are (or are proposed to be) contractor priced, so the rate for 97173, 97180 and the harmful-behavior codes comes from the MAC (91 FR 43891).
2. Stop 0362T and 0373T at year end. For dates of service from January 1, 2027, bill 97148/+97149 or 97159/+97160 instead (supplemental guidance, p. 28).
3. Split 97155 time. Time a BCBA spends directing a technician stays 97155; time treating the patient with no technician becomes 97173; data review and protocol rewrites without the patient become 97180 (pp. 22-24).
4. Log 97180 by date. Each date is documented; a week’s time may be summed and reported on one claim (p. 11). Our 97180 log shows the fields.
5. Check telehealth claims. POS 02 or 10, plus BB or BC where they apply from January 1, 2027 (MLN901705; Telehealth FAQ). Do not assume the new codes are on the telehealth list until the final rule says so.
6. Watch the edits. The Coalition is preparing “Updates to 2027 Medically Unlikely Edits and Procedure to Procedure edits for the revised code set” (provider guide, p. 1); until they publish, the 2027 limits for the new codes are unknown.
7. Recheck after the final rule. Look for the CY 2027 PFS final rule (RIN 0938-AV82) on the Federal Register and compare it with the three proposals above.

Sources

• Centers for Medicare & Medicaid Services. CY 2027 Physician Fee Schedule proposed rule, CMS-1848-P, 91 FR 43842 (July 16, 2026); telehealth list p. 43863, adaptive behavior services p. 43891. The final rule was not published as of October 29, 2026.
• Centers for Medicare & Medicaid Services. CY 2026 List of Medicare Telehealth Services; MLN901705, Telehealth & Remote Patient Monitoring (December 2025); Telehealth FAQ (updated October 8, 2026).
• ABA Coding Coalition. Supplemental guidance on the 2027 codes (published October 2026); 2027 code conversion table (September 11, 2026); Preparing for implementation (October 2026).
• Optum. Applied Behavior Analysis (ABA) Reimbursement Policy - Commercial, policy 2022RP501A (revised June 2026).

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

Updated October 29, 2026: rewritten for 2027 from CMS sources only (contractor pricing, the proposed rule, the telehealth list and claim modifiers). Corrected: 97153 is “treatment by protocol” by a technician, not “protocol modification”; ABA codes are contractor priced, with no national RVUs to cut; Medicare professional telehealth claims use POS 02/10 rather than modifier 95; and the 30-day plan-of-care rule we listed applies to outpatient therapy (PT/OT) plans of care, not ABA.

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