How Michigan BCBAs Can Avoid 97153 Denials After 2026 Updates

If you are a Michigan BCBA or ABA clinic owner, 2026 is not the year to treat documentation as an afterthought. One missed detail in your 97153 notes can be the difference between a clean payment and a denial. Between BCBS Michigan’s new 97153 note expectations, Medicaid rate updates, and growing audit pressure, clean ABA billing now depends on what happens before the claim is submitted.

What CPT Code 97153 Covers

Before you even think about denials or fixing claims, it’s better to get the basics right. CPT 97153 is billed when a qualified technician (typically an RBT) delivers one-on-one adaptive behavior treatment in accordance with an established protocol. The technician is implementing the plan, not creating or changing it. Each 15-minute face-to-face unit with the client is one billable unit. 97153 is billed in 15-minute units. It is commonly used when:

• An RBT delivers direct ABA therapy

• The client is present

• The technician follows an established protocol

• Data is collected during the session

• The service is delivered under BCBA direction

If you need a deeper breakdown of units, modifiers, and proper billing structure, refer to this complete CPT 97153 billing guide.

What 97153 does not cover is just as important

It should not be used for passive observation, admin work, documentation after the client leaves, group therapy, or BCBA protocol modification. Public billing guides also explain that when the BCBA is actively modifying the protocol, 97155 may apply instead of 97153. 

What Changed for Michigan BCBAs in 2026

In 2026, 97153 is under a brighter spotlight in Michigan because it is a high-volume and high-risk area for payers. When a clinic bills large numbers of 97153 units each month, even small documentation gaps are easy to spot during audits. 

• BCBSM policy change: As of January 1, 2026, Blue Cross Behavioral Health is using an updated ABA supplemental policy. Progress notes for 97153 are now capped at 2 hours and 30 minutes (10 units) per note, and reviewers are looking more closely at whether notes clearly support time, units, and goals.

• Stronger focus on notes: Across payers, vague or incomplete session notes are now one of the top reasons for denials and recoupments in ABA billing services.

• Medicaid and future code changes: Michigan Medicaid managed care plans each have their own documentation rules, and the ABA code set is scheduled for major changes in 2027, making 2026 the year to get 97153 documentation airtight for ABA billing services and therapy billing services in Michigan.

The Top Denial Triggers for 97153 in Michigan ABA Billing 

Vague or Narrative-Only Session Notes

This is one of the most common audit issues. Notes like worked on communication goals or the client had a good session do not support a 97153 claim. They don’t prove medical necessity or show what protocol was followed, so they won’t hold up in a review.

Session notes should clearly show what happened and why it mattered. They must connect to target behaviors and include measurable data like percentages, frequency, or duration.

A proper 97153 note includes the exact program, numeric trial data, and any behavior incidents with the response used. Anything less detailed creates a documentation risk.

Unit Count Doesn’t Match Documented Time

If your note shows 3:00–3:50 PM (50 minutes) but four units were billed (60 minutes), the claim will be denied. This is basic math, but it still causes many denials because time tracking is often done manually. Instafill

Start and end times must be exact, not rounded. If your system is not calculating units automatically, someone needs to verify this before every claim is submitted.

Use this simple internal rule: 

Session Time	Billable Units
15 minutes	1 unit
30 minutes	2 units
45 minutes	3 units
60 minutes	4 units
150 minutes	10 units

Credential and Modifier Mismatches

Each CPT code is tied to specific credentials, and payers check this closely. BCBAs can bill for ABA services, but if an RBT-delivered service is submitted with the wrong modifier or under the wrong credential, the claim will be denied even if the service itself was correct and authorized. Passagehealth

In Michigan, BCBAs must also hold an active LBA (Licensed Behavior Analyst) license through LARA, along with their BACB certification. Michigan has required state licensure since January 2020, and the license must stay active through LARA. A BCBA with a lapsed LBA is not a billable provider in Michigan. Applied Behavior Analysis Education

97153 Volume Out of Ratio with 97155

This is the issue that leads to clawbacks, not just denials.

Many payers expect 97155 to be billed in a set ratio compared to 97153 hours, often around 10 percent, though it can vary. Under-billing 97155 compared to 97153 is one of the most common audit triggers.

BCBS Michigan and Anthem Michigan both monitor this ratio. If your practice shows high 97153 volume without enough 97155 claims, a utilization review is likely. Clawbacks can come 6 to 24 months later, turning a billing issue into a cash-flow problem.

Check your 97155-to-97153 ratio every month. If it stays below 10 percent, either supervision is not documented properly, or billing is not reflecting what is actually happening.

Prior Authorization Problems

Authorization in Michigan is handled by each enrollee’s Medicaid Health Plan, and reauthorization is usually required to continue services. ProviderSpark

Billing 97153 beyond approved units, billing after an authorization expires, or sending claims to the wrong managed care organization ID will lead to denials. These are not complex mistakes, but they happen often when authorization tracking is manual.

Set up a system that checks authorization balance before every claim submission, not after. If you’re seeing repeated issues, it’s worth reviewing how to reduce common 97153 billing mistakes.

How to Build a Documentation System That Prevents 97153 Denials

Most 97153 denials are not billing errors. There are documentation errors that show up in billing. The distinction matters because it tells you where to intervene. If your team is scrambling to fix claims after the fact, you are already behind. The fix has to happen at the point of service.

Weak vs Strong 97153 Documentation

Weak Note

“Client worked on behavior goals. Some problem behavior occurred. RBT redirected the client. Session completed.”

This note is too vague.

Strong Note

“RBT provided 1:1 adaptive behavior treatment from 9:00 AM to 11:00 AM under BCBA direction. Session targeted functional communication, transition tolerance, and receptive identification from the approved treatment plan. Client completed 24 trials of receptive ID with 75% accuracy and used functional communication in 8 of 10 opportunities. Two episodes of elopement were addressed using the approved response-blocking and redirection protocol. Data was recorded during the session.”

This version is much stronger because it shows time, service type, goals, data, behavior response, and treatment plan connection.

The 2027 Code Change Is Coming — Plan Now

Big changes are coming in 2027, including new CPT codes and the removal of older ones. Michigan ABA billing will be affected as payers start updating rules in 2026, so teams should prepare early.

Need Help Managing 97153 Billing in Michigan?

If your team is spending more time fixing denials than preventing them, it’s a sign your system needs support.

Working with specialized therapy billing services in Michigan can help you:

• Reduce denials

• Stay compliant with BCBS updates

• Improve cash flow without adding admin burden

FAQ

1. How often does BCBS Michigan audit 97153 claims? 

There’s no fixed schedule. Audits usually depend on billing patterns. High 97153 volume, repeated errors, or unusual ratios can trigger reviews anytime, sometimes months after claims are already paid. 

2. Can I still bill more than 10 units in a day for 97153? 

Yes, you can bill more than 10 units in a day. But each note cannot exceed 10 units, so longer sessions must be split properly in documentation. 

3. Are ABA CPT codes changing in 2026? 

No major CPT changes start in 2026. The big updates are planned for 2027, so 2026 is the time to prepare and fix any issues in current billing practices.