NC Medicaid ABA Policy Update 2026: Key Changes for ABA Providers

Veronica Cruz
6 hours ago
3 min read

If you bill ABA services for NC Medicaid beneficiaries, Policy 8F has just moved again. The state released a revised draft during a 10-day additional public comment period, with several changes worth understanding now, before they hit your billing team's workflow. None of this is final yet.

Here's what actually changed, what didn't, and what's just a paperwork fix dressed up to look bigger than it is.

What Changed in the Revised NC Medicaid ABA Policy

The most important updates for ABA providers include:

The proposed restriction on out-of-state rendering providers was removed from the revised draft.
Telehealth may account for up to 50% of eligible CPT 97155 services for a beneficiary.
CARS2-ST and CARS2-HF were added as accepted autism diagnostic tools.
Treatment plans involving more than 16 hours per week may require reauthorization every 90 days rather than monthly.
Treatment plans now carry more detailed requirements for staffing, caregiver involvement, service schedules, titration, crisis planning, and medical necessity.
Documentation requirements are becoming more specific, particularly for session notes, caregiver training, supervision, and concurrent billing.

Change 1: Existing Out-of-State Providers Can Continue Serving NC Medicaid Members

One of the biggest concerns in the original draft is gone.

The earlier proposal would have stopped Medicaid reimbursement for services from clinicians located more than 40 miles outside North Carolina. That language is gone from the revised policy.

For practices already serving NC Medicaid members from neighboring states like Virginia or South Carolina, this is welcome news. Existing care arrangements won't get interrupted just because the provider is based outside the state.

Don't confuse this with enrollment rules. Session Law 2026-1 still bars new out-of-state BCBAs and QASP Supervisors from enrolling as NC Medicaid providers. Providers can review the NC Medicaid provider enrollment requirements before applying or updating their enrollment status.

What this means for providers: Current cross-state arrangements can continue, but there's still no new pathway for out-of-state providers to enroll.

Change 2: Telehealth Supervision Aligns With State Law

The revised draft updates the telehealth supervision limit for CPT 97155 to 50%.

It looks like North Carolina expanded telehealth flexibility. It didn't. The policy is just catching up to Session Law 2026-1, which already set that limit.

The earlier draft listed a 20% cap, which didn't match the law. The revision fixes that inconsistency.

For ABA providers, the expectation stays the same: telehealth supervision can't exceed 50% of a beneficiary's LQASP-delivered 97155 services, unless future guidance says otherwise.

What this means for billing teams: Check that your authorization tracking and telehealth reports reflect the 50% threshold, not the earlier 20% figure.

Change 3: CARS-2 Is Now Officially Recognized

The revised policy now lists the diagnostic tools that can support a comprehensive autism diagnosis: ADOS-2, BOSA, TAP, CARS2-ST, and CARS2-HF.

The previous draft just said "a scientifically validated diagnostic tool," leaving room for interpretation during medical reviews.

Naming CARS-2 directly gives providers and reviewers clearer guidance, and should cut down on unnecessary questions during prior authorization. That's especially helpful since CARS-2 is more accessible and takes fewer resources to administer than ADOS-2, while still being well-established.

Change 4: Longer Authorization Periods, But Clinical Reviews Still Matter

Treatment plans over 16 hours of ABA per week now get a 90-day authorization period instead of a monthly renewal. That should ease the administrative load on billing and authorization teams.

But monthly clinical responsibilities haven't disappeared. Higher-intensity treatment plans still need regular review and updates to show continued medical necessity, with progress data and documentation kept current throughout the authorization period.

What this means for practices: Fewer authorization requests, but documentation still needs to stay current. That's still the best way to avoid delays or denials during utilization review.

Does the Policy Update Change North Carolina Medicaid ABA Rates

The revised Policy 8F primarily addresses coverage, authorization, provider roles, telehealth, documentation, treatment planning, and billing rules. It is not itself a complete ABA reimbursement-rate announcement.

North Carolina previously increased rates for Research-Based Intensive Behavioral Health Treatment as part of broader behavioral health reimbursement changes. The state also uses rate floors for certain managed-care services, although contracted payment can depend on the applicable plan and provider agreement.

Providers should confirm current rates through the official NC Medicaid fee schedule and covered-code portal before relying on a third-party reimbursement table.

A correct CPT rate does not guarantee payment. The claim can still deny when: