Certification Standards Providers of Home Based Therapeutic Services (inclusive of ABA)
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Standards governing certification, scope, service components, prior authorization, and provider requirements for Home Based Therapeutic Services (HBTS) — inclusive of Applied Behavior Analysis (ABA) — as issued by the Rhode Island Executive Office of Health and Human Services. Affects HBTS provider-agencies, licensed supervisors, home-based workers, and payers administering Medicaid and applicable third-party coverage in Rhode Island.
HBTS Treatment Plans are approved for 12 months with required 6 month progress reports.
There are five distinct HBTS phases (Pre-Treatment Consultation; Specialized Treatment and Treatment Support; Treatment Support; Post-Treatment Consultation; Ongoing HBTS).
RI law mandates third-party health insurance coverage for ABA for qualifying children/adolescents with ASD until age 15 (effective Jan 1, 2012).
Licensure for BCBAs/BCaBAs was mandated and overseen by the RI Department of Health.
Clinical Supervision hours changed from 2 hours per week to 8 hours total per month.
Travel reimbursement was eliminated and rate adjustments were provided.
Coverage Criteria and Clinical Necessity
inv-01: HBTS General Medical Necessity
Covered when ALL of the following are met
inv-02: HBTS Service Components
Covered HBTS service components may include one or more of the following as specified in the Treatment Plan
Each component must be documented in the Treatment Plan and linked to measurable goals.
inv-03: Coverage for HBTS
Covered when ALL of the following are met
Provider must use collateral info and obtain parent/caregiver signatures on Treatment Plans.
inv-04: Treatment Support
Treatment Support criteria (rationale must be linked to one or more domains)
See Appendix 2: Treatment Support Domains.
inv-05: ABA Services (subset of HBTS)
ABA-specific coverage and supervision
Lead Therapist reports to Behavior Analyst/Clinical Supervisor and has defined responsibilities.
Requirements detailed in Appendix 6.
inv-06: Initial Eligibility / Level of Care
Covered when ALL of the following are met:
inv-07: Continuing Care / Reauthorization
Treatment Plan continuation requires ALL of the following:
Treatment Plans are approved for 12 months with required 6-month progress reports.
inv-08: Limitations of Service
Medication administration prohibited for HBTS staff under RI Nurse Practice Act
inv-09: Use of Restraint
Restraint is permitted only under emergency conditions and with strict safeguards; the following conditions and procedures apply:
Provider-agencies may decline referrals where history indicates likelihood of restraints.
inv-10: Clinical Supervision Requirements
Clinical supervision is mandatory for both Specialized Treatment and Treatment Support with specified responsibilities and documentation requirements:
All clinical staff must hold a valid Rhode Island DOH license or BCBA certification where applicable.
Documentation elements detailed in client record guidelines.
Some administrative activities are non-reimbursable.
inv-11: Administrative and Staffing Requirements
Provider-agency must maintain organizational, staffing and administrative processes to ensure reliable delivery of HBTS:
inv-12: Staff Qualifications and Background Screening
Minimum qualifications and required background screenings for various roles:
Must pass BCI and CANTS.
Must pass BCI and CANTS.
BCBA may provide Clinical Supervision; licensure from DOH required when procedures are issued.
Provider-agency must confirm conflicts of interest.
inv-13: Phase 1 Pre-Treatment and Treatment Plan requirements
Covered when the following program structure and documentation requirements are met:
Pre-Treatment intensity: 2 hours/week by a licensed clinician.
inv-14: ABA program content and quality requirements
ABA programs must satisfy the following content and operational criteria:
Providers must describe the curriculum and assessment tools (Appendix 6).
inv-15: Phase 1 (Pre-Treatment) coverage criteria
Covered when the following apply for up to 6 months:
Prior authorization required for each 6-month authorization period.
inv-16: Phase 2 (HBTS Specialized Treatment / Treatment Support) coverage criteria
Covered when provided per an approved Treatment Plan under licensed Clinical Supervisor:
Supervision, consultation, coordination, orientation, and plan development limits apply as listed in appendices.
inv-17: Phase 3 (Treatment Support) coverage criteria
Covered when ALL of the following are met for up to 6 months:
Treatment Support must be directed by Clinical Supervisor.
inv-18: Phase 4 (Post-treatment) coverage criteria
Covered for up to 6 months when used to transition out of HBTS:
Prior authorization required for each 6-month authorization period.
inv-19: Phase 5 (HBTS beyond 2 years) coverage criteria
Covered on an ongoing basis when ALL of the following are met and annually reassessed:
Ongoing duration assessed annually.
HBTS is intended for children and adolescents with moderate to severe special health care needs whose needs exceed typical outpatient care but do not require inpatient or residential placement. Services are provided in the child’s home, community, or outpatient setting and must be based on medical necessity documented by a physician’s prescription and an approved Treatment Plan with defined goals and measurable objectives. HBTS is not intended to replace clinically necessary therapies such as emergency behavioral health treatment, psychiatric care, speech and language therapy, occupational therapy, or physical therapy; HBTS represents an integrated set of components (Specialized Treatment, Treatment Support, or ABA) that support measurable treatment objectives.
HBTS must not be used to replace recommended or required therapies, nor to serve as respite for families or for transportation convenience. HBTS may be combined with other outpatient therapies or educational services, but inclusion of transportation in a Treatment Plan must be clinically justified and related to accomplishing previously approved treatment objectives; the State approves service provision only and assumes no liability for transportation.
HBTS will not be used as respite or childcare and will not substitute for services delivered by licensed professional mental health clinicians, private duty nursing, or Certified Nursing Assistants. HBTS staff are not permitted to administer medication; medication administration remains the responsibility of the parent/caregiver or other authorized adult per the RI Nurse Practice Act.
Physical or mechanical restraint is strictly a last-resort emergency intervention when there is an immediate, serious safety risk to the child or staff. Provider-agency policies must require staff certification in an approved crisis intervention model (including restraint techniques), thorough training in restraint guidelines and conflict de-escalation, First Aid and CPR certification, and clear documentation and supervisory review of each restraint episode. Recurrent use of restraint may trigger emergency psychiatric or medical consultation and re-evaluation of continuation of HBTS.
Restraint techniques are never to be used as punishment or to force compliance. Each episode must be documented and reviewed by the Clinical Supervisor to determine necessity and whether alternative interventions could have been used.
EOHHS may limit the amount, duration, and scope of services and may exclude any item or service it determines is not medically necessary, unsafe, experimental, or not generally recognized as accepted medical practice. Providers should expect EOHHS oversight, including site visits, and potential limits consistent with Medicaid regulations.
Families who have received outpatient services addressing the same issues within the past 6 months, or who are currently receiving relevant mental health services, may be exempted from beginning HBTS with Phase 1 Pre‑Treatment. Providers must document prior services in the Treatment Plan to support the exemption.
Services that are provided solely as companionship for the child or as respite for the family are not medically necessary uses of HBTS and are not covered under this policy. HBTS hours must be linked to measurable treatment goals and objectives in an approved Treatment Plan.
Experimental treatments are not reimbursable by Medicaid and therefore are not medically necessary under this policy. Provider-agencies must ensure interventions are consistent with accepted practice and documented medical necessity.
Billing Codes, Limits, and Coding Notes
| S9445 | Child Specific Orientation |
| H0046HO | Clinical Supervision - Master Level Clinician |
| H0046HP | Clinical Supervision - Doctoral Level Clinician |
| H0046 | Lead Therapy |
| H2014 | Specialized Treatment Consultation / Treatment Consultation (including OT/PT/SLP and master/doctoral-level variants H2014HO/H2014HP) |
| T1016 | Treatment Coordination |
| T1013 | Interpretation |
Authorization, Documentation, and Operational Requirements for Providers
Prior authorization procedure for HBTS
Prior authorization (PA) is required for reimbursement of HBTS. For fee-for-service families, each HBTS provider must submit prior authorization requests using the weekly batch PA form once a week, before the service start date; managed care providers must follow their third‑party payer procedures.
- Submit batch PA once weekly for FFS families, prior to service start date.
- Follow third‑party payer PA procedures for managed care enrollees.
Authorization required for additional ABA supports
Additional ABA supports — including extra hours for Clinical Supervision and Lead Therapy associated with discrete trial ABA interventions — require authorization and may only be provided by ABA‑recognized providers with approval from EOHHS or the family’s insurer.
- Authorization required for additional supervision and lead therapy hours for ABA.
- Only ABA‑recognized providers may provide these additional supports with authorization.
PA codes and required reports; treatment plan approval
Prior authorization procedure codes and required reports are specified in the appendices; Treatment Plan approval and the listed PA codes must be obtained prior to delivering services.
- See appendices (including Appendix 15) for PA procedure codes and required reports.
- Treatment Plan approval and applicable prior authorization must be in place before services begin.
Single approved provider‑agency is sole billing agent
EOHHS requires that a single legally incorporated entity be approved as the HBTS provider‑agency and that this certified provider‑agency act as the sole billing agent and accountable entity for all HBTS services.
- Certified HBTS provider‑agency is the single legal entity responsible for performance.
- That approved agency must be the single billing agent for all HBTS.
EOHHS review required for supervisor/consultant >30 hrs/week
Any pattern in which a Clinical Supervisor or Treatment Consultant provides more than 30 hours of service per week, unless approved by EOHHS, will be subject to review by EOHHS.
- Patterns >30 hours/week for a Clinical Supervisor or Treatment Consultant trigger EOHHS review.
- Approval by EOHHS is required to exceed this threshold without review.
Provider application, review time, and Letter of Approval
Applicants for HBTS provider approval undergo EOHHS review (anticipate a minimum of two months) and must receive a Letter of Approval to become certified; EOHHS may place limits on services per Medicaid regulations.
- Expect a minimum ~2 month review process including possible on‑site inspections.
- A Letter of Approval is issued on favorable determination; EOHHS may limit amount, duration, and scope of services.
PA required for T1024 TG/TF and Pre/Post‑Treatment Consultation
Prior authorization is required for Home Based – Specialized Treatment (T1024 TG) and Home Based – Treatment Support (T1024 TF); Pre‑ and Post‑Treatment Consultation also require prior authorization for each 6‑month authorization period.
Prior authorization — unspecified in these chunks
(No specific prior authorization action stated in the cited segments.)
Step therapy — not specified
(No step therapy requirements are specified in these sections of the policy.)
Coordinate benefits: Medicaid pays after commercial exhaustion
When a child has both commercial insurance and Medicaid, Medicaid will pay only after commercial benefits are exhausted; payment reverts to commercial insurance at the start of each benefit year — providers and families must verify and coordinate benefits.
- Providers/families must verify commercial coverage and provide proof to EOHHS.
- Medicaid assumes payment after commercial benefits are exhausted; payment reverts at each benefit year start.
HBTS only when intensified outpatient care insufficient; not with CAITS/CFIT/EOS
HBTS should be considered when intensified outpatient services have been insufficient; HBTS is not intended when CAITS, CFIT, or EOS are being used.
- Ensure intensified outpatient services have been insufficient before initiating HBTS.
- Do not provide HBTS when CAITS, CFIT, or EOS are in use.
Use restraint only as last resort with required training and documentation
Physical restraint is permitted only as a last‑resort emergency intervention presenting an immediate and serious safety risk; staff must follow documented protocols, be certified in crisis intervention and restraint techniques, and each episode must be documented and reviewed by the Clinical Supervisor.
- Restraint permitted only for immediate, serious safety risks and as last resort.
- Staff must be certified in crisis intervention and restraint techniques and First Aid/CPR.
- Each restraint episode must be documented and reviewed by the Clinical Supervisor.
Initiate HBTS referrals with Phase 1 Pre‑Treatment (2 hrs/week)
All HBTS referrals begin with Phase 1 Pre‑Treatment (up to 6 months) unless the family received outpatient services addressing the same issues in the past 6 months; Pre‑Treatment intensity is 2 hours/week by a licensed clinician.
- Phase 1 Pre‑Treatment is up to 6 months; families with relevant outpatient services in past 6 months may be exempt.
- Pre‑Treatment intensity: maximum 2 hours/week (4 units/week, 30‑minute units) by a licensed clinician.
- Prior authorization is required for each 6‑month authorization period.
Phase‑based initiation: start with Pre‑Treatment unless exempt
Families generally must begin with Phase 1 Pre‑Treatment (up to 6 months) unless exempt due to recent outpatient services; providers may continue Pre‑Treatment another 6 months if family will not proceed to Phase 2.
- Exemptions: families who received relevant outpatient services within past 6 months.
- Pre‑Treatment may be extended another 6 months if needed; outpatient referral recommended for longer‑term care.
Obtain physician prescription and maintain signed Treatment Plan with measurable goals
Provider‑agencies must obtain a physician's prescription documenting medical necessity and maintain an approved, signed Treatment Plan with defined, measurable goals and objectives; Treatment Plans must be reviewed at major decision points and at least every six months.
- Physician's prescription required as the basis for HBTS services.
- Treatment Plan must be current, comprehensive, individualized, signed by a licensed practitioner, contain measurable goals, and be reviewed at admission/discharge/major change and at least every 6 months.
Substantiate and document treatment intensity; observe 20‑hour (non‑ABA) limit
Treatment intensity (hours/week) must be justified in the record with documented medical necessity and measurable goals; non‑ABA HBTS is limited to up to 20 hours per week (combined HBTS+PASS up to 25 hrs with collaboration) and provider‑agency must justify the number of hours in the Treatment Plan.
- Document medical necessity and measurable goals tying to frequency and duration for requested hours.
- Non‑ABA HBTS: up to 20 hours/week; combined HBTS+PASS: up to 25 hours/week when documented and collaborated.
- Provider‑agency is responsible to justify hours as medically necessary.
Document measurable goals, use collateral info, and obtain caregiver signatures
Provider‑agencies must document written, specific, measurable treatment goals and objectives tied to intervention methods and measurement of progress; use collateral information (IEP/IFSP, evaluations) and obtain parent/caregiver signatures on Treatment Plans.
- Include specific, measurable goals, defined interventions, and methods for measuring progress in the Treatment Plan.
- Utilize referral/collateral information (IEP/IFSP, provider contacts, evaluations).
- Parents/Caregivers/Guardians must sign proposed Treatment Plans.
Ensure diagnosis within 3 years and include required evaluations for initial/continuing care
Initial Treatment Plan approval requires a formal behavioral health or medical diagnosis made within 3 years, a clinical diagnostic interview, evidence of functional impairment, and any necessary neuropsychological/educational/language evaluations; continuing care requires measurable progress documentation.
- Diagnosis must be within 3 years and supported by clinical interview and evidence of impairment.
- Include necessary testing/evaluations (neuropsychological, psychological, educational, language) as appropriate.
- Continuing authorization requires documentation of measurable progress toward goals.
Document reasons and provide 30‑day notice for suspension/termination
When suspending or terminating HBTS, document specific reasons, provide written notice to parents/caregivers and referral source/medical home 30 days prior, and maintain continuous written documentation describing safety concerns that led to suspension/termination.
- Provide 30 days' written notification to family, referral source, and medical home prior to discontinuation.
- Document specific reasons and maintain continuous written safety documentation leading to suspension/termination.
- Inform families of dispute resolution procedures and provide transitional support.
Support all billing with comprehensive client records
All billed services must be substantiated in the client record; client records must include initial and detailed assessments, Treatment Plan, documentation of services provided, changes in status, progress notes, and evidence of informed consent where required.
- Client record must support all billed service hours; records form the basis for billing.
- Include assessments, Treatment Plan, service documentation, progress notes, and discharge summaries when applicable.
- Entries must be dated, authenticated, and reflect reasons for clinical judgments.
Document clinical supervision with specified elements
Clinical supervision documentation must include the child’s name; recipient(s) of supervision; date; place; duration; purpose and content; recommendations and follow‑up; and signature of the Clinical Supervisor.
- Document date, place, duration, recipient(s), purpose/content, recommendations/follow‑up, and supervisor signature for each supervision event.
Document and clinically review every restraint episode
Each restraint episode must be documented and reviewed by the Clinical Supervisor for necessity and alternative interventions; Clinical Supervisor must document dates, duration, which worker received supervision, and sufficient content to substantiate service delivery.
- Document each restraint episode in detail and have Clinical Supervisor review for necessity and alternatives.
- Clinical Supervisor documentation must include date, duration, recipient of supervision, and sufficient content.
Maintain Treatment Plans and records available for EOHHS inspection
Providers must maintain comprehensive Treatment Plans documenting medical necessity signed by a licensed practitioner; records, claims documentation, clinical supervision notes, and related documentation must be available for EOHHS inspection, including site visits.
- Treatment Plans must be signed by a Licensed Practitioner of the Healing Arts.
- Maintain records and documentation accessible for EOHHS site visits and inspections; repayment or self‑audit may be required for adverse findings.
Document consultations, supervision, and data collection
Consultations, supervision, and treatment activities (including data collection on goals/objectives) must be documented; home‑based workers must collect and manage shift data and Clinical Supervisors must document supervision.
- Document consultations, supervision, and data collection on treatment goals/objectives.
- Home‑based workers collect data during shifts for targeted behaviors; clinical supervisors document supervision and summary reports.
Collect shift data and prepare summary reports
Home‑based workers must collect and manage data during shifts for targeted behaviors and prepare summary reports; clinical supervisors must document supervision activities and data for reports.
- Collect direct observation data on target skills and challenging behaviors during shifts.
- Prepare summary reports; Clinical Supervisors document supervision and compile data for reporting.
Maintain complaint logs and family satisfaction records for review
Maintain complaint logs with timeliness of complaint resolution and annual family satisfaction summaries; provide these records upon EOHHS request.
- Keep complaint logs and document timeliness of complaint resolution.
- Conduct and summarize annual family satisfaction surveys and provide results upon request.
Prior authorization required for reimbursement
Reimbursement for HBTS requires prior authorization (PA); failure to obtain required PA may result in denial of reimbursement.
- Obtain PA prior to billing to avoid denial of reimbursement.
Avoid preferential enrollment — risk of certification suspension/termination
A material breach such as preferential enrollment based on referral source or third‑party payer may be grounds for suspension or termination of certification; providers must not preferentially enroll clients.
- Do not preferentially enroll families based on referral source or payer; such conduct may be considered a material breach and trigger suspension/termination.
Do not use HBTS as respite/childcare or for experimental treatments
Using HBTS as respite, childcare, or for experimental treatments is not medically necessary and can lead to denial of services and reimbursement.
- Do not bill HBTS for respite, childcare, or experimental treatments; these uses are non‑covered and may be denied.
Verify continuous Medicaid eligibility to avoid non‑payment
Provider‑agencies must verify continuous Medicaid eligibility; failure to verify coverage can result in non‑payment or denial.
- Confirm and document continuous Medicaid enrollment before providing and billing services.
Providers may decline referrals with restraint history; multiple restraints trigger re‑evaluation
Provider‑agencies may decline referrals when there is a history or high likelihood of restraints; multiple restraints on a daily or weekly basis may trigger emergency psychiatric/medical consultation and re‑evaluation of HBTS continuation.
- Providers may decline referrals with prior restraint history or high likelihood of restraints.
- Multiple restraints may prompt emergency consultation and re‑evaluation of continued HBTS.
Repeated restraints may trigger emergency consultation and continuation review
Multiple restraints occurring daily or weekly may trigger emergency psychiatric/medical consultation and re‑evaluation of continued HBTS; providers must monitor and document restraint frequency.
- Document frequency of restraints; repeated incidents require emergency consultation and program re‑evaluation.
EOHHS may limit or exclude services deemed not medically necessary
EOHHS may exclude or limit services it determines are not medically necessary, unsafe, experimental, or not generally accepted; providers should expect EOHHS to set amount, duration, and scope limits.
- EOHHS can limit or exclude services based on medical necessity and safety considerations.
- Providers should comply with EOHHS determinations on amount, duration, and scope.
Adverse site‑visit findings can trigger repayment or self‑audit
Adverse findings on EOHHS site visits may require repayment; significant irregularities in billing or utilization may trigger a complete self‑audit and repayments.
- Maintain accurate claims and documentation to avoid repayment or required self‑audit.
- EOHHS site visits review client records, claims documentation, supervision notes, time sheets, and other materials.
PA required for T1024 TG and T1024 TF (and Pre/Post consultations)
Prior authorization is required specifically for T1024 TG (Home Based – Specialized Treatment) and T1024 TF (Home Based – Treatment Support); Pre‑ and Post‑Treatment Consultations also require PA for each authorization period.
Service delivery performance is measured; failure to deliver may trigger oversight
Failure to deliver authorized direct service hours may be measured and reported (performance metrics) and high percentages of undelivered services for provider reasons may trigger oversight actions.
- Measure % of delivered authorized direct service hours; monitor provider‑ and family‑caused non‑delivery.
- High rates of services not delivered may lead to EOHHS oversight or corrective action.
Background, Scope, and Definitions
HBTS serves children and adolescents with chronic developmental, cognitive, physical, medical, neurological, behavioral, and/or emotional conditions who require services more intensive than standard outpatient care but less restrictive than inpatient or residential settings. Services aim to improve functioning and support family-centered care, are authorized based on physician documentation of medical necessity, and are delivered in the child’s home, community, or outpatient setting with measurable goals and objectives documented in an approved Treatment Plan.
Level-of-Care and Place of Service Criteria
Applied Behavior Analysis (ABA) Requirements and Supervision
inv-96: ABA Provision and Coverage Notes
ABA-specific notes present in this part of the document
Provider-agencies specializing in ABA may act as Direct Service Providers subject to EOHHS approval.
inv-97: ABA criteria and roles
ABA-specific operational rules
Lead Therapist may directly observe assigned child/treatment worker once per month as needed.
inv-98: ABA inclusion and requirements
Applicable HBTS/ABA criteria are integrated into the HBTS level-of-care and clinical eligibility requirements.
inv-99: BCBA provisioning and supervision
Standards specific to Board Certified Behavior Analysts (BCBA) and clinical supervision in ABA contexts:
BCBA clinicians must obtain DOH licensure when procedures are issued.
inv-100: ABA program requirements
Appendix 6 lists specific ABA program components provider-agencies must describe and implement.
Providers must describe the curriculum used.
Providers must describe the assessment tool.
inv-101: ABA role definitions
ABA-related personnel and activity notes included in billable services:
Units determined case-by-case
Therapies, Interventions, and Supervision Activities
inv-102: ABA, OT, PT, SLP, Behavioral Interventions
Specialty Consultations address HBTS goals but do not substitute for IEP/IFSP therapies.
inv-103: Therapy consultations (OT, PT, Speech)
inv-104: Treatment Support / Specialized Treatment
Occurrence of target behaviors monitored and recorded during shift hours.
inv-105: Crisis intervention / Restraint protocols
Documentation of training must be placed in staff record.
inv-106: Clinical Supervision activities
Some listed administrative activities are non-reimbursable.
inv-107: ABA / HBTS training and clinical modalities
Medical training items include CPR/First Aid and universal precautions.
inv-108: ABA / Specialized Treatment
Units and billing as specified in appendices.
Service Intensity and Weekly Hour Limits
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