Behavioral Health and Substance Use Disorder Services (Members 18 and Over)
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Defines coverage, prior authorization, and medical necessity criteria for behavioral health and substance use disorder services for members aged 18 and older across outpatient, IOP, partial hospitalization, and inpatient settings, including specialized services (ABA, TMS, ECT). Affects providers contracting with Curative Health Plan for applicable products.
Replaced original ABA section with comprehensive ABA Therapy content integrating adult-specific clinical and regulatory framing.
36-month diagnostic currency requirement added for ABA services.
Mandatory supervision requirements for ABA (10% BCBA supervision ratio of RBT direct hours, minimum 2 face-to-face contacts/month).
Adult-specific weekly ABA hour caps defined (Focused up to 25 hrs/week; Comprehensive up to 30 hrs/week for ages 18-21 with justification).
Coverage and Medical Necessity Criteria
General Medical Necessity
Covered when services are medically necessary, evidence-based, and delivered by qualified providers in appropriate clinical settings.
Medical Necessity and Code-Specific Meets Criteria
Authorization and medical necessity require all universal prerequisites and applicable code-specific criteria to be met.
Coverage criteria for CPT 97156
MEETS CRITERIA when ALL of the following are true:
CPT 97156 (Family/Caregiver Adaptive Behavior Treatment Guidance) Coverage
Covered when ALL of the following are met:
Coverage criteria for CPT 97156
CPT 97156 MEETS CRITERIA when ALL of the following are true:
Coverage criteria for CPT 97156
Covered when ALL of the following are met
Coverage criteria for CPT 97156
Covered when ALL of the following are met
Adult ABA - Medical Necessity and Reauthorization
Covered when clinically indicated and documented in the treatment plan with clinical rationale. Reauthorization requires demonstration of medical necessity per listed criteria.
Age-Specific Coverage Criteria
Age-stratified criteria for young adult (18-21) and adults (22+).
TMS Coverage Criteria
TMS covered for FDA-cleared indications and select evidence-based uses with criteria.
Concurrent Services
Rules for ABA concurrent with SLP/OT/PT and vocational services.
TMS Coverage Criteria
TMS may be considered when APA/NNDC-supported indications and code-specific requirements are met.
ECT Coverage Criteria
ECT is medically necessary when diagnosis-specific criteria and general medical/supervision/consent requirements are met.
Inpatient Psychiatric Admission Criteria
Admission to inpatient psychiatric facility is covered when intensity of service and severity-of-illness criteria are met.
Inpatient SUD (ASAM 4.0) Coverage Criteria
ASAM Level 4.0 inpatient SUD services covered when ASAM-focused criteria are present.
ASAM Level 3.7 Coverage Criteria
ASAM 3.7 coverage when residential-level management is clinically indicated and appropriate.
Continued Inpatient Stay Criteria
Continued stay requires demonstration of ongoing need and active treatment.
Outpatient Coverage Criteria
Outpatient BH/SUD facility and professional services are medically necessary when diagnostic, setting, treatment approach, and documentation criteria are met.
IOP Coverage Criteria
IOP (H0015/S9480) coverage requires moderate symptoms and structured program requirements.
Outpatient Behavioral Health (H0004, H0005)
Standard outpatient behavioral health covered when ALL of the following are met:
Intensive Outpatient Program (H0015, S9480)
IOP covered when ALL of the following are met:
Partial Hospitalization (S0201) Admission Criteria
Partial Hospitalization (S0201) admission covered when all 'Intensity of Service' criteria AND at least one 'Severity' criterion are met:
PHP Continued Stay Criteria
PHP continued stay authorization requires ALL of the following:
Adult ABA Does Not Meet Criteria (Denial Bases)
ABA services for adults DO NOT MEET CRITERIA when ANY of the following diagnostic or documentation exclusions apply:
MHPAEA Compliance — Limitations Not Applied
MHPAEA parity considerations affecting ABA limits:
Adult ABA medical necessity
Covered when ALL of the following are met (adult ABA):
TMS - Does Not Meet Criteria
TMS coverage exclusion criteria listed (Does Not Meet Criteria):
ECT - Clinical coverage principles
ECT coverage stance and exclusions:
Level-of-care exclusions
Level-of-care coverage exclusions (Does Not Meet Criteria):
State-specific adult ABA mandate coverage and CHP parity approach
CHP coverage approach for ABA and behavioral health services for adults by plan type and state:
Coverage and payment determinations under this policy are driven by the member's own benefit plan and certificate of coverage. Inclusion of a CPT/HCPCS code or a described service in this policy does not guarantee coverage; all services remain subject to the plan's terms, conditions, limitations, and exclusions and require individualized medical necessity review by licensed behavioral health clinicians.
Telehealth delivery is explicitly prohibited for CPT 97153 (adaptive behavior treatment by protocol delivered by a technician). CPT 97153 requires in-person delivery per the policy's code-specific rules and supervision requirements.
No additional explicit exclusions are provided in the excerpted coverage criteria for CPT 97156 beyond the code-specific documentation and consent requirements described; reviewers should consult Sections 4Z and 5Z and the member's benefit terms for any plan-level exclusions.
Codes, Systems, and Billing Rules
Prior Authorization, Documentation, and Denial Risks
Prior authorization governs PA & medical necessity for BH/SUD services
This policy governs prior authorization requirements and medical necessity criteria for outpatient, intensive outpatient (IOP), partial hospitalization (PHP), inpatient care, and specialized services including ABA, TMS, and ECT for members aged 18 and over; submit PA requests with required documentation for the applicable level of care and codes listed in Section 4 and Section 3A. Authorization decisions are subject to the member's benefit plan terms.
PA required for adult ABA codes; 97151 required for initial assessment
Prior authorization is required for ABA therapy codes for members 18 and over and is governed by the adult-specific ABA section (Section 4Z); an initial behavior identification assessment (CPT 97151) is required prior to initiating treatment as specified.
97156 requires BIP training goals with measurable caregiver competency targets
CPT 97156 meets coverage criteria only when training goals are documented in the member's Behavior Intervention Plan (BIP) with measurable caregiver competency targets and are tied to the adult member's ABA program in natural environments.
97156 must support ABA implementation in natural settings and be BIP‑linked
CPT 97156 meets criteria when the caregiver/support-person training is designed to support implementation of the adult member's ABA program in natural settings (home, community, workplace) and training goals are documented in the BIP with measurable caregiver competency targets.
Coverage: 97156 covered when caregiver training criteria & consent documented
CPT 97156 is covered when all caregiver training criteria are met, including documentation of training goals in the BIP, design to support implementation of the adult's ABA program in natural settings, and consent/documentation requirements when the adult has decision‑making capacity.
Document adult consent to involve support persons for 97156 when applicable
Coverage criteria for CPT 97156 require that the training supports the adult's ABA program in natural settings and that, for adults with decision‑making capacity, the member's agreement to involve specific support persons in treatment is documented when applicable.
Authorizations and reauthorization intervals: 6 months with BCBA reassessment
Initial authorizations and reauthorizations for ABA are issued in 6‑month periods; formal BCBA reassessment is required at least every 6 months and must include Vineland‑3 and at least one criterion‑referenced instrument for reauthorization.
TMS PA and code-specific billing rules (90867/90868/90869)
TMS requires meeting specified clinical criteria and is billed per code: 90867 for the initial session (billed once per course), 90868 for subsequent delivery sessions (with a typical acute-course maximum of 36 sessions), and 90869 for motor‑threshold re‑determination with documented justification.
PA required for TMS/ECT and inpatient admissions; 90867 billed once per course
Authorization is required for TMS, ECT, and inpatient psychiatric admissions and must document that the service‑specific clinical criteria are met; initial TMS (90867) is billed once per course as the setup/mapping session.
PA required for IOP, PHP, outpatient BH/SUD services and required documentation
Prior authorization is required for specified services including IOP (H0015, S9480), PHP (S0201), outpatient behavioral health (H0004/H0005), and outpatient SUD services (H0012, H0013, H0014, H0016); PA requests must demonstrate medical necessity and include required documentation.
Adult ABA PA requires individualized review, session‑level documentation, 6‑month reauth
Prior authorization for adult ABA requires individualized medical‑necessity review with session‑level documentation (daily session notes, BIP, outcome measures) and 6‑month reauthorization evidence; PA requirements for ABA must be comparable to analogous medical/surgical PA criteria under MHPAEA.
Coverage is plan‑specific; code listing does not guarantee coverage
Coverage is determined by the member's specific benefit plan and certificate of coverage; the presence of CPT/HCPCS codes in this policy does not guarantee coverage and all services remain subject to plan terms.
PA decision timelines: standard 15 days, urgent 72 hours
Standard prior authorization decisions must be completed within 15 calendar days of receipt of all necessary clinical information; urgent PA decisions must be completed within 72 hours.
PA review must be performed by licensed clinical reviewers (policy use guidance)
This policy is intended for use by licensed clinical reviewers and AI‑assisted prior authorization systems; authorization determinations must be made by qualified clinicians using the clinical criteria in this policy.
ABA treatment intensity must be individualized; Focused = 10–25 hrs/week typical
Treatment intensity for ABA must be individualized by BCBA assessment; Focused ABA (10–25 hrs/week) is the standard upper limit for most adults while comprehensive intensity (up to 30 hrs/week for ages 18–21) requires documented extraordinary clinical justification.
Document adult member's consent/wishes regarding caregiver training participation
Document the adult member's participation or non‑participation in caregiver training consistent with their consent and wishes; when the adult has decision‑making capacity, record whether they agreed to involve specific support persons in treatment.
TMS requires documentation of prior antidepressant trial/failure or intolerance
For TMS in MDD, include documentation of prior antidepressant treatment failure or intolerance (at least one adequate trial in the current episode) unless a contraindication or documented patient preference applies.
ECT requires prior adequate medication trials for TRD definitions (≥2 trials)
ECT authorization for TRD requires documentation of prior adequate medication trials consistent with the TRD definition (failure of ≥2 adequate medication trials) or other listed indications per the ECT criteria.
Do not apply categorical step‑therapy/ fail‑first to adult ABA without clinical basis
Fail‑first or step‑therapy requirements are not applied categorically to adult ABA without clinical justification; CHP will not require trials of less‑intensive ABA as a universal prerequisite absent an individualized clinical basis in accordance with MHPAEA.
Prohibited: mandatory less‑intensive ABA trials for adults without clinical justification
Fail‑first or step‑therapy mandates that force trials of less‑intensive ABA for adults without individualized clinical justification are prohibited for fully insured plans subject to MHPAEA; clinical overrides must be permitted when justified.
Denial risk if BIP lacks documented training goals with measurable caregiver targets
Authorization or claims may be denied if training goals are not documented in the member's BIP with measurable caregiver competency targets; ensure the BIP includes measurable competency targets linked to 97156 requests.
Medical necessity determinations must be individualized and clinician‑led
Medical necessity determinations must be individualized and made by licensed behavioral health clinicians using all available clinical information; PA reviewers must apply the policy criteria on a case‑by‑case basis.
Required submissions: DSM‑5‑TR evaluation, Vineland‑3 baseline and 6‑month results, criterion‑referenced test
Submit a current DSM‑5‑TR diagnostic evaluation (ADOS‑2/ADI‑R preferred where applicable), baseline Vineland‑3 and Vineland‑3 at each 6‑month reauthorization, and at least one criterion‑referenced assessment (AFLS preferred for adults) to support authorization.
BIP must document training goals and measurable caregiver competency targets for 97156
Training goals for caregiver/support‑person sessions must be documented in the member's BCBA‑authored Behavior Intervention Plan (BIP) and include measurable caregiver competency targets; training must be designed to support implementation of the member's ABA program in natural settings.
Document adult agreement to involve specific support persons when member has capacity
When the adult member has decision‑making capacity, document the member's agreement (or documented non‑participation consistent with their wishes) to involve specific support persons in treatment; absence of such documentation may affect authorization for caregiver training codes.
Reauthorization requires Progress Summary Report, Vineland‑3, and criterion‑referenced results
At reauthorization, submit a Progress Summary Report with objective behavioral data for each active goal, updated Vineland‑3 and at least one criterion‑referenced assessment (AFLS preferred), updated BIP, support person engagement documentation, and treatment intensity justification.
When ABA co‑occurs with SLP/OT/PT: document distinct goals, quarterly coordination, avoid overlapping billing
When ABA co‑occurs with SLP/OT/PT, providers must document distinct non‑overlapping discipline‑specific goals, provide quarterly coordination communication, and not bill overlapping time blocks for simultaneous services.
Document clinical & administrative requirements for ECT/inpatient requests (medical clearance, consent, supervision)
Maintain diagnostic confirmation, medical clearance/anesthesia assessment (for ECT), informed consent, psychiatrist supervision documentation, and relevant prior acute response or treatment history when requesting ECT or inpatient services.
Maintain individualized treatment plan updates (≥90 days) and detailed daily session notes
Providers must keep individualized treatment plans with measurable goals updated at least every 90 days and maintain daily session notes documenting date/time/duration, setting, provider identity and BACB number, goals targeted, objective data, support person involvement, ABC incident format when applicable, and billing code/unit details.
Reauth submission must include Vineland‑3, criterion‑referenced results, and objective behavioral data
Reauthorization requests must include Vineland‑3 and criterion‑referenced assessment results (AFLS, VB‑MAPP, or ABLLS‑R) plus objective behavioral data demonstrating response during the prior authorization period.
Required ABA session documentation: date/time, setting, provider/BACB number, goals, objective data, support person involvement
Daily ABA session notes must include date/time/duration, setting, provider name and BACB number, targeted goals (by name or code), objective goal‑specific data, support person involvement, ABC‑formatted incident documentation, and any plan modifications; ensure billing codes and unit details are recorded.
Diagnostic currency: DSM‑5‑TR ASD evaluation required within 36 months for ABA authorization
Authorization requires a current DSM‑5‑TR ASD diagnosis within 36 months of treatment initiation; an older diagnostic evaluation (>36 months) necessitates a re‑evaluation with a validated instrument before authorizing ABA.
TMS session limit risk: >36 acute sessions without justification may be non‑covered
Exceeding 36 sessions for a standard acute TMS course without documented clinical justification may result in non‑coverage or require additional review and justification.
Denial risk: ABA billed without current comprehensive DSM‑5‑TR ASD diagnosis
Claims for ABA will be denied if billed for an adult without a current, documented DSM‑5‑TR ASD diagnosis established through a comprehensive evaluation (ICD‑10: F84.0, F84.5, F84.8, or F84.9); screening instruments alone are insufficient.
Denial risk: provider credentialing or supervision failures (BCBA ratios, improper billers)
Billing 97151, 97155, or technician codes by improperly credentialed or unsupervised staff, or failing to meet BCBA supervision ratio (≥10% of technician monthly direct hours and ≥2 face‑to‑face contacts/month) may trigger denial.
Do not bill custodial, non‑evidence‑based, or non‑billable time as ABA — risk of denial
Services that are custodial, non‑evidence‑based ABA derivatives, or non‑billable time (travel, administrative time, no‑shows) billed as ABA are excluded and will be denied.
Ohio adult applicability: ORC § 3923.84 generally does not apply to adults 21+
For fully insured Ohio plans, services for members age 21 and over may not be covered under the Ohio mandate (ORC § 3923.84); verify applicability and perform MHPAEA parity analysis when adjudicating adult Ohio claims.
Verify benefit plan terms & current state statutes for authorization decisions
All authorization decisions are subject to the member's specific benefit plan terms and state statute provisions should be verified against current law at time of claim adjudication.
Applied Behavior Analysis — Adult-Specific Criteria
ABA Therapy - Delivery & Supervision
Delivery, supervision, and concurrent billing rules for adult ABA therapy.
ABA Adult Clinical Prerequisites
Universal prerequisites and assessment requirements for adult ABA prior authorization.
ABA caregiver training criteria
Caregiver training as part of ABA for adult members meets criteria when:
Adult ABA Caregiver Training (97156)
Adult-specific ABA caregiver training criteria
ABA caregiver training criteria
ABA caregiver guidance
ABA-specific caregiver guidance criteria
ABA Clinical Criteria (Adults)
Adult ABA clinical criteria for setting, progress, reauthorization, and age-specific rules.
Adult ABA Clinical and Provider Criteria
Adult ABA coverage requires clinical and provider qualifications; otherwise services meet 'Does Not Meet' conditions.
Adult ABA policy nodes
ABA-specific policy points emphasizing parity and documentation:
State ABA statutory requirements (adult applicability)
State statutory requirements for ABA provision to adults vary by state and include age eligibility, dollar caps, hour minimums/limits, and provider licensure/supervision requirements.
Adult ABA clinical criteria
Policy integrates comprehensive ABA medical necessity criteria adapted for adults; key adult-specific elements summarized in revision history.
Therapies and Modality-Specific Rules
Units, Session Limits, and Intensity
Key Definitions and Reference Terms
Policy Context and Rationale
This policy aligns clinical criteria with relevant professional frameworks and evidence: it references American Psychiatric Association guidance, LOCUS for level-of-care placement, ASAM Criteria (4th ed.) for substance use disorder placement, and guideline and evidence sources for ABA, TMS, and ECT. The policy's clinical rationale and modality-specific criteria draw on these guideline sources and peer-reviewed evidence cited in the references section to support coverage decisions and level-of-care placement.
The policy integrates comprehensive ABA medical necessity criteria adapted for adult members. Adult ABA coverage is governed by the adult-specific Section 4Z ABA criteria, which were drawn from CHP-BEH-2026-003 and revised to include adult-focused elements (diagnostic currency, supervision ratios, caregiver/support person provisions, and weekly hour limits). Providers should use the adult ABA criteria when requesting prior authorization for ABA services for members aged 18 and older.
ABA-specific clinical criteria applied to adults are adapted from CHP-BEH-2026-003 and incorporated here. The full adult-focused ABA criteria are located in Sections 4Z and 5Z of this policy and include universal prerequisites (diagnostic confirmation and functional impairment), required assessments (Vineland-3 and criterion-referenced tools), BCBA supervision standards, BIP documentation requirements, and code-specific meets/does-not-meet criteria for CPT codes including 97156.
Policy Updates and Material Changes
Replaced original ABA section with comprehensive adult ABA content (Sections 4Z and 5Z) integrating adult-specific clinical and regulatory framing including diagnostic currency, supervision, caregiver participation, assessment tools, and weekly hour caps.
Initial policy creation that covered prior authorization categories for members 18+ and included an original ABA section with general adult ABA medical necessity criteria.
Policy metadata: Version 2.0; Effective date: 2026-04-01; Last review: 2026-04-27. This policy is intended for use by licensed clinical reviewers and authorized internal users; state statute applicability and MHPAEA considerations are noted and should be verified at claim adjudication.
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