FABA Update Regarding South Florida Moratorium and Upcoming CPT Codes

You will see in the November 10, 2021 Medicaid Alert that AHCA has extended the Moratorium for Provider Enrollment another 6 months, to May 13, 2022.

In addition, AHCA has announced the forthcoming transition from the current Healthcare Common Procedure Coding System (HCPCS) to the national Current Procedural Terminology (CPT) Codes.  The Agency plans to have the CPT-based behavior analysis fee schedule in place effective July 1, 2022.

In anticipation of this transition, FABA met with the AHCA team who will be driving this change.  We agreed that as soon as the Provider Alert was published then additional messaging and training would be developed and provided incrementally to help providers have a smooth transition to this national standard. 

You may have heard that a strong coalition of behavior analysis supporting organizations have been collaborating on a model health insurance coverage policy since 2016 for the AMA with the model specifically for ABA providers developed in 2020.   The ABA Coding Coalition included representatives of the Association of Professional Behavior Analysts, Autism Speaks, Behavior Analyst Certification Board, Council of Autism Service Providers, and their CPT® consultant.

It is felt by providers both at the national and local level sampled here in Florida that this is a good change regardless of who your payers are.  At present there is considerable variability across payers in policies regarding ABA services.  In turn, to the extent that payers will adopt these standards there should be more consistency in the coverage of ABA services.  This should enable providers of ABA services to communicate with payers about appropriate coverage determinations, including indications, limitations, and competence level of those providers recommended to render services.

FABA will continue to meet with this AHCA transition team as information becomes available and to help develop language for policy and rule related to the transition to CPT Codes.

Thank you for staying engaged with us as we work with the Agency for Health Care Administration to help with this transition and address any questions or concerns you may have about this change.  Remember you can always contact us at:  [email protected] .

Regards, Steve Coleman, BCBA-D

FABA’s Public Policy Director