Maryland Medicaid covers ABA for children under 21 through the EPSDT benefit under COMAR 10.09.28 — and its structure is the simplest in our directory once you see it: there is exactly one pipeline. ABA (like all specialty behavioral health) is carved OUT of the nine HealthChoice MCOs and paid fee-for-service by the state through its Behavioral Health Administrative Services Organization (BHASO), Carelon Behavioral Health of Maryland. Whatever MCO card the family carries — Aetna Better Health, Priority Partners, Kaiser, UnitedHealthcare Community Plan — every authorization and every claim goes to Carelon, never to the plan. One credentialing path, one UM vendor, one statewide fee schedule (refreshed February 1, 2026), zero MCO variation.
The MDH ABA Provider Manual states it directly: ABA services are covered and reimbursed by the Medical Assistance fee-for-service program through its BHASO, Carelon Behavioral Health. MDH's HealthChoice pages say the same thing from the other side — specialty behavioral health is carved out of managed care, and the state pays providers directly. The practical consequences for intake: never route an ABA eligibility or authorization question to an MCO (Aetna Better Health, Priority Partners, MedStar, Wellpoint, or any of the nine); run benefits checks against Medicaid eligibility and Carelon, not the plan on the card; and expect parents to be confused by this — the MCO card is what they hold, but for ABA it's irrelevant. Providers enroll with Maryland Medicaid via ePREP and then register with the BHASO — that single path covers the whole state. (Carelon replaced Optum Maryland as the ASO; anything still pointing at Optum Maryland is stale.)[1][5][7]
All ABA services require prior authorization from the BHASO — the assessment included. The gate before everything is the Comprehensive Diagnostic Evaluation (CDE): a QHCP (developmental pediatrician, pediatrician, pediatric neurologist, child psychiatrist, clinical psychologist, neuropsychologist, or nurse practitioner) must complete a CDE with direct observation, caregiver interview, and developmental history, confirming the ASD diagnosis and referring for ABA. Only then can a psychologist, BCBA-D, or BCBA complete the 97151 assessment and treatment plan. Treatment authorizations run a maximum of 180 days; every cycle requires a reassessment (capped at 12 units / 3 hours per request unless more is justified) and a new PA on the state's Treatment Plan Template — biopsychosocial information, skill-acquisition goals, a behavior intervention plan, parent goals, and generalization, fading, discharge, and crisis plans. Requesting telehealth for 97155, 97156, or 97157 requires the Telehealth Readiness Checklist. Auths submit through Carelon's ProviderConnect; claims go through Availity Essentials; the ABA line is (800) 888-1965.[1][2]
Two documentation rules to design intake around: depending on the child's age at diagnosis and how long ago it was made, Carelon may require a Clinical Confirmation Form from a QHCP confirming the child still meets ASD criteria — so capture the diagnosis date, not just the diagnosis. And services must be home/community-based: clinic delivery needs individualized justification under COMAR 10.09.28.05C, participants over 6 are expected to be in school with an IEP, an RBT/BT may not serve as a 1:1 school aide, and school-based ABA is short-term and clinically justified only.[1][2]
The manual effective February 1, 2026 carries the current statewide fee schedule, tiered by credential per 15-minute unit: 97151 assessment pays $38.34 (psychologist/BCBA-D/BCBA, daily max 32 units); 97153 direct treatment pays $24.41 at the BCBA tier, $20.91 BCaBA, and $19.17 RBT/BT (daily max 32 units); 97155 protocol modification pays $38.34 (daily max 24 units, GT modifier for remote direction of a technician); and 97156 parent training pays $20.91 without the child present versus $38.34 with the child present, billed 97156-U2 (daily max 16 units). Also on the schedule: 97152 at $19.17, group codes 97154/97158, family-group 97157 at $12.91, and 0362T/0373T at $52.28.[1][3]
Two structural changes landed with this schedule. H2012 (ABA treatment planning) was discontinued effective February 1, 2026 — treatment planning folds into 97151 and care coordination into 97156, with existing H2012 auths honored through their end dates. And PT 42-26 (ABA Transmittal No. 8) loosened the combination-of-services rules effective January 1, 2026: ABA may now be billed same-date with other behavioral health services except 96156/96158/96159 and ECT, and Carelon is auto-reprocessing previously denied combination claims — if you ate those denials in 2025, watch for the reprocess.[1][3]
Only ABA groups, psychologists, BCBA-Ds, and BCBAs can bill directly — BCaBAs, RBTs, and BTs render under them. Maryland has an unusual workforce on-ramp: Behavior Technicians can enroll in Medicaid before earning RBT certification (specialty code 325), with a 90-day grace period to submit RBT proof. Licensed psychologists may render and bill ABA with an attestation (40 coursework hours in behavior analysis plus 1,500 supervised hours including ASD experience). Supervision has a hard floor — direction of BCaBA/RBT/BT staff must equal at least 10% of technician direct-service hours, and remote direction requires MDH/BHASO approval. Telehealth (GT modifier) is allowed only for direct supervision (97155), parent training (97156/97156-U2), and group parent training (97157) — direct 97153 treatment is not on the telehealth list at all. And as of April 1, 2026, those three telehealth-eligible codes carry a new in-person floor: PT 60-26 ("ABA Transmittal No. 9," issued February 27, 2026) ends 100%-telehealth delivery for 97155, 97156/97156-U2, and 97157 — at least 25% of the service must now be rendered in person, with up to 75% allowed via telehealth, superseding the older PT 11-22 telehealth-continuation guidance. And Maryland is a payment-in-full program: providers may not balance-bill participants for covered or denied services.[1][4]
Maryland's defining staffing rule: every individual who renders ABA — psychologist, BCBA-D, BCBA, BCaBA, RBT, and even not-yet-certified BTs — enrolls with Maryland Medicaid individually through ePREP, on top of the group's own enrollment. The technician floor is codified in state regulation, not just BACB policy: under COMAR 10.09.28.02, an RBT must be 18 or older, hold current BACB registration, hold a high school diploma or national equivalent (a copy attaches to the ePREP application), and work under a documented supervisory relationship with a licensed psychologist, licensed BCBA-D, or licensed BCBA. There is no separate Maryland RBT license or state technician registry — the binding credential is BACB certification plus individual Medicaid enrollment. The pre-certification BT on-ramp (specialty code 325, license number 'BT', 90-day expiration) covered above has one hiring trap: the 90-day grace period attaches to the person, not your company — a BT who used part of it at a prior employer doesn't restart the clock with you. Underneath all of this sits the BACB's own floor: RBT applicants must pass a criminal background check and abuse-registry check within 180 days of paying for the certification application, confirmed by the RBT Supervisor or Requirements Coordinator, and effective January 1, 2026 the 40-hour training must follow the updated 2026 curriculum, delivered by active BCBAs/BCaBAs who've completed the BACB's 8-hour supervision training.[8][1][9][10][11][12][13]
State screening runs through two instruments, and both are yours to manage. First, the CJIS criminal background check: COMAR 10.09.28.02 makes a completed Criminal Justice Information System background check a condition of participation for the group and each enrolled individual — it's completed as part of ePREP enrollment, using the CJIS Private Party Petition form from the Department of Public Safety and Correctional Services (DPSCS). There's no separate fingerprint clearance card system for ABA staff; fingerprint-based CHRC obligations attach to licensure applicants (behavior analysts), while unlicensed staff clear through Medicaid enrollment. Second, ongoing exclusion screening: the provider manual makes agencies responsible for OIG exclusion checks of ALL staff who touch the Medicaid program — direct service or administrative support — every 30 days, with documentation maintained; failure to screen is subject to disciplinary action. Enrolled providers must also be sanction-free — no current sanctions or disciplinary actions from licensing authorities, Medicare, Maryland Medical Assistance, or other federally funded programs.[8][1][9][10][11][12][13]
At the supervisor tier, Maryland has required licensure since January 2015: anyone practicing behavior analysis needs a Licensed Behavior Analyst (LBA) license from the Board of Professional Counselors and Therapists — current BCBA/BCBA-D certification, a master's or higher from a BACB-accredited/approved program, and a criminal history records check obtained before applying; the license renews every 2 years with a fresh CHRC at each renewal (and the board moves to online-only applications June 20, 2026). For Medicaid, supervisors need both the LBA license and current BACB certification (a licensed psychologist with the ABA attestation is the alternative). The supervision floors that bind your staffing model: direction of a technician (BCaBA/RBT/BT) must equal at least 10% of the technician's direct-service hours AND be performed in person at least 25% of the time (COMAR 10.09.28.04) — with remote direction requiring MDH or BHASO approval, and 0362T requiring the supervisor onsite. The BACB's 5%-monthly RBT supervision minimum (two face-to-face contacts, one individual) layers underneath. One structural mercy: because ABA runs through a single BHASO, there is no plan-by-plan credentialing — enroll each person via ePREP (applications reviewed by MDH, not the ASO), then register once with Carelon for ProviderConnect/Availity access; Carelon publishes no separate staff-credentialing standard beyond the state's, though it does require sentinel-event reporting (including any sexual activity between a staff member and a participant) within 24 hours.[8][1][9][10][11][12][13]
The questions that decide whether a family can start with Maryland Medicaid (Medical Assistance), and what they have to bring. Each maps onto something intake should ask on the first call.
Under 21. The manual states that since January 1, 2017 MDH covers medically necessary ABA “for Medicaid enrolled participants under the age of 21,” and that “ABA services are only available under the Early Periodic Screening, Diagnosis, and Treatment (EPSDT) program,” which itself runs to under 21. There is no lower age bound and no hour, dollar or lifetime cap on the benefit. One age-linked expectation rather than a limit: after 6 years old, participants should be in school with an IEP.[1]
No fixed expiry date on the Comprehensive Diagnostic Evaluation — but there is a conditional re-confirmation. The manual defines a Clinical Confirmation Form as “a form to be completed by a QHCP to confirm a participant continues to meet the criteria for Autism Spectrum Disorder,” and notes that “the need for the form is dependent on age of participant at time of ASD diagnosis and amount of time since that diagnosis was given.” So capture the diagnosis date and the child's age at diagnosis at intake, not just the diagnosis: those two facts decide whether Carelon will ask for a CCF before authorizing.[1]
A closed list of seven. The ASD diagnosis must be made by a qualified health care professional (QHCP) “with training and experience to diagnose ASD”: a developmental pediatrician, a pediatrician, a pediatric neurologist, a child psychiatrist, a clinical psychologist, a neuropsychologist, or a nurse practitioner. The ABA assessment that follows is a separate role and a separate credential — only a licensed psychologist, BCBA-D or BCBA may complete it and write the treatment plan.[1]
Maryland names no specific instrument. The manual requires the QHCP to diagnose “through the use of a comprehensive diagnostic evaluation (CDE) and with the help of validated instruments” without listing which, and then specifies the CDE by its components instead: a direct observation of the participant outlining behaviors consistent with DSM-5 criteria; interviews with the parent or caregiver; documentation of developmental history, psychosocial history and current functioning across major domains of development; and a statement identifying the presenting diagnosis (F84.0, F84.5, F84.8 or F84.9). Build intake around those four components rather than around a named tool.[1]
Required, and it is part of the CDE rather than a separate note. The QHCP's comprehensive diagnostic evaluation must result “in a referral for ABA therapy services,” and the BHASO “will only authorize ABA services if a QHCP completes a CDE and prescribes medically necessary ABA services.” Access to the benefit additionally requires that the participant be under 21, reside in a home/community setting and carry a confirmed ASD diagnosis. Every ABA service is prior-authorized by Carelon — assessment included — and authorizations run a maximum of 180 days.[1]
A short list, and no longer a full-time option. Only three services may be rendered by two-way audio-visual telehealth: direct supervision of a BCaBA/RBT/BT (97155), parent training (97156 and 97156-U2) and group parent training (97157). Direct 97153 treatment is not on the telehealth list at all, and “services rendered by mail or telephone” are expressly non-billable, so audio-only is out. Bill with the GT modifier and Place of Service 11, and attach the Telehealth Readiness Checklist to the treatment plan — a required element for any 97155, 97156 or 97157 telehealth request since October 16, 2023. Effective April 1, 2026, PT 60-26 ends 100 percent telehealth delivery for those three codes: at least 25 percent must be rendered in person, with up to 75 percent by telehealth. Telehealth that does not meet COMAR 10.09.49 may not be billed.[1][4]
Carelon, the state’s BHASO, decides every ABA request on its published clock: “Prospective - Non-Urgent … Within 7 calendar days” and “Prospective - Urgent … Within 72 hours (3 days),” while a non-urgent concurrent (continuing-care) request “reverts to prospective.” The operational rule is the submission lead time: Carelon’s Authorization Grid asks for ABA initial and concurrent requests “30 CD in advance,” with backdating tolerated only as an exception, up to 20 calendar days. Authorizations run a maximum of 180 days, and a reassessment plus a new PA is required before each one ends — so put the reauth packet on the calendar a month ahead of expiry. One discrepancy to know about: the grid (turnaround section last revised 8/14/25) still lists ABA turnaround as “14 CD”; the PBHS manual’s 7-calendar-day rule is newer (Chapter 5 revised August 2026) and matches the federal standard for state Medicaid agencies since January 1, 2026 (42 CFR 440.230(e)).[14][15][1][16]
“Medicaid is always the payer of last resort.” Verify other coverage in EVS at intake. When commercial insurance is primary: “Submit the claim to the commercial carrier first and within the commercial carrier’s timely filing requirements,” then submit to Carelon “within 12 months of the first date of service or 120 days of the commercial carrier’s EOB, whichever is later,” with the primary payment or EOB attached — claims without it deny (“Primary insurance information or EOB required”). Maryland’s big simplifier: “Preauthorization is not required when Carelon is paying as secondary.” Carelon pays the difference between the commercial payment and the Medicaid allowed amount, and the family may not be billed for the gap between charges and what the two payers paid.[14]
Coverage decides whether Maryland Medicaid (Medical Assistance) pays. These decide whether the claim survives: how sessions must be staffed and supervised, what may be billed concurrently, the per-day ceilings, who signs the note, where the service is payable, and whose NPI the claim goes out under.
Direction of a BCaBA, RBT or BT with protocol modification is performed by a psychologist, BCBA-D or BCBA and “must be performed on an ongoing basis, equal to at least 10 percent of the amount of hours that the BCaBA, RBT, or BT is providing direct ABA services to the participant, or group of participants.” COMAR 10.09.28.04 adds that at least 25 percent of that direction be performed in person, and remote direction requires approval from MDH or the BHASO. For 0362T and 0373T the psychologist/BCBA-D/BCBA must be onsite — defined on the fee schedule as “immediately available and interruptible to provide assistance and direction.” Every rendering individual, technicians included, must also be enrolled with Maryland Medicaid through ePREP.[1][9]
Maryland publishes an explicit per-day unit ceiling on every ABA code, in the fee schedule at the back of the provider manual (15-minute units): 97151, 97152, 0362T and 97153 at 32 units per day; 97155 and 0373T at 24; 97154 and 97156/97156-U2 at 16; 97157 and 97158 at 10. Group codes carry their own size limits — 97154 and 97158 are limited to 2–8 ABA participants, 97157 to 2–8 families. The reassessment is separately capped: a maximum of 12 units (three hours) authorized per treatment request, with more available if the standard 12 are used before the end of the authorization for clinical need.[1]
The manual lists what each service note must contain and closes it with the signature rule: “a legible signature, along with the printed or typed name of the individual providing care, with the appropriate title.” The rest of the required record is consent to treatment from the participant or parent/guardian; the location, date, start time and end time of the service; a brief description of the service with reference to the treatment plan; a description of the participant's behaviors or symptoms in measurable terms; and a description of the parent or caregiver's participation including their name, relationship, date and time — or documented consent to be absent. No co-signature requirement and no signing deadline are stated, and services “rendered but not documented in accordance with COMAR 10.09.28.04” may not be billed.[1][9]
Home and community first. Under COMAR 10.09.28.05C “ABA services shall be delivered in a home or community setting, including a clinic, when medically necessary,” and a clinic-based request must carry an individualized rationale, a plan for transitioning care into the home/community, the objectives targeted in each setting, a description of caregiver involvement, and the anticipated schedule of hours across settings. School is narrower still: it “is not the standard model of the Maryland Medicaid ABA benefit,” is short-term and must be clinically justified, an RBT/BT “may not serve as a 1:1 educational aide,” and the plan needs an observation narrative, a fading plan, evidence of no duplication and a copy of the IEP. After age 6 participants should be in school with an IEP. Not payable anywhere: services in a 24-hour, 365-day residential program funded with federal, State or local government funds; vocationally- or recreationally-based services; respite; and travel to and from the site of service.[1]
The Program reimburses only an ABA group or an individual ABA provider — psychologist, BCBA-D or BCBA. “BCaBAs, RBTs and BTs rendering ABA services cannot bill directly to the Maryland Medical Assistance Program and receive reimbursement,” so technician-delivered 97153 goes out under the enrolled group or supervising analyst. Claims bill on the CMS-1500 or the 837P and go to the BHASO, not to the participant's HealthChoice MCO. Every rendering individual still enrolls with Maryland Medicaid separately through ePREP, including not-yet-certified BTs on specialty code 325.[1][8]
Not resolved for ABA-to-ABA pairs. The ABA Provider Manual sets a 10 percent direction floor and requires that direction be delivered while the technician is treating, but neither it nor COMAR 10.09.28.04 states in terms that 97155 and 97153 may be billed for the same clock time. What Maryland did publish is the other kind of concurrency: PT 42-26 loosened the combination-of-services rules effective January 1, 2026 so that ABA may be billed on the same date as other behavioral health services except 96156, 96158, 96159 and ECT, with Carelon auto-reprocessing previously denied combination claims. The manual separately bars “services that duplicate a service that a participant is receiving under another medical care program.”[1][3]
Ask the plan: Carelon Behavioral Health of Maryland, ABA line (800) 888-1965 (Option 1 then Option 4) — ask whether 97155 pays alongside 97153 for the same clock time, and whether the answer changed with PT 42-26.
Yes — for children under 21 with a confirmed ASD diagnosis, under the EPSDT benefit (COMAR 10.09.28). Every ABA service requires prior authorization from Carelon Behavioral Health, the state's BHASO, with authorizations running up to 180 days.
None of them. ABA is carved out of all nine HealthChoice MCOs and paid fee-for-service through Carelon. Authorizations go through ProviderConnect, claims through Availity — the MCO on the family's card never touches ABA.
Per the fee schedule effective February 1, 2026: 97153 direct treatment pays $24.41/15-min unit at the BCBA tier, $20.91 BCaBA, $19.17 RBT/BT; 97151 assessment and 97155 pay $38.34; 97156 parent training pays $20.91 without the child present or $38.34 with (billed 97156-U2).
Yes — a confirmed ASD diagnosis (F84.0, F84.5, F84.8, or F84.9) made through a Comprehensive Diagnostic Evaluation by a qualified health care provider, plus a referral. Depending on the child's age at diagnosis and time elapsed, a Clinical Confirmation Form may also be required.
Not for 97155 (RBT/BCaBA/BT supervision), 97156/97156-U2 (parent training), or 97157 (group parent training) — effective April 1, 2026, PT 60-26 ("ABA Transmittal No. 9") requires at least 25% of those three services to be rendered in person, with up to 75% allowed via telehealth. Direct 97153 treatment was never on the telehealth list at all.
Payer policies change frequently and vary by plan, state, and funding type. This guide was compiled from the sources above and last reviewed September 2026; it is general information, not billing, legal, or clinical advice. Always verify current requirements against the payer's live policy and a benefits check for the specific member.
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