On this page
- Per the ABA Coding Coalition, yes, when both code descriptors are met and two different practitioners deliver them; a single QHP may not report both concurrently.
- In the Florida Medicaid Behavior Analysis Fee Schedule, 97153 XP and 97155 XP mark the supervisee's time under concurrent supervision.
- No. The ABA Coding Coalition says a single QHP may not report 97153 and 97155 concurrently.
The two codes
97153 is adaptive behavior treatment by protocol, administered by a technician under the direction of a physician or other qualified health care professional (QHP). 97155 is adaptive behavior treatment with protocol modification, administered by a QHP face-to-face with one patient. The QHP resolves one or more problems with the protocol and may simultaneously direct a technician in administering the modified protocol while the patient is present. Direction of the technician without the patient present is not reported separately. (Descriptor language as published in payer policy, for example Blue KC, and as quoted from CPT Assistant by the ABA Coding Coalition.)
Same day, different times
Billing both codes on the same date for separate, non-overlapping time blocks is ordinary. An RBT runs a 97153 session in the morning and the BCBA does 1:1 protocol work under 97155 later. Each line needs its own documented start and stop time and its own rendering provider.
Tip. Check the cited source for the current version before you change a billing process.
Same time: what CPT guidance says
The ABA Coding Coalition's FAQ answers "Can I report 97153 and 97155 concurrently?" with "Yes, as long as the criteria in the descriptors of both codes are met. A single QHP may not report 97153 and 97155 concurrently." Its supplemental guidance quotes CPT Assistant (November 2018): 97155 may be reported when the QHP directs the technician delivering 97153 and both the technician and the client are present. It argues this is not duplicate billing, because the two codes represent two different services.
Some public payers have adopted that reading, with conditions. Kentucky Medicaid announced that, effective December 2, 2025, 97155 may be billed concurrently with 97153 when the patient is present and the QHP is directing the technician implementing a modified protocol. Oregon Health Authority allows it when it is medically necessary and appropriate and the professional is providing targeted supervision, and caps the concurrent activity at four units or one hour. Blue KC's policy allows the overlap when different QHPs deliver the services and both descriptors are met.
Florida Medicaid: the XP line
Florida's Behavior Analysis Fee Schedule (January 1, 2025) takes a different approach. It lists:
| Code | Mod | Fee schedule entry |
|---|---|---|
| 97153 | $12.26 per 15 minutes; service provided by an RBT, a BCaBA, or a Lead Analyst | |
| 97153 | XP | Under concurrent supervision, not reimbursed. Supervisee only; supervisor may be reimbursed using 97153, 97155 or 97155HN |
| 97155 | $19.17 per 15 minutes; Lead Analyst | |
| 97155 | HN | $15.37 per 15 minutes; BCaBA |
| 97155 | XP | Under concurrent supervision, not reimbursed. Supervisee only; supervisor may be reimbursed using 97155 or 97155HN |
The schedule adds a note: when more than one BA practitioner provides concurrent services, one practitioner's services are reimbursable, unless the concurrent services are determined to be medically necessary, prior authorized, and indicated in the approved behavior plan. The coverage policy says the same in section 8.5.1: the supervisor may be reimbursed for observing a supervisee implementing the plan, and the supervisee is not reimbursed when the supervisor is reimbursed for the same time period.
In plain terms, under the Florida fee-for-service schedule the overlapping RBT time is reported with XP at no payment while the supervisor bills the supervision time. Fee-for-service rates are maximums. Since February 1, 2025, most Florida Medicaid BA claims go to SMMC plans, which may set different rules and rates, so check your plan contract and provider manual.
Documentation that keeps both lines safe
- Separate notes, each signed and dated by its rendering practitioner, with start and end times (Florida section 6.2.4 asks for date, time, location and duration).
- The 97155 note should state what protocol problem was addressed and what direction or modification was given. Florida's note list includes "protocol modification, changes to goals/objectives, and/or therapist directions provided during the session."
- The overlap window should match to the minute on both notes, and the units on each line should follow from the documented minutes.
A pre-claim check that lines up the two notes, flags an overlap billed without the payer's required modifier, and confirms the 97155 note documents an actual modification is the simplest way to keep this from becoming a denial or an audit finding.
Watch out. Payer contracts and plan manuals can add requirements beyond the rules summarized here.
FAQ
Can 97153 and 97155 be billed at the same time?
Per the ABA Coding Coalition, yes, when both code descriptors are met and two different practitioners deliver them; a single QHP may not report both concurrently. Payers differ: Kentucky and Oregon Medicaid allow it with conditions, while Florida Medicaid's FFS fee schedule reports the supervisee's overlapping time with modifier XP, not reimbursed.
What is the XP modifier on a Florida ABA claim?
In the Florida Medicaid Behavior Analysis Fee Schedule, 97153 XP and 97155 XP mark the supervisee's time under concurrent supervision. Those lines are not reimbursed; the supervisor may be reimbursed for the same time.
Can one BCBA bill 97153 and 97155 for the same minutes?
No. The ABA Coding Coalition says a single QHP may not report 97153 and 97155 concurrently.
Clean notes, clean claims, paid claims.
We check every ABA session note before the claim is built, and you keep the PM software you already use.
Related guides
Sources
- ABA Coding Coalition, Frequently Asked Questions
- ABA Coding Coalition, Supplemental Guidance Resource (quotes CPT Assistant, Nov 2018)
- Blue KC payment policy, Billing of ABA with Speech, Occupational and/or Physical Therapies
- Kentucky DMS, Concurrent Billing for ABA CPT codes 97153 and 97155 (Dec 3, 2025)
- Oregon Health Authority, Concurrent billing for ABA codes
- AHCA, Behavior Analysis Fee Schedule, January 1, 2025 (incorporated in Rule 59G-4.002, F.A.C.)
- AHCA, Florida Medicaid Behavior Analysis Services Coverage Policy (Dec 2024), incorporated in Rule 59G-4.125, F.A.C.
- AHCA, Behavior Analysis Services Information (SMMC transition, Feb 1, 2025)
Last reviewed October 2026. This page summarizes public rules and vendor pages for education; it is not legal or billing advice. Payer contracts and plan manuals can add requirements, so confirm with the payer.