Applied Behavior Analysis (ABA) Supervision Requirements

Effective October 1, 2025, the New York State Department of Health (NYS DOH) will implement updated supervision standards for Licensed Behavior Analysts (LBAs) overseeing unlicensed individuals/technicians delivering Applied Behavior Analysis (ABA) services.

These requirements apply to both Fee-for-Service (FFS) Medicaid and Medicaid Managed Care (MMC) plans, including Healthfirst.

Key Policy Changes

• LBAs must supervise unlicensed individuals/technicians for a minimum of 5% of the ABA service hours provided each calendar month.
• Supervision must include at least two face-to-face, real-time contacts per month (not permitted via phone, email, or text).
• At least one of the monthly contacts must include the LBA directly observing the technician providing services.
• Supervision may occur on-site or via synchronous audio/video technology consistent with NYS Medicaid telehealth policy.
• Small-group supervision may be used for one of the required monthly real-time meetings, provided the primary focus remains on technician engagement and participation.
• Supervision may include, but is not limited to: developing performance expectations; observing, providing behavioral skills training, and delivering performance feedback; modeling technical, professional, and ethical behavior; guiding the development of problem-solving and ethical decision-making capacity; reviewing written materials (e.g., daily progress notes, data sheets); overseeing and evaluating the effects of behavior-analytic service delivery; and/or providing ongoing evaluation of the effects of supervision.

Use of CPT Code 97155 (When Applicable)

The 5% required supervision may include CPT 97155 only when the LBA is:

• Present with the patient and technician, and
• Directing the technician in implementing a new or modified treatment protocol.

Documentation Requirements

• All supervision must be documented in the patient’s file.
• ABA providers must retain records for a minimum of six years, or until a minor turns 22.
• MMC providers must retain records for 10 years.

More Information

• eMedNY Applied Behavioral Analysis Policy Manual

Questions?

If you have any questions, please contact your Network Account Manager, or call Provider Services at 1-888-801-1660, Monday to Friday, 8:30am-5:30pm.