CMS Releases Proposed 2027 Medicare Physician Fee Schedule: A Sneak Peek Into The New CPT Codes
The Centers for Medicare & Medicaid Services (CMS) has released its proposed 2027 Medicare Physician Fee Schedule (MPFS), providing the first official look at the new ABA-related CPT codes approved by the American Medical Association (AMA).
While many ABA providers have been anticipating more information about these changes, it's important to note that nothing is final yet. The proposed rule confirms that CMS intends to recognize the new and revised adaptive behavior CPT codes beginning in 2027, but the AMA hasn't officially released the codes.
What Happened?
CMS published the 2027 Medicare Physician Fee Schedule Proposed Rule. The proposal highlights the six new adaptive behavior CPT codes that were approved by the AMA CPT Editorial Panel in September 2025.
These codes are expected to become part of the 2027 CPT® Professional Edition, but they are not official until the AMA publishes the final CPT codebook, which is expected this fall.
The proposed Medicare Physician Fee Schedule is also subject to a 60-day public comment period. Providers, beneficiaries, and other stakeholders are encouraged to submit comments for the agency to consider before they finalize it.
The Six New Adaptive Behavior CPT Codes
ABA providers have been anticipating the release of these six new adaptive behavior CPT codes. The new codes are designed to better capture services that previously lacked specific billing options.
CPT Code | Description |
97X1X | Behavior identification–supporting assessment of harmful behavior; each 15 minutes of technician time face-to-face with a patient, requiring the following components:
|
97X2X | Behavior identification–supporting assessment of harmful behavior; additional technicians present, each 15 minutes |
97X3X | Adaptive behavior non-face-to-face services, personally performed by a physician or other qualified health care professional, each 15 minutes, with any of the following elements, when performed:
|
97X4X | Adaptive behavior treatment of harmful behavior; each 15 minutes of technician time with a patient, requiring the following components:
|
97X5X | Adaptive behavior treatment of harmful behavior; each additional technician present, each 15 minutes |
97X6X | Adaptive behavior treatment with analysis, administered by physician or other qualified health care professional, face-to-face with 1 patient, each 15 minutes |
A New Code Recognizes Important Non-Face-to-Face Clinical Activities
One of the most notable additions is 97X3X, a new code for adaptive behavior non-face-to-face services performed by a physician or other qualified healthcare professional. This code specifically recognizes clinical activities that are essential to effective ABA treatment but often occur outside of direct treatment sessions, like:
Reviewing and analyzing treatment data and session notes
Modifying treatment targets, goals, or protocols
Training technicians
Determining the need for additional assessments and modifying assessment protocols
Existing ABA CPT Codes Remain
The proposed rule also includes the existing adaptive behavior services CPT codes, including:
97151 – Behavior identification assessment
97152 – Supporting assessment by technician
97153 – Adaptive behavior treatment by protocol
97154 – Group adaptive behavior treatment by protocol
97155 – Adaptive behavior treatment with protocol modification
97156 – Family adaptive behavior treatment guidance
97157 – Multiple-family group guidance
97158 – Group adaptive behavior treatment with analysis
Telehealth
CMS also proposes keeping CPT codes 97151-97158 on Medicare's permanent telehealth services list for 2027. However, the proposal does not address whether the six new adaptive behavior CPT codes will also be eligible for telehealth services. The ABA Coding Coalition has indicated that it plans to request that CMS add the new codes to the permanent Medicare telehealth list before the final rule is published.
What ABA Providers Should Do Now
Providers should avoid making operational changes until the coding and payment policies are finalized.
For now, ABA organizations should:
Familiarize themselves with the six new codes
Monitor the publication of the 2027 CPT® codebook
Watch for the final 2027 Medicare Physician Fee Schedule expected in November
Hold off on updating electronic medical records or billing workflows until the codes become official
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