CPT Code 97155 Is Changing in 2027: What BCBAs Need to Know About 97155 vs. 97173
If you regularly bill CPT code 97155, you'll want to pay close attention to the changes taking effect January 1, 2027. The way 97155 is defined, and when BCBAs can use it, is changing significantly.
Beginning in 2027, 97155 will be used specifically for direction of a technician with analysis. It will no longer be used when a BCBA provides one-on-one treatment directly to a patient, and it shouldn't be confused with general supervision of an RBT.
So, what exactly is changing and what does it mean for ABA providers? Let's break it down.
What's Changing With CPT Code 97155 in 2027?
Under the current CPT code set, 97155 is used for adaptive behavior treatment with protocol modification administered by a physician or other QHP. Historically, this has been a dual-use code. It could be used when the QHP provided one-on-one treatment directly to the patient and modified protocols, or when the QHP overlapped a technician and modified protocols.
In other words, the existing code has encompassed both QHP-delivered treatment and QHP direction of technician-delivered treatment. That changes in 2027.
The revised 97155 is specifically described as adaptive behavior direction of a technician and analysis by a physician or other QHP, face-to-face with a patient. This code, along with all other ABA-related CPT codes, is reported in 15-minute units.
At the same time, the new CPT code 97173 has been created for adaptive behavior treatment with analysis administered face-to-face with one patient by a physician or other QHP. This creates a much clearer distinction based on who is actually delivering the treatment.
At a high level:
97155 = QHP direction of a technician + analysis
97173 = QHP-delivered treatment + analysis
But there are some important nuances to understand, which we'll further explore.
What Does "With Analysis" Mean?
A notable change you'll see in code 97155 and throughout the 2027 adaptive behavior CPT codes is the use of the term "analysis" in services performed by a physician or other qualified health care professional (QHP). But what does that mean?
The CPT Code Book defines analysis as cognitive work performed by a physician or other QHP during the face-to-face delivery of assessment or treatment services to the patient or caregiver(s). In practice, this involves observing how the patient or caregiver responds to the treatment and determining whether treatment targets or protocols need to be adjusted.
You'll see "analysis" incorporated into QHP-level codes such as 97155 and the new 97173, while technician-level services such as 97153 continue to describe treatment by protocol.
Importantly, performing analysis doesn't necessarily mean that the BCBA must actually modify the treatment protocols. The QHP may analyze the patient's response and determine that no adjustment is needed. It's the analysis and clinical decision-making, not simply whether a protocol ultimately changes, that distinguishes this component of the service.
97153 vs. 97155 vs. 97173
With the addition of 97173 and changes to 97155, it can help to look at these three treatment codes side by side.
CPT Code | What's Happening? | Who Can Deliver the Service? |
97153 | Delivering treatment by protocol | Technician or QHP |
97155 | Directing a technician + analysis | QHP (reports 97155 while the technician reports 97153) |
97173 | Delivering treatment with analysis | QHP |
When Might 97155 Be Used?
Imagine an RBT is working directly, face-to-face with a patient, implementing treatment protocols as written. At the same time, the BCBA evaluates the patient’s responding, directs the RBT, observes implementation, provides feedback, and analyzes whether treatment targets or protocols need to be adjusted. The analysis may result in modifications, or the BCBA may determine that no changes are necessary.
Under the 2027 code descriptors, this type of service aligns with 97155 as the QHP is providing direction of the technician and analysis while face-to-face with the patient.
When NOT to Report 97155
Beginning in 2027, 97155 is specifically for direction of a technician and analysis by the QHP. With that said, 97155 wouldn't be the appropriate code in any of the following situations.
The BCBA/QHP is providing 1:1 treatment with analysis directly to the patient, without directing a technician.
The BCBA/QHP is simply delivering treatment by protocol in place of the technician, without performing analysis.
The technician is not actively delivering treatment to the patient while being directed by the QHP.
The BCBA is providing general supervision rather than patient-specific direction of treatment.
The service is not face-to-face with the patient. The 2027 descriptor for 97155 specifically requires the QHP to be face-to-face with the patient.
Important Note: "Face-to-face" doesn't mean the BCBA has to be in person. This code can be rendered via telehealth when clinically appropriate and allowed by the payer and state law.
Concurrent Billing: Can 97153 and 97155 Be Reported at the Same Time?
Under the 2027 guidance, 97155 is reported in conjunction with another code because the QHP is directing a technician who is actively delivering a service to the patient.
However, it's important to distinguish CPT coding rules from payer coverage and reimbursement policies. Although the CPT code set allows 97153 and 97155 to be reported concurrently when the requirements of both codes are met, individual payers may establish their own policies. Providers should communicate with provider reps ahead of the 2027 changes for payer-specific guidance.
What Is The New CPT Code 97173?
97173 is a new code for adaptive behavior treatment with analysis delivered directly by a physician or other QHP.
Under the current code set, QHP-delivered 1:1 treatment involving evaluation of the need for protocol modification has been reported under 97155. However, to bill 97155 in 2027, a technician must be present and actively engaged with the patient. Therefore, QHPs who deliver direct care with analysis (e.g., analyzing the learner's response and making modifications as necessary) can bill 97173 instead.
Example: When Might 97173 Be Used?
Imagine a BCBA is working one-to-one with a patient. The BCBA directly implements treatment. However, they also analyze the patient’s responding and determine whether changes to treatment are needed. There is no technician delivering the treatment during this service. Beginning in 2027, this type of QHP-delivered treatment would be reported using 97173.
Does BCBA-Delivered Treatment Automatically Mean 97173?
No. The code you report should be based on the service being delivered, not simply the credentials of the person delivering it. CPT code 97153 continues to describe adaptive behavior treatment by protocol. Although this service is typically delivered by a technician, a QHP can also deliver treatment by protocol.
A good example of this is a BCBA who fills a 1:1 session on another BCBA's caseload. If the BCBA simply implements the patient's established treatment protocols without performing analysis, the service would be reported using 97153.
What About 97153?
97153 continues to describe adaptive behavior treatment by protocol administered by a technician (or QHP), face-to-face with one patient.
These three 2027 codes more clearly differentiate between treatment by protocol, QHP direction of a technician with analysis, and QHP-delivered treatment with analysis.
Treatment by protocol: 97153
QHP direction of a technician with analysis: 97155
QHP-delivered treatment with analysis: 97173
How ABA Providers Can Prepare for the 2027 CPT Code Changes
The new and revised CPT codes take effect January 1, 2027, but that doesn't mean implementation will look exactly the same across payers. Coverage, reimbursement rates, authorization requirements, and other policies are determined by individual payers.
Providers should begin reaching out to payers before the transition to understand how they plan to implement the new codes. Ask when fee schedules and claims systems will be updated, whether existing authorizations will be honored or replaced, how services under the new codes will be authorized, and whether reimbursement rates or billing requirements will change.
Organizations should also use this time to prepare internally. That may include:
Updating billing and practice management systems for the new codes
Reviewing authorization and billing workflows
Training BCBAs, technicians, and billing teams
Updating documentation templates and terminology
With recent increased payer scrutiny, organizations may also want a way to proactively identify documentation gaps before they become billing or compliance problems. Brellium uses AI-powered clinical documentation review to audit notes at scale and flag potential issues, helping ABA organizations strengthen documentation and prepare for changing requirements.
Additional Resources For Adopting The 2027 CPT Codes
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