CPT Code 97180 Explained: New Non-Face-to-Face ABA Services Code for 2027
With several major changes to ABA CPT codes taking effect in 2027, there's a lot for ABA providers to understand, and plenty of questions still to be answered as payers and providers prepare for implementation.
As part of our 2027 ABA CPT Code Series, we're breaking down the new and revised codes, what they mean in practice, and what providers need to know as January 1 approaches.
First up: 97180, the new code for certain non-face-to-face adaptive behavior services.
What Is CPT Code 97180?
Beginning January 1, 2027, 97180 will describe adaptive behavior non-face-to-face services personally performed by a physician or other QHP. This service involves clinical decision-making without the patient present.
To report 97180, the QHP must perform one or more of the following patient-specific activities:
Review and analysis of data and session notes on patient treatment targets,
Clinical decision-making regarding the need to modify treatment targets, goals, or protocols and/or making those modifications,
Clinical decision-making regarding the need for additional assessment and developing or modifying assessment protocols,
Developing discharge or transition plan,
Training on or reviewing treatment targets and/or revised assessment or treatment protocols with technician(s).
These are the only allowable activities. If an activity doesn't fall under one of these, don't report 97180.
Importantly, the service must be patient-specific. For example, training a new technician in the office on general ABA strategies wouldn't meet the requirements of this code. However, training a technician on a specific patient's treatment targets or revised assessment or treatment protocol may qualify.
What Doesn't Qualify for 97180?
While 97180 creates a way to report certain non-face-to-face clinical services, it shouldn't be viewed as a catch-all code for any work a QHP performs outside of a direct treatment session. The activity must be patient-specific and meet one of the elements included in the 97180 code descriptor. For example, activities such as general staff training, administrative tasks, employee performance management, or training technicians on general ABA procedures would not meet the requirements of 97180.
Reporting 97180
CPT code 97180 has some unique reporting requirements that providers and billing teams will want to understand before the new code takes effect.
Like the other adaptive behavior service codes, 97180 is reported in 15-minute units. However, guidance shared by the ABA Coding Coalition states that 97180 can be reported only once per week by adding together the time spent performing qualifying non-face-to-face services during the preceding seven days, rather than reporting each occurrence separately. This doesn't mean the service itself can only be performed once per week. A QHP may perform qualifying activities multiple times throughout the week.
For example, if a BCBA completes allowable activities for 30 minutes on Wednesday and 30 minutes on Friday, they would add that time and report the total: 1 hour (4 units).
Providers should confirm payer-specific billing and claims requirements before implementation, as payer policies may provide additional instructions for reporting the new code.
How Many Units of 97180 Can Be Billed?
CPT code 97180 is reported in 15-minute units, but the number of units that may be authorized or reimbursed will depend on the individual payer. Payers can establish their own coverage policies, authorization requirements, and unit or frequency limits for 97180.
How Do You Document 97180?
Documentation for 97180 should clearly support the patient-specific service performed and the time associated with that service. Because qualifying activities may occur at multiple points throughout the week and the time can be accumulated for reporting, providers will also need a reliable process for tracking qualifying time.
Documentation should make it clear that the work performed falls within the activities described by 97180. For example, simply documenting "treatment planning" or "case review" may not provide enough detail to demonstrate what service was actually performed and validate the claim.
With that said, specific documentation requirements may vary by payer. Review payer guidance as it becomes available and confirm what information must be documented to support billing 97180. Consider utilizing AI-powered note reviews to ensure documentation meets payer requirements.
97180 and 97151 Are Not Interchangeable
Code 97151, the existing code used for behavior identification assessment and reassessment, will remain in the 2027 code set. However, 97151 and the new 97180 are not interchangeable.
Each code represents a distinct service, and the work performed must meet the requirements of the code being reported. In other words, a QHP can't choose between 97151 and 97180 based on which code has available authorized units.
So, when should you use 97151 versus 97180?
97151 is used for behavior identification assessment and reassessment. It includes activities associated with assessing the patient and developing or updating the treatment plan, including certain non-face-to-face activities such as reviewing records and data, scoring and interpreting assessment results, and preparing the assessment report and treatment plan. 97151 is not intended for day-to-day treatment planning.
97180, on the other hand, describes a specific set of non-face-to-face adaptive behavior services performed by the QHP in the absence of the patient. This would be what many would consider ongoing "treatment planning," though it's important to note that treatment planning isn't the language used in the CPT Code Book.
Non-face-to-face work may occur under either code, but the activity must meet the requirements of the code being reported. For example, analyzing information as part of a patient's initial assessment would fall under 97151, while reviewing ongoing treatment data to determine whether treatment targets, goals, or protocols need modification would fall under 97180.
Does 97180 Mean Non-Face-To-Face Work Will Finally Be Reimbursed?
Not necessarily. Creating a CPT code establishes a standardized way to report the service, but it doesn't require every payer to cover or reimburse it.
Individual payer policies will determine whether and under what circumstances 97180 is covered, including specifics such as:
Whether a particular service is covered
Authorization requirements
Provider qualifications
Unit or frequency limitations
Documentation requirements
Reimbursement rates
As such, providers shouldn't assume that the introduction of 97180 means all qualifying activities can automatically be billed beginning January 1. Providers will need to review payer-specific policies and implementation guidance to determine when and how 97180 can be reported for reimbursement.
What ABA Providers Should Do Before January 1
Before the new codes take effect, providers should seek written guidance from each payer regarding how and when they plan to implement the 2027 ABA CPT code changes.
For 97180 specifically, consider asking payers about:
When they will begin accepting 97180
Whether the service will be covered and under what circumstances
Reimbursement rates
Authorization requirements and unit or frequency limits
Provider qualification requirements
Documentation requirements
Any payer-specific billing or reporting instructions
Organizations should also prepare internally by reviewing billing workflows, documentation practices, and staff training needs so clinical and billing teams understand when 97180 may apply. Remember, the new CPT code takes effect January 1, 2027, but coverage and reimbursement policies will depend on the individual payer.
Additional Resources For Adopting The 2027 CPT Codes
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