It is proposed that DMAS adjust their expectations for the concurrent billing of code 97151.  Considering the scope of the necessary, non face-to-face activities provided using code 97151 for reassessment, it would be in our clients’ best interest to allow overlapping services when medically necessary.  While a QHP is performing the non face-to-face, reassessment services of 97151, the client and their family can still receive services from other qualified providers in the form of 97153, 97154, 97155, 97156, 97157 and 97158.  To restrict non face-to-face usage of 97151 only to times outside of a client’s direct care yields no benefit and creates barriers to care.  The ABA Coding Coalition has provided feedback that the provision of these services by different providers is distinct and separate, and could be legitimate for concurrent billing, and that per CPT guidance, there are not any exclusionary parentheticals preventing this.  Additionally, other payors allow for the concurrent billing of 97151 with other ABA codes. 

It is understood and agreed that billing for the face-to-face component of 97151 will carry differing implications, and it is understood that code 97152 can already be billed concurrently under certain limitations.  It is also understood that the medical need for concurrent billing otherwise would not be the norm, but rather the exception.  For these exceptions, however, allowing the concurrent billing of code 97151, for non face-to-face reassessment functions, with all other ABA codes performed by different providers as separate and distinct would increase client access to care.