From Clone Notes to Communication Issues, Payers Share Common ABA Documentation Mistakes

When it comes to behavioral health providers being reimbursed for their services, documentation is key. But in the applied behavioral analysis (ABA) realm, documentation mistakes that can impact reimbursement and authorizations are common.

Just ask Christina Weston, vice president of behavioral health at CareSource, a Medicaid and Marketplace insurer that operates in five states.

“One of the things that I see a lot that, in my mind, is an indicator of poor quality is cookie-cutter treatment plans,” Weston said. “There’s the exact same phrase for when to stop care, and there’s the same number of hours for every single kid.”


Weston made those comments late last month during a panel at the 2021 virtual Autism Investor Summit, which was put on by Sara Litvak and Ronit Molko. There, she and her fellow panelists — Darren Sush, head of autism and psychology at Cigna (NYSE: CI), and Brian Dowd, an executive for the Georgia Medicaid program — shared the payer perspective on common pain points in ABA. 

Like Weston, Dowd pointed to “clone notes” as one of the most common documentation issues he sees from ABA providers.

“If I can tell you’re updating the name and the date and the time and that’s it, that’s a problem for me,” he told panel attendees.


Instead, Weston and Dowd advised providers to be as detailed as possible in their notes and care plans, taking each child’s individual needs into account and documenting them. For example, a 2-year-old and a 6-year-old probably can’t tolerate the same number of care hours per day, she said, and their care plans should reflect that.

Documentation is also essential to explain why children aren’t progressing as they should, often due to the fact that they’re receiving fewer hours of care than they’ve been authorized for. While that’s sometimes a function of limited staffing, Sush advised providers to make that clear to payers.

“One of the things that we look for oftentimes as a funding source is: number one, is there a need?” he said. “But then, also, is this individual making progress within the services that are being provided? … And if the understanding is that the individual is getting a certain intensity, but they’re really not, then that could look like that intensity may not necessarily be appropriate for that individual.”

Because progress for children with autism can vary from patient to patient, it’s also important for providers to include quantifiable goals in their treatment plans. That way, payers can more easily measure success when it comes time for a reauthorization.

The same goes for outcomes measures and discharge planning.

“If you don’t have a clear measurable way of identifying when you’re going to feel comfortable phasing yourselves out, then it makes it that much more difficult for treatment planning along the entire path,” Sush said.

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