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Webinar Q&A clarifies diagnoses, certification timelines and lack of grandfathering for some telehealth providers
Summary
In a Q&A following North Carolina Medicaid’s RBBHT policy presentation, staff clarified accepted diagnostic tools (ADOS‑2, BOSA, teleASD‑PEDs; CARS‑2 not accepted for initial diagnosis), confirmed a 120‑day certification window for technicians, and said there is no grandfathering for out‑of‑state telehealth BCBAs under the new statutory requirement.
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During the webinar’s Q&A, North Carolina Medicaid staff answered provider questions about supervision thresholds, diagnoses, certification and grandfathering under the statutory changes summarized in House Bill 696.
A Q&A speaker (Latoya) said that all aspects of a treatment plan — including observation and plan modification — must be clinically justified if observation exceeds 10 percent. On diagnostic tools, staff clarified that provisional diagnoses for children under 3 may be made by physicians, licensed psychologists, licensed psychological associates or master’s‑level clinicians with appropriate training and are valid for six months; nonprovisional diagnoses must be completed by physicians, licensed psychologists or psychological associates using validated tools such as the ADOS‑2, BOSA or teleASD‑PEDs. “CARS‑2 is not included, and that is not an accepted tool for initial diagnosis,” the Q&A response said.
On workforce rules, the Q&A confirmed behavioral technicians must stop rendering services if they do not obtain required national certification within 120 calendar days of hire. When asked whether there would be a grandfather period for telehealth BCBAs currently licensed in North Carolina, the department answered there is not a grandfather period because the prohibition on out‑of‑state providers is a new statutory requirement.
The Q&A also confirmed the slide deck and recording will be posted after the presentation and provided an email for further questions (bhidd.helpcenter@dhhs.nc.gov).

