North Carolina Medicaid to tighten standards, technician certification and telehealth limits for RBBHT

North Carolina Medicaid officials said in a webinar that they will expedite updates to the Research Behavioral Health Treatment (RBBHT) clinical coverage policy (policy 8F), proposing tighter treatment‑planning requirements, new technician certification rules, clearer billing guidance and limits on telehealth for key assessment and direct‑service codes.

The proposed changes, officials said, are a response to rapid growth in RBBHT utilization and spending and increased federal and state oversight. Angela Smith, chief clinical officer for North Carolina Medicaid, said the policy went before the Physicians Advisory Group on April 30 and is planned for public comment ahead of an August 2026 promulgation.

LaCosta Parker, IDD and TBI program manager for North Carolina Medicaid, summarized the principal changes: treatment plans must rely on validated assessment tools and include standardized elements such as justification for treatment hours and whether the approach is focused or comprehensive; plans must include a weekly service schedule that lists Medicaid and non‑Medicaid services to prevent duplication; and observation and direction hours must fall between 10% and 20% of technician hours unless clinically justified. “When spending rises this quickly, it naturally raises questions about whether services are clinically appropriate, whether the treatment is individualized, and whether oversight structures are sufficient,” Parker said.

Officials also proposed minimum caregiver engagement standards: every plan should embed at least two caregiver‑specific measurable goals and include a minimum of six parent training sessions during each six‑month authorization; providers must document reasons when caregiver training is limited or omitted. On workforce standards, Parker said technicians will be required to obtain certification from either the Behavior Analyst Certification Board (BACB) or the Qualified Applied Behavior Analysis Credentialing Board (QABA), with new hires given 120 calendar days from hire to complete certification.

Billing guidance in the draft seeks to reduce ambiguity and audit risk by clarifying billable activities under RBBHT CPT codes (including expectations for CPT 97155) and by explicitly prohibiting billing for activities that duplicate or supplant non‑Medicaid supports (for example, IDEA services), for respite or custodial care, for habilitative services that are not RBBHT, or for unstructured activities such as naps, meals or transportation.

On telehealth, Parker said use “nearly doubled from 2024 to 2025,” and the updated policy would disallow telehealth for key assessment and direct‑service codes (97152, 97153, 97154) while allowing certain parent‑training codes (97156, 97157) to continue via telehealth. The policy would permit code 97151 via telehealth only with clinical justification. The draft also would bar out‑of‑state providers who are more than 40 miles from North Carolina from delivering RBBHT services in state.

The department emphasized that these slides present summaries and that full policy language will be posted for a 30‑day public comment period; stakeholders will be able to review detailed clinical coverage policy language when released. The department invited providers, families and health plans to submit feedback during the comment period.

Next steps: the agency said it expects to post the draft for public comment within the week and proceed with rule promulgation in August 2026; a public comment period of 30 days was announced.