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Georgia · Georgia Families · Autism spectrum disorder services

Georgia rewrote the ABA session note on October 1, 2026

Georgia governs ABA through its own Autism Spectrum Disorder Services manual, not the Health Check manual. The October 1, 2026 edition added a session-note standard: the note is completed no later than one business day after the service, carries seven named elements, and records the specific goals targeted with objective data. It applies to dates of service on or after October 1, 2026. The matching rule set lives in the rules library in the Penguin Health app, and we update it when DCH republishes the manual.

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In the rules libraryGeorgia Medicaid ABA · nine rules · maintained by Penguin · reviewed Oct 12, 2026

Session-note standard, dates of service fromOct 1, 2026

Part II Policies and Procedures for ASD Services, October 2026 edition.

Deadline to complete the note1 business day

§602.3.3.1. Backdated, copied, pre-written, and pre-signed notes are prohibited.

Required elements7

§602.3.3.3 and §602.3.4, from the member's name to a signature with credential and date.

Note templates2

One for technician notes and one for BCBA notes, §602.3.3.4 and §602.3.3.5.

October 1, 2026

What the new manual adds, and what a September note lacks

Georgia governs ABA through its own ASD services manual, not the Health Check manual. The October 1, 2026 edition is the first with a session-note standard, and it applies to dates of service on or after that day. Here is a note written the way many were written in September, marked with what it lacks under §602.3.3, and then what the manual adds. The note is fictional.

Session notewritten the September way

Client: M. B. 1
Date: 09/22/2026
Location: Clinic
Time: 9:00 am to 1:00 pm 2
Provider: T. O. 1

M. had a great day. Worked on goals with minimal prompting. 3 Some behaviors during transitions, redirected. 4 Will continue current programs.

Signed T. O. · 09/25/2026 56

1
Names and credentials
The member's name and the rendering provider's name and credentials are required elements. Initials are not a name, and "T. O." carries no credential.
Georgia §602.3.3.3
2
The CPT code billed
The note never says which code the four hours were billed under. Start and stop times are here; the code is not.
Georgia §602.3.3.3
3
"Worked on goals"
The manual names this phrase as not acceptable. The note has to state the specific goals targeted, with objective data.
Georgia §602.3.3.3
4
An opinion with no data
"Some behaviors, redirected" is an opinion unsupported by data: no behavior named, no count, no duration, no intervention.
Georgia §602.3.3.3
5
A signature without a credential
The signature carries a credential and a date.
Georgia §602.3.4
6
Three days late
The note is completed no later than one business day after the date of service. Backdated, copied, pre-written, and pre-signed notes are prohibited.
Georgia §602.3.3.1

A deadline§602.3.3.1

The note is completed no later than one business day after the date of service.
Backdated, copied, pre-written, and pre-signed notes are prohibited.

Seven required elements§602.3.3.3 · §602.3.4

Member name, date of service, service location, start and stop times, the CPT code billed, the rendering provider's name and credentials, and a signature with credential and date.

Substance§602.3.3.3

The specific goals targeted, with objective data.
Vague entries such as "worked on goals" and opinions unsupported by data are not acceptable.

Two templates§602.3.3.4 · §602.3.3.5

One for technician notes and one for BCBA notes. Both list the individuals present and caregiver observation, participation, or coaching.
97156 notes carry the caregiver goal, training procedures, caregiver performance, coaching or feedback, and recommendations.

Licensure and telehealth readinessRequirements on the practice

BCBAs and BCaBAs need a Georgia Behavior Analyst Licensing Board license as well as national certification.
A Telehealth Readiness Checklist is filed with the prior authorization. Providers delivering more than 25% of assessments or 50% of service units by telehealth are audited more often.

Penguin does not check licensure or telehealth readiness.

What the manual no longer saysOct 1, 2026

DCH removed its supervision percentage guide on October 1, 2026; the manual no longer states a supervision share.
Caregiver signatures on daily notes are not a Georgia requirement. CareSource dropped its own parent-signature rule in March 2025.

The checklist

Ten things a Georgia note has to show

§602.3.3.3 and §602.3.4 list the elements: member name, date of service, service location, start and stop times, the CPT code billed, the rendering provider's name and credentials, and a signature with credential and date. §602.3.3.3 also requires the specific goals targeted with objective data, and names what is not acceptable: vague entries such as "worked on goals" and opinions unsupported by data. §602.3.3.1 sets the deadline: completed no later than one business day after the date of service.

Here is that requirement as a technician's note under the technician template, each element tied to its section. The member, staff, and data are fictional.

Technician session note97153 · Adaptive behavior treatment by protocol

Member: D. P. (full name on file) · Georgia Families member ID TEST-00402 1
Date of service: 10/06/2026 2
Service location: Clinic, Macon, GA 3
Start and stop: 9:00 am to 12:00 pm · 12 units 4
CPT code billed: 97153 5
Rendering provider: Tomas Okafor, RBT 6
Individuals present: Member and RBT. Mother observed 11:30 to 12:00 and was coached on the mand prompt. 10
Supervising BCBA: Renee Castillo, M.S., BCBA, Georgia LBA (rendering provider on the claim)

Goals targeted, with data 8

Manding for preferred items (goal 2). Discrete trial training, 3 blocks. 21 of 30 independent (70%); 60% on 10/02.
Following one-step directions (goal 5). Natural environment training in the play area. 9 of 12 with a gestural prompt.
Transitions (behavior plan). First-then visual with differential reinforcement. 2 instances of dropping, 40 and 55 seconds; both ended with the visual.

Narrative

D. arrived alert and went to the work table on the first request. The RBT ran mand training with D.'s blocks and faded the vocal model after the second block; D. manded "block" independently in 21 of 30 trials, up from 18 of 30 on 10/02. During NET D. followed "put it in" on a gestural prompt in 9 of 12 chances. Two drops during the transition from the table to the play area, 40 and 55 seconds; the first-then visual ended both. D.'s mother observed the last 30 minutes and ran two mand trials with coaching on the prompt delay. No protocol changes.

Signed electronically: Tomas Okafor, RBT · 10/06/2026 12:14 pm 79

1
Member name
The first required element. A name, not initials.
Georgia §602.3.3.3
GA-2All seven elements, each with real content.
2
Date of service
The date the service happened, which is also the date the one-business-day clock starts.
Georgia §602.3.3.3
3
Service location
Where the service happened. The claim carries a location modifier (U6 in clinic, U7 out of clinic, GT telehealth); the note carries the location in words.
Georgia §602.3.3.3
4
Start and stop times
The minutes billed, as a start and a stop.
Georgia §602.3.3.3
5
The CPT code billed
Which code the time was billed under. A 97153 note that reads like 97155 is a finding either way.
Georgia §602.3.3.3
6
Rendering provider name and credentials
The person who rendered the service, with their credential. For RBT and BCaBA sessions the supervising BCBA is the rendering provider on the claim, but the technician writes and signs the note.
Georgia §602.3.3.3
7
Signature with credential and date
The signer's credential sits beside the signature, and the signature is dated. Pre-signed notes are prohibited.
Georgia §602.3.4 · §602.3.3.1
8
Specific goals with objective data
Named goals, the technique used, and the data: trial counts, percentages, durations, and the comparison with the last session. "Worked on goals" fails. An opinion with no data behind it fails.
Georgia §602.3.3.3
GA-3Named goals with objective data. Vague summaries and unsupported opinions fail.
9
Completed within one business day
The note is completed no later than one business day after the date of service. Penguin flags a note signed more than four calendar days after the session, which is late under any reading of one business day; it does not enforce the business-day deadline exactly.
Georgia §602.3.3.1
GA-1Signed more than four calendar days after the session fails.
10
Individuals present and caregiver participation
The technician and BCBA templates list who was present and whether a caregiver observed, participated, or was coached. A template item rather than one of the seven mandatory elements, which is why GA-4 ships turned off.
Georgia §602.3.3.4 · §602.3.3.5
GA-4, off by defaultTurn it on in the rules library if your templates carry these fields.

Two modifiers on every claim line

One for practitioner level (U1 physician, U2 psychologist or doctoral BCBA, U3 BCBA, U4 BCaBA, U5 RBT) and one for location (U6 in clinic, U7 out of clinic, GT telehealth).

Requirement onlyA DCH billing requirement. Penguin does not check modifiers.

A Georgia license

BCBAs and BCaBAs need a Georgia Behavior Analyst Licensing Board license as well as national certification.

Requirement onlyA licensure requirement. Penguin does not check licensure.

Telehealth readiness

A Telehealth Readiness Checklist is filed with the prior authorization. Providers delivering more than 25% of assessments or 50% of service units by telehealth are audited more often.

Requirement onlyA requirement on the practice. Penguin does not track telehealth share.

Who signs and who is on the claim

The technician signs the note. The BCBA is on the claim.

For RBT and BCaBA sessions, the supervising BCBA is the rendering provider on the claim and the technician writes and signs the note. The claim carries two modifiers per line, and the BCBA and BCaBA on it hold a Georgia license as well as national certification. Penguin reads the note: the provider named and credentialed on it, and the signature. It does not check modifiers, the rendering provider on the claim, or licensure.

On the noteWhat Penguin reads

Rendering provider name and credentials. The technician who delivered the service: "Tomas Okafor, RBT."
Signature with credential and date. The technician's, dated, within one business day.
Individuals present and caregiver participation, from the template.

GA-1, GA-2, and GA-4.

On the claimRequirements only

Rendering provider. The supervising BCBA, for RBT and BCaBA sessions.
Practitioner modifier. U1 physician, U2 psychologist or doctoral BCBA, U3 BCBA, U4 BCaBA, U5 RBT.
Location modifier. U6 in clinic, U7 out of clinic, GT telehealth.
Licensure. A Georgia Behavior Analyst Licensing Board license for BCBAs and BCaBAs.

DCH billing and licensure requirements. Penguin does not check any of these.

The 97155 problem

97155 is direction, not supervision

97155 is adaptive behavior treatment with protocol modification. In Georgia it is protocol modification, or direction of the technician, with the member present, and DCH calls notes that show "only supervision" inappropriate (§601.3.2; Appendix D). 97155 billed alongside the technician's 97153 is how direction is billed. Two other code rules sit next to it: 97154 and 97158 may not be billed concurrently, and 0373T requires the BCBA on site and immediately available.

Supports 97155

The member present, and the note says so.
A protocol modification named, with what changed and how the member responded.
Or direction of the technician during the member's session, with the technician's 97153 billed alongside.

Does not support 97155

Only supervision. Observing the technician with no modification and no direction tied to the member in the room.
Parent training written up as 97155. Caregiver training is 97156, with its own template elements.
A 97154 billed over the same minutes as a 97158. The two group codes are not billed concurrently.

GA-5 · 97155 documents protocol modification with the member presentFAIL

applies_when: procedure code contains 97155 · date of service on or after 2026-10-01
rule_text: Pass when the note shows a protocol modification or direction of the technician with the member present. Fail for supervision only.
modification_or_direction: false
rationale: Narrative states "Supervised RBT session; programs running as written." No modification and no direction tied to the member.

What the reviewer gets: the finding, the BCBA's educational email, and the action steps to amend or rebill, pre-filled with the date of service and a link to the note.

In the rules library

Nine Georgia rules, ready to turn on

Open the rules library in the Penguin Health app, choose Georgia Medicaid ABA, and click Add to organization. Rules your organization already has are left alone, so adding the set twice only fills gaps. After adding, edit any rule or add your own alongside them.

Each rule runs only on notes billed to Georgia Medicaid and Georgia Families plans. Penguin checks the CentralReach payer name, so a Georgia rule never fires on an Anthem commercial note in the same organization. The match is on payer names that contain the state's Medicaid label (for example "GA Medicaid CMO"), and an organization whose payer names differ edits that match after adding the set.

Penguin reads signed session notes from CentralReach, read-only, after signature and before the claim, and runs the set on every note. Deterministic rules compare record fields. AI rules are read by the AI, which returns a pass or fail with a one-sentence reason. Both means the AI reads a value off the note and a deterministic check makes the decision.

Rules that took effect with the October 1, 2026 manual apply only to sessions on or after that date; older sessions are skipped, not failed. GA-7 and GA-9 apply to all dates. GA-4 ships turned off because it checks template items rather than the seven mandatory elements; an organization whose templates carry those fields turns it on.

Rules libraryPenguin Health app

Georgia Medicaid ABAMaintained by Penguin

Nine rules for Georgia Families ABA, each with QA guidance by program code. GA-4 ships turned off.

reviewed: Oct 12, 2026
runs on: Notes billed to Georgia Medicaid and Georgia Families payers · GA-1 to GA-6 and GA-8 from Oct 1, 2026 · GA-7 and GA-9 all dates
sources: DCH Part II Policies and Procedures for ASD Services, Oct 1, 2026 · Georgia Behavior Analyst Licensing Board · CareSource MM-0212
watching: Georgia Behavior Analyst Licensing Board deadlines · CMO rate changes

Add to organizationAdds all nine rules and their QA guidance. Edit any rule afterward, or add your own alongside them.

Georgia requirement	What Penguin checks on every note	Georgia source	How
Completed within one business day of the serviceGA-1 · item 9 · from Oct 1, 2026	Flags a note signed more than four calendar days after the session, late under any reading of one business day.	§602.3.3.1	Deterministic
Required session-note elements are presentGA-2 · items 1 to 7 · from Oct 1, 2026	Member name, date, location, start and stop times, CPT code, provider name and credentials, signature with credential and date.	§602.3.3.3; §602.3.4	AI
Specific goals with objective data, no vague summariesGA-3 · item 8 · from Oct 1, 2026	Named goals with objective data; "worked on goals" or unsupported opinions fail.	§602.3.3.3	AI
Individuals present and caregiver participation recorded (off by default)GA-4 · item 10 · from Oct 1, 2026 · off by default	Who was present, and whether a caregiver observed, participated, or was coached.	§602.3.3.4 and .5 templates	AI
97155 documents protocol modification with the member presentGA-5 · The 97155 problem · from Oct 1, 2026	Modification or technician direction with the member present; supervision only fails.	§601.3.2; Appendix D	AI
97156 documents the caregiver training elementsGA-6 · from Oct 1, 2026	Caregiver goal, procedures, caregiver performance, coaching, recommendations.	§602.3.3.5	AI
97154 groups have 2 to 8 participantsGA-7 · all dates	Group size stated and between 2 and 8.	Appendix F	AI
0373T has the analyst on site; school 97156 has a parent presentGA-8 · from Oct 1, 2026	BCBA on site for 0373T; parent or guardian present for 97156 in a school.	Appendix D	AI
Units on the line are within the daily limitGA-9 · all dates	The billed line against the daily limit for its code (32, 24, 18, 16). Several lines on one day are not summed.	Appendix A	Deterministic

Every failure ships with QA guidance for that program code: an educational email, numbered action steps, and a QA email pre-filled with the date of service and a link to the note. Each reviewer action is written to a write-once audit log with seven-year retention, which is the record you hand a reviewer next time. And because the rules live in the library rather than in a template, an update from Penguin reaches every organization using the set. Billing Medicaid in more than one state? The rules library covers sixteen, including Florida and South Carolina.

Maintained by Penguin

We watch DCH so the rules never go stale

Georgia changed the session-note standard in one edition of the manual, and its payers have changed rates and signature rules on their own schedules. The Georgia set is tied to those documents, not to a template written once. Here is how it stays current, and what each change so far did to the set.

Watch

The DCH Part II Policies and Procedures for Autism Spectrum Disorder Services and each new edition, the Georgia Behavior Analyst Licensing Board, CMO medical policies such as CareSource MM-0212, and trade-press reports of payer rate changes.

Update

We rewrite the affected rule, cite the document that changed it, and date the review. The set shows its sources and review date in the library, so you can see it is current without asking us.

Re-run

An updated rule runs in the next scheduled validation and on demand against notes you have already reviewed, so a changed requirement shows you exactly which past notes it touches.

Mar 2025
CareSource drops its parent-signature rule
CareSource no longer requires a parent signature on daily session notes. Georgia does not require caregiver signatures on daily notes.
Apr 8, 2026
Behavioral Health Business reports a CareSource rate cut
Trade press reported that CareSource would pay ABA at 80% of the fee schedule from May 11, 2026. The cut was partly reversed for some providers in July 2026.
Oct 1, 2026
The ASD services manual gets a session-note standard
One business day to complete the note; seven required elements; specific goals with objective data; technician and BCBA templates; a prohibition on backdated, copied, pre-written, and pre-signed notes. DCH removed its supervision percentage guide the same day.
LibraryGA-1 through GA-6 and GA-8 apply to dates of service on or after this day. GA-7 and GA-9 apply to all dates.
Oct 12, 2026
Georgia set reviewed
Checked against the October 1, 2026 manual, the licensing board, and CareSource policy MM-0212. Current.
Watching
Licensing deadlines and payer rate changes
Georgia Behavior Analyst Licensing Board deadlines for BCBAs and BCaBAs, and CMO rate changes of the kind CareSource made in May and July 2026. When DCH republishes the manual, the set is updated and every organization using it gets the change.

Next step

Run a month of Georgia notes through Penguin

Bring one month of 97153 and 97155 notes from October. We add the Georgia set from the rules library, run it, show every finding beside the manual section it maps to, and hand your QA lead the fix for each one. Or get a demo account and click through Penguin on your own time first.

Book a demo Get a demo account

This page summarizes public documents for ABA providers in Georgia and is not legal or billing advice. Requirements change; everything here, and the Georgia Medicaid ABA set in the Penguin Health rules library, was reviewed against the sources below on October 12, 2026. When a source changes, the set is updated and the review date moves with it. The example note, its client, staff, and data are fictional. CPT is a registered trademark of the American Medical Association.

Georgia DCH Part II Policies and Procedures for Autism Spectrum Disorder Services, October 1, 2026 (§602.3.3.1 completion, §602.3.3.3 and §602.3.4 elements and substance, §602.3.3.4 and §602.3.3.5 templates, §601.3.2 and Appendix D on 97155, Appendix F group size, Appendix A daily unit limits, telehealth readiness)
Georgia Behavior Analyst Licensing Board (state licensure for BCBAs and BCaBAs)
CareSource Georgia ABA medical policy MM-0212 (CareSource dropped its parent-signature-on-daily-notes requirement in March 2025)
Behavioral Health Business, April 8, 2026, Georgia ABA providers brace for 20% rate cut from CareSource (rate paid at 80% of the fee schedule from May 11, 2026, partly reversed for some providers in July 2026)