Penguin Health
Louisiana · Healthy Louisiana · Applied behavior analysis
Louisiana is tightening ABA oversight. The daily log is the record.
Louisiana Medicaid ABA spending grew 41% in three years, and in September 2026 LDH announced the response: high-risk provider screening with fingerprinting and site visits, and a review of authorized-hours policy. The documentation standard has been there all along: the ABA manual's daily documentation log and a per-code table that says plainly: data collection is insufficient for a medical record. The matching rule set lives in the rules library in the Penguin Health app.
Over three years, per the LDH secretary in September 2026.
Chapter 4, section 4.4: attendees, times, narrative, code, signed credentials, individualization.
New start and stop times after any break of 12 or more minutes, and on any code switch.
High-risk screening, fingerprinting, site visits, and an hours-policy review.
The oversight
What LDH requires in the daily log
Louisiana has no recoupment headline yet, and that is the point: the state announced its tightening before the enforcement wave, which is the window to get documentation right. The manual's section 4.4 enumerates the daily log, and the per-code table adds requirements per CPT code, repeating one sentence for nearly every code: data collection is insufficient for a medical record.
- Names of session attendees; start and stop times for each session; a narrative of the programs run, each attendee's responses, and barriers to progress; the correct billing code; the renderer's name, signature, and credentials, signed and dated per day and session; all legible and individualized.
- Start and stop times are recorded at session start, after any break of 12 or more minutes, and on any billing-code switch, so every segment accounts for its own time.
- Data collection alone is insufficient for a medical record. A registered line technician (RLT) may document with recorded data; every other renderer writes the narrative.
- The specific intervention used, the response, progress made or not made, future plans, and documentation of parent involvement.
- 97156 and 97157 document parent participation and the parent's understanding of the targets and interventions.
- Two hours of supervision for every ten hours of therapy, or one for every five.
The checklist
What a Louisiana ABA note has to show
Each item below names its source and the Penguin rule that checks it. Louisiana sets no note-completion deadline, so none is claimed.
| The note shows | What that means in practice | Source | Rule |
|---|---|---|---|
| The session attendees, named | Who was in the session, by name. | §4.4 | LA-1 |
| Per-segment start and stop times matching the billing | New times after any 12-minute break or code switch, agreeing with the claim. | §4.4 | LA-2 |
| A narrative of programs, responses, and barriers | What ran, how each attendee responded, and what stood in the way. RLT-rendered sessions may stand on recorded data. | §4.4 | LA-3 |
| The billing code, documented and matching the claim | The note states which code the time was billed under. | §4.4 | LA-4 |
| The renderer's name, signature, and credentials, dated | Per day and distinct session. | §4.4 | LA-5 |
| A narrative accompanying the data | Data collection alone is not a medical record, except for RLT-rendered services. | per-code table | LA-6 |
| The 97153 elements | Intervention, response, progress, future plans, and parent involvement. | per-code table | LA-7 |
| Parent participation and understanding on 97156/97157 | What the parent did and what they took away. | per-code table | LA-8 |
Two supervision hours per ten therapy hours, or one per five.
Records kept six years under the manual, with session time and presence records kept seven under the per-code table.
Louisiana requires signing and dating per day and session but sets no completion deadline, so none is claimed or checked.
In the rules library
Eight Louisiana rules, ready to turn on
Open the rules library in the Penguin Health app, choose Louisiana 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 Louisiana Medicaid payers. Penguin checks the CentralReach payer name, so a Louisiana rule never fires on a commercial note in the same organization, 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.
Eight rules for LDH ABA: the daily log, per-segment times with the 12-minute break rule, narratives over bare data, and the per-code 97153 and parent-training elements.
- reviewed
- Oct 20, 2026
- runs on
- Notes billed to Louisiana Medicaid payers
- sources
- LDH ABA Provider Manual ch. 4 §4.4 · LDH per-code documentation table
- watching
- Both LDH documents
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 matches the longest retention the per-code table requires. Billing Medicaid in more than one state? The rules library covers sixteen, including Texas and Georgia.
Maintained by Penguin
We watch LDH so the rules never go stale
Louisiana announced its oversight tightening before the enforcement wave. The Louisiana set is tied to the LDH documents, not to a template written once.
The ABA manual chapter and the per-code table. Penguin fetches the sources on a schedule and archives every revision.
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.
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.
- The per-code table takes effect
Per-code documentation requirements, with the data-collection sentence repeated across the code set.
- The manual's current chapter 4 revision
Section 4.4's daily log, the 12-minute break rule, and the RLT exception.
- LDH announces tighter oversight
High-risk screening with fingerprinting and site visits, and a review of authorized-hours policy, after 41% spending growth.
LibraryLA-1 through LA-8 live in the rules library.
- Louisiana set reviewed
Checked against the manual chapter and per-code table. Current.
- WatchingThe hours-policy review
LDH said it is reviewing authorized-hours and medical-necessity policy. When the manual changes, the set is updated and every organization using it gets the change.
Next step
Run a month of Louisiana notes through Penguin
Bring one month of 97153 and 97155 notes. We add the Louisiana 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.