Penguin Health
Missouri · MO HealthNet · Applied behavior analysis
Missouri gives ABA notes five business days, and it said so twice this year
MO HealthNet published two ABA documentation Hot Tips in 2026. The March 10 Hot Tip sets the five-business-day documentation deadline and the licensed supervisor's signature on technician notes. The September 9 Hot Tip goes after times: exact start and stop per service, non-therapy time subtracted, and 8-minute unit thresholds. Behind both sits the manual's 11-element note standard that prepayment review checks. The matching rule set lives in the rules library in the Penguin Health app.
13 CSR 70-3.030(2) and the March 10, 2026 Hot Tip.
March 10 on documentation, September 9 on times and billing.
Section 1.3, the list prepayment review checks against (section 1.16).
The renderer and the licensed supervisor's review signature.
The Hot Tips
Two notices in six months is a message
When a Medicaid agency publishes the same topic twice in a year, it is telling providers what its reviewers keep finding. The September notice names the pattern directly: blanket time blocks like "8:00 AM to 4:00 PM, 32 units" with no per-service times, non-therapy time billed through, and concurrent 97155 folded into the technician's note. Missouri runs prepayment review of ABA claims against the manual's note elements, so these are not post-hoc audit risks; they decide whether claims pay at all.
- Services are documented in the health record within five business days to be timely.
- The licensed behavior analyst reviews and signs documentation for services rendered by BTs and RBTs.
- Exact start and stop times per service. Blanket blocks covering the whole day are called out by name.
- Naps, meals, routine toileting, free play, transitions, and post-session note-writing are subtracted from billed time.
- Daily minute summing, one claim line per code per day, and the 8-minute unit threshold.
- Participant name; service or procedure code; date with actual begin and end times; setting; issues addressed; symptoms or behaviors tied to the diagnosis and plan goals; interventions and response; progress toward goals; family members present and group count when applicable; provider name, signature, and date.
The checklist
What a Missouri ABA note has to show
Each item below names its source and the Penguin rule that checks it. On the deadline, Penguin flags a note signed more than ten calendar days after the session, which is late under any reading of five business days; it does not enforce the business-day deadline exactly.
| The note shows | What that means in practice | Source | Rule |
|---|---|---|---|
| Documented within five business days | Flagged when signed more than ten calendar days after the session, late under any reading. | Hot Tip 3/10/26; 13 CSR 70-3.030(2) | MO-1 |
| The eleven section 1.3 elements | Every element with real content, family and group items when applicable. | manual §1.3 | MO-2 |
| Exact per-service times matching the billing | No blanket time blocks; each service carries its own start and stop. | Hot Tip 9/9/26 | MO-3 |
| Non-therapy time excluded | Naps, meals, toileting, free play, transitions, and note-writing stay outside billed time. | Hot Tip 9/9/26 | MO-4 |
| Units supported under the 8-minute threshold | Documented minutes against billed units, with the final partial unit at 8+ minutes. | Hot Tip 9/9/26 | MO-5 |
| The supervisor's review signature on BT/RBT notes | The licensed analyst signs in addition to the renderer. | Hot Tip 3/10/26; §1.16 | MO-6 |
| Clinical content tied to the diagnosis and goals | Symptoms tied to plan goals, interventions with response, and progress. | manual §1.3 | MO-7 |
| Concurrent 97155 documented separately | The analyst's service stands as its own note with its own times. | Hot Tip 9/9/26 | MO-8 |
The NPI on the claim must be the deliverer or the licensed, enrolled supervisor for BT/RBT services.
13 CSR 70-98.030(7) enumerates the ABA treatment plan content.
MHD recommends the CASP session-note templates, noting they may need modification and do not guarantee immunity from audits.
In the rules library
Eight Missouri rules, ready to turn on
Open the rules library in the Penguin Health app, choose Missouri 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 MO HealthNet payers. Penguin checks the CentralReach payer name, so a Missouri 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 MO HealthNet ABA: the five-business-day deadline, the section 1.3 elements, exact times, non-therapy time, unit thresholds, and supervisor signatures.
- reviewed
- Oct 20, 2026
- runs on
- Notes billed to MO HealthNet payers
- sources
- MHD Hot Tips of Mar 10 and Sep 9, 2026 · Behavioral Health manual §§1.3, 1.16 · 13 CSR 70-3.030
- watching
- Both Hot Tip pages and the manual
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. Billing Medicaid in more than one state? The rules library covers sixteen, including Minnesota and Texas.
Maintained by Penguin
We watch MHD so the rules never go stale
Missouri published its documentation expectations twice in six months. The Missouri set is tied to those pages, not to a template written once.
Both MHD Hot Tip pages and the Behavioral Health Services manual. Penguin fetches the sources on a schedule and archives every revision.
We rewrite the affected rule, cite the notice 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 documentation Hot Tip
Five business days, supervisor signatures on BT/RBT notes, rendering NPI rules, and the CASP template recommendation.
- The Behavioral Health manual is updated
Section 1.3 carries the 11-element progress-note list; section 1.16 ties ABA prepayment review to it.
- The billing Hot Tip
Exact per-service times, non-therapy time subtraction, daily minute summing, 8-minute thresholds, and separate documentation of concurrent 97155.
LibraryMO-1 through MO-8 are built against these notices and the manual.
- Missouri set reviewed
Checked against both Hot Tips and the manual. Current.
- WatchingThe next notice
Two Hot Tips in six months suggests a third is coming. When it lands, the set is updated and every organization using it gets the change.
Next step
Run a month of Missouri notes through Penguin
Bring one month of 97153 and 97155 notes. We add the Missouri set from the rules library, run it, show every finding beside the notice 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.