Penguin Health
Nebraska · Heritage Health · Applied behavior analysis
Nebraska's auditor tore into ABA notes. The new service definitions answer, rule by rule.
In September 2025 the Nebraska Auditor of Public Accounts published an attestation report on ABA billing: session notes lacking detail, missing signatures, and signing times inconsistent with billed time. Effective July 1, 2026, DHHS reissued the ABA service definitions (Provider Bulletin 26-06), and the new text reads like a response: narrative substantiation, accurate start and end times, and a non-billable list that names naps, meals, and extended breaks. The matching rule set lives in the rules library in the Penguin Health app.
Notes lacking detail, missing signatures, inconsistent times.
Provider Bulletin 26-06, with a companion requirements document.
Plus extended recreational reinforcement and extended breaks.
No direct ABA billing in a school setting.
The definitions
What the July 2026 service definitions require
The service definitions and their companion requirements document, together with the progress-note regulation at 471 NAC 32-001.12A, set the note standard: each service substantiated through a narrative of activities and interventions, tied to treatment-plan goals, with the individual's response, and a list of what cannot sit inside billed time.
- The client's name, the practitioner's name and title, the date of service, the type of therapy, and an accurate start and end time.
- A narrative summary of activities and interventions substantiating the service. The auditor found notes that did not.
- The treatment-plan goals addressed, participation and any goal revision, and the individual's response to the session.
- Naps; extended recreational reinforcement; meals without active goals and treatment; extended breaks in active intervention.
- No direct ABA billing in a school setting.
- Supervision of technicians is documented in progress notes.
The checklist
What a Nebraska ABA note has to show
Each item below names its source and the Penguin rule that checks it. Nebraska sets no fixed note-completion deadline (it defers that to provider policy), so none is claimed.
| The note shows | What that means in practice | Source | Rule |
|---|---|---|---|
| Client, practitioner with title, date, and type of therapy | Who, by whom, when, and what service. | companion requirements | NE-1 |
| An accurate start and end time matching the billing | The auditor flagged times inconsistent with billed time. | service definitions | NE-2 |
| A narrative of activities and interventions | The note substantiates the service, not just that it happened. | service definitions | NE-3 |
| Treatment-plan goals addressed, with participation | The session ties to the plan. | service definitions | NE-4 |
| The individual's response to the session | How the client responded, in the note. | service definitions | NE-5 |
| No non-billable time inside the billed window | Naps, meals without active goals, and extended breaks stay outside it. | service definitions | NE-6 |
| No direct billing in a school setting | School place of service is excluded. | service definitions | NE-7 |
In the rules library
Seven Nebraska rules, ready to turn on
Open the rules library in the Penguin Health app, choose Nebraska 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 Nebraska Medicaid (Heritage Health) payers. Penguin checks the CentralReach payer name, so a Nebraska 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.
Seven rules for the July 2026 Nebraska ABA service definitions, written after the September 2025 state audit: note elements, accurate times, narratives, non-billable time including naps and meals, and the school-setting exclusion.
- reviewed
- Oct 26, 2026
- runs on
- Notes billed to Nebraska Medicaid (Heritage Health) payers
- sources
- NE DHHS ABA Service Definitions, effective Jul 1, 2026; companion requirements; 471 NAC 32-001.12A
- watching
- The service definitions and the companion requirements document
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 twenty-nine, including South Dakota and Missouri.
Maintained by Penguin
We watch the definitions so the rules never go stale
Nebraska just demonstrated how fast this text moves: an audit in September 2025, new service definitions ten months later. The Nebraska set is tied to the current definitions, not to the ones the auditor scored.
The service definitions and the companion requirements document. 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 auditor's attestation report
Session notes lacking detail, missing signatures, and signing times inconsistent with billed time.
- New service definitions take effect
Provider Bulletin 26-06: narrative substantiation, accurate times, the non-billable list, and the school exclusion.
LibraryNE-1 through NE-7 are built against this edition, not the one the auditor scored.
- Nebraska set reviewed
Checked against the July 2026 definitions and companion requirements. Current.
- WatchingThe next revision
When the definitions change again, the set is updated and every organization using it gets the change.
State alerts
Get an email when Nebraska changes its documentation rules
We fingerprint 56 official payer documents every week, Nebraska's among them. When one changes, a person verifies what changed and writes a short plain-language summary before anything is sent. A few emails a year, not a newsletter. Unsubscribe anytime.
Check your inbox: confirm your email and you are on the list.
You will get a confirmation email first. Watching more than one state? Pick your states here.
Next step
Run a month of Nebraska notes through Penguin
Bring one month of session notes. We add the Nebraska set from the rules library, run it, show every finding beside the source 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.