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North Carolina · NC Medicaid Tailored Plans · Research-based behavioral health treatment

Policy 8F changed on August 1, 2026. Telehealth billed as 02 or 10 is now wrong in North Carolina.

North Carolina calls ABA research-based behavioral health treatment, and it rewrote Clinical Coverage Policy 8F effective August 1, 2026, with a reminder bulletin on August 31 that replaces the July 21 and August 5 versions. Section 5.5.1 lists what every service note contains, and the state's Records Management and Documentation Manual makes a note documented more than seven business days after the service unbillable. Trillium says all RB-BHT services are subject to post-payment review. The matching rule set lives in the rules library in the Penguin Health app, and we update it when NC Medicaid changes the policy.

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In the rules libraryNorth Carolina Medicaid ABA · eleven rules · maintained by Penguin · reviewed Oct 12, 2026

Policy 8F, fully rewritten, effectiveAug 1, 2026

With the August 31, 2026 reminder bulletin replacing the July 21 and August 5 versions.

Documented late, then not billable7 business days

Records Management and Documentation Manual, July 2025. Late entries are labeled and signed with the date.

Telehealth place of serviceNot 02 or 10

The place of service the session would have had in person, plus GT (KX for audio-only). 8F Attachment A.

Supervisor countersignatureNot required

8F §5.5. Many providers assume it is.

The August 1 rewrite

What changed, and what the national telehealth convention gets wrong here

North Carolina calls ABA research-based behavioral health treatment, RB-BHT. Clinical Coverage Policy 8F was rewritten end to end effective August 1, 2026, and the August 31, 2026 bulletin replaces the August 5 and July 21 versions of the state's reminder. The telehealth change is the one that catches multi-state providers: the place-of-service codes most payers use for telehealth are the ones North Carolina does not.

Telehealth place of service8F Attachment A

The place of service the session would have had in person, with modifier GT. KX for audio-only.
Place of service 02 and 10 are not used. A 97155 billed as 10 because the child was at home is billed wrong in North Carolina.

NC-8 fails a claim billed with place of service 02 or 10. Penguin does not check the GT or KX modifier.

Codes that are never telehealth8F Attachment A

97152, 97153, and 97154 are delivered in person.
97155 by telehealth is capped at 50% per 180 days. A requirement on the practice; Penguin does not track the share.

NC-9 fails when the note shows remote delivery for 97152, 97153, or 97154.

Who may render what8F Attachments A and B

97156 and 97157: only a licensed behavior analyst, physician, or psychologist.
Technicians do not render 97155 through 97157. An assistant behavior analyst may render 97155 but not 97156 or 97157.

NC-11 reads the credential written beside the signature on the note. It does not check a roster or the licensing board.

The service note8F §5.5.1

Fifteen listed elements, from beneficiary name and Medicaid ID to a dated signature with credentials or job title.
Every page carries the beneficiary name, Medicaid ID, and record number (§5.5.1(o)).
No supervisor countersignature is required. Many providers assume it is.

Not billable8F §4.2.1 · Attachment A

Naps, meals and breaks, transportation, academic teaching, staff-only meetings, and incidental supervision.

NC-10 reads the note for these inside the billed window.

Requirements on the practiceNot on the note

Technician certification. RBT or QABA ABAT within 120 days of hire, with existing staff on the same 120-day clock from August 1, 2026.
97155 concurrency. Only with 97153 or 97154, and never by the same rendering provider.
Supervision. A licensed supervisor observes at least 10% of technician services, with a 10 to 20% band above 200 technician hours in 180 days.

Penguin does not check certification clocks, concurrent sessions across notes, or supervision shares for North Carolina.

The checklist

Eleven things a North Carolina note has to show

8F §5.5.1 lists the service-note elements: beneficiary name, Medicaid ID, date of service, service name, type of contact, and place of service; the purpose tied to treatment-plan goals; a description of interventions supporting the full duration billed; effectiveness and progress with data; time in and time out; caregivers present; and a signature, date, and credentials for professionals or job title for technicians. Every page carries the beneficiary name, Medicaid ID, and record number. The RMDM adds the deadline: a note documented more than seven business days after the service is not billable.

Here is that requirement as a licensed behavior analyst's 97155 note that states the protocol modification made, each element tied to its subsection. The beneficiary, staff, and data are fictional.

Service note · page 1 of 197155 · Adaptive behavior treatment with protocol modification

Beneficiary: R. K. (full name on file) · Medicaid ID TEST-00088 · Record no. TEST-R-14 1
Date of service: 10/05/2026 2
Service: Adaptive behavior treatment with protocol modification (97155) 2
Type of contact: In person, face to face 2
Place of service: 11 Office, Raleigh, NC 2
Time in and out: 1:00 pm to 2:00 pm · 4 units 6
Caregivers present: Mother, for the last 15 minutes 7
Rendering: Dana Whitfield, M.S., LBA

Purpose 3

Treatment plan goal 3 (requesting help) stalled at 40% independent for three weeks under the technician's protocol. Session held to resolve the prompt fading step and direct the technician.

Interventions, for the full hour 4

1:00 to 1:20. Ran the requesting-help protocol with R. directly: 10 trials, errorless with a model prompt, 7 of 10 correct.
1:20 to 1:45. Changed the prompt-fading step from a full model to a partial verbal model and ran 10 trials with the technician delivering: 8 of 10 correct.
1:45 to 2:00. Reviewed the change with R.'s mother and modeled it twice.

Effectiveness and progress 5

R. requested help independently in 8 of 10 trials under the revised step, against 4 of 10 on 09/28 and 09/30. The protocol change is entered in the plan and the technician will run it from 10/06.

Modification made 9

Yes. Prompt-fading step for goal 3 changed from full model to partial verbal model.

Signed electronically: Dana Whitfield, M.S., LBA · 10/05/2026 2:12 pm 811

1
Three identifiers on every page
The beneficiary's name, Medicaid ID, and record number, on each page of the note, not only the first.
North Carolina 8F §5.5.1(o)
NC-6All three identifiers on each page.
2
Date, service, type of contact, place of service
The date of service, the service name, the type of contact, and the place of service, alongside the name and Medicaid ID.
North Carolina 8F §5.5.1(a) to (f)
NC-1The identifying and contact elements, each with real content.
3
The purpose, tied to treatment-plan goals
Why this session happened, named against a goal in the treatment plan.
North Carolina 8F §5.5.1(g)
4
Interventions supporting the full duration billed
What was done, across all the minutes billed. An hour billed with twenty minutes described is a finding.
North Carolina 8F §5.5.1(h)
5
Effectiveness and progress, with data
How the beneficiary responded, with the data that shows it and the comparison that shows progress.
North Carolina 8F §5.5.1(j)
NC-2Purpose, interventions for the full duration, effectiveness with data, and times.
6
Time in and time out
The minutes billed, as a time in and a time out.
North Carolina 8F §5.5.1(k)
7
Caregivers present
Who was there, or that no one was.
North Carolina 8F §5.5.1(m)
8
Signature, date, and credentials or job title
A professional signs with credentials; a technician signs with a job title. The signature is dated. No supervisor countersignature is required.
North Carolina 8F §5.5 · §5.5.1(n)
NC-3Caregivers present (or none) and a dated, credentialed signature. A missing countersignature is not a finding.
9
97155: whether the plan or protocol was modified
A statement of whether a plan-of-care or protocol modification was made, and what it was.
North Carolina 8F §5.5.1(i)
NC-4The statement, and the modification itself.
10
97156 and 97157: the guidance and who attended
The specific guidance given to caregivers, whether the beneficiary was present, and whether one or several beneficiaries were served. Not shown in this 97155 example.
North Carolina 8F §5.5.1(l)
NC-5Guidance, beneficiary presence, one or several.
11
Documented within seven business days
A note documented more than seven business days after the date of service is not billable. Late entries are labeled "late entry" with a dated signature. Penguin flags a note signed more than twelve calendar days after the session, which is late under any reading of seven business days; it does not enforce the business-day deadline exactly.
North Carolina RMDM, Late Entries
NC-7Signed more than twelve calendar days after the session fails.

Technician certification

Technicians hold RBT or QABA ABAT certification within 120 days of hire, with existing staff on the same 120-day clock from August 1, 2026.

Requirement onlyA requirement on the practice. Penguin does not track certification clocks.

97155 alongside other codes

97155 may run concurrently only with 97153 or 97154, and never by the same rendering provider.

Requirement onlyA billing requirement. Penguin does not compare sessions across notes.

Supervision

A licensed supervisor observes at least 10% of technician services, with a 10 to 20% band above 200 technician hours in 180 days.

Requirement onlyA requirement on the practice. Penguin does not track supervision shares for North Carolina.

Telehealth in North Carolina

The usual place of service, plus GT. Never for the technician codes.

8F Attachment A says a telehealth claim carries the place of service the session would have had in person, with modifier GT, or KX for audio-only. Place of service 02 and 10 are not used. 97152, 97153, and 97154 are never delivered by telehealth. 97155 by telehealth is capped at 50% per 180 days, which is a requirement on the practice rather than on any one note.

Billed the North Carolina way

97155 by video, child at home: place of service 12 (home), modifier GT.
97156 by phone, audio only: the place of service the training would have had in person, modifier KX.
97153 in the clinic, in person: place of service 11. The technician code is never remote.

Billed the way most other payers want it

97155 with place of service 02 or 10. Correct for many commercial payers. Wrong in North Carolina.
97153 or 97154 by telehealth at all.
97152 by telehealth. Assessment, like treatment by protocol, is in person.

NC-8 · Telehealth is billed with the usual place of service, not 02 or 10FAIL

applies_when: payer name contains the NC Medicaid Tailored Plan label · date of service on or after 2026-08-01
rule_text: Fail a claim line billed with place of service 02 or 10.
place_of_service: 10
rationale: Claim line place of service 10. North Carolina bills telehealth with the place of service the session would have had in person, plus GT.

What the reviewer gets: the finding, the billing team's action steps to correct the place of service, and the QA email pre-filled with the date of service and a link to the note.

Timeliness

Seven business days, then it is not billable

The NC DHHS RMDM (July 2025) sets the clock: a note documented more than seven business days after the date of service is not billable. A late entry is labeled "late entry" and carries a dated signature. Neither Alliance nor Trillium publishes note rules beyond 8F and the RMDM, and Trillium states in Provider Communication 009 that all RB-BHT services are subject to post-payment review.

Penguin approximates the business-day deadline with calendar days. It flags a note signed more than twelve calendar days after the session, which is late under any reading of seven business days, and it does not enforce the business-day deadline exactly. A note signed on day nine may or may not be inside seven business days; Penguin leaves that to your QA lead.

NC-7 · Documented within seven business days of the serviceFAIL

applies_when: payer name contains the NC Medicaid Tailored Plan label · date of service on or after 2026-08-01
rule_text: Fail when the renderer's signature date is more than twelve calendar days after the date of service.
days_after_service: 15
rationale: Date of service 09/14/2026, signed 09/29/2026. Fifteen calendar days is past seven business days under any reading.

What the reviewer gets: the finding, the action steps (label the entry "late entry" with a dated signature; do not bill it), and the QA email pre-filled with the date of service and a link to the note.

In the rules library

Eleven North Carolina rules, ready to turn on

Open the rules library in the Penguin Health app, choose North Carolina 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 NC Medicaid Tailored Plans. Penguin checks the CentralReach payer name, so a North Carolina 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 "NC Medicaid Tailored Plan"), 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.

The whole set applies to dates of service on or after August 1, 2026, when the rewritten 8F took effect. Older sessions are skipped, not failed.

Rules libraryPenguin Health app

North Carolina Medicaid ABAMaintained by Penguin

Eleven rules for NC Medicaid research-based behavioral health treatment, each with QA guidance by program code.

reviewed: Oct 12, 2026
runs on: Notes billed to NC Medicaid Tailored Plan payers · dates of service on or after Aug 1, 2026
sources: Clinical Coverage Policy 8F, eff. Aug 1, 2026 · NC Medicaid bulletin, Aug 31, 2026 · NC DHHS RMDM, Jul 2025 · Trillium Provider Communication 009
watching: The 120-day RBT or ABAT certification clock for existing staff, from Aug 1, 2026

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

North Carolina requirement	What Penguin checks on every note	North Carolina source	How
Identifying and contact elements are presentNC-1 · item 2	Beneficiary name, Medicaid ID, date, service name, type of contact, place of service.	8F §5.5.1(a) to (f)	AI
Purpose, interventions, effectiveness, and times are documentedNC-2 · items 3 to 6	Purpose tied to plan goals, interventions for the full duration, effectiveness with data, time in and out.	8F §5.5.1(g), (h), (j), (k)	AI
Caregivers present and a credentialed signature are recordedNC-3 · items 7, 8	Caregivers present (or none), and a dated signature with credentials or job title. No countersignature required.	8F §5.5; §5.5.1(m), (n)	AI
97155 states whether the plan or protocol was modifiedNC-4 · item 9	A statement of whether a modification was made, and what it was.	8F §5.5.1(i)	AI
97156 and 97157 document the guidance and who attendedNC-5 · item 10	Specific caregiver guidance, beneficiary presence, one or several beneficiaries.	8F §5.5.1(l)	AI
Every page carries the beneficiary name, ID, and record numberNC-6 · item 1	All three identifiers on each page of the note.	8F §5.5.1(o)	AI
Documented within seven business days of the serviceNC-7 · item 11	Flags a note signed more than twelve calendar days after the session, late under any reading of seven business days.	RMDM, Late Entries	Deterministic
Telehealth is billed with the usual place of service, not 02 or 10NC-8 · Telehealth	Fails a claim billed with place of service 02 or 10.	8F Attachment A	Deterministic
97152, 97153, and 97154 are delivered in personNC-9 · Telehealth	Fails when the note shows remote delivery for these codes.	8F Attachment A	AI
No non-billable time inside the billed windowNC-10 · The rewrite	Naps, meals and breaks, transport, academic teaching, staff-only meetings, incidental supervision.	8F §4.2.1; Attachment A	AI
The signer holds a credential allowed for the codeNC-11 · The rewrite	97156 and 97157 signed by a licensed behavior analyst, physician, or psychologist; no technician on 97155 to 97157. Reads the credential written on the note.	8F Attachments A and B	Both

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 Virginia and South Carolina.

Maintained by Penguin

We watch NC Medicaid so the rules never go stale

North Carolina replaced its ABA policy in one step and then issued three versions of the reminder bulletin in six weeks. The North Carolina 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

Clinical Coverage Policy 8F and its attachments, the NC Medicaid bulletin series, the NC DHHS Records Management and Documentation Manual, and Tailored Plan provider communications from Alliance and Trillium.

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.

Jul 2025
Records Management and Documentation Manual
NC DHHS sets the documentation clock: a note documented more than seven business days after the date of service is not billable, and late entries are labeled and signed with the date.
LibraryNC-7 cites the RMDM.
Jul 21, 2026
First reminder bulletin on RB-BHT service delivery
NC Medicaid previews the August 1 requirements.
Aug 1, 2026
Policy 8F, fully rewritten, takes effect
Service-note elements in §5.5.1, the telehealth place-of-service rule and in-person codes in Attachment A, who may render each code in Attachments A and B, and the non-billable list in §4.2.1.
LibraryNC-1 through NC-6 and NC-8 through NC-11 cite the rewritten policy. The whole set applies to dates of service on or after this day; older sessions are skipped.
Aug 5, 2026
Second reminder bulletin
Replaced on August 31.
Aug 31, 2026
Updated reminder bulletin
Replaces the July 21 and August 5 versions and restates the service-delivery requirements this page cites.
Oct 12, 2026
North Carolina set reviewed
Checked against 8F as effective August 1, 2026, the August 31 bulletin, the July 2025 RMDM, and Trillium Provider Communication 009. Current.
Watching
The 120-day certification clock
Existing technicians are on the same 120-day RBT or QABA ABAT clock as new hires, counted from August 1, 2026. When NC Medicaid or a Tailored Plan publishes a change, the set is updated and every organization using it gets the change.

Next step

Run a month of North Carolina notes through Penguin

Bring one month of 97153 and 97155 notes from August or later. We add the North Carolina set from the rules library, run it, show every finding beside the 8F subsection 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 North Carolina and is not legal or billing advice. Requirements change; everything here, and the North Carolina 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.

NC Medicaid Clinical Coverage Policy 8F, Research-Based Behavioral Health Treatment for Autism Spectrum Disorder, effective August 1, 2026 (§5.5.1 service-note elements, §4.2.1 non-billable time, Attachment A telehealth and rendering rules, Attachment B credentials)
NC Medicaid bulletin, updated reminder on RB-BHT service delivery requirements, August 31, 2026 (replaces the July 21 and August 5, 2026 versions)
NC DHHS Records Management and Documentation Manual, July 2025 (seven business days; late entries)
Trillium Health Resources, Provider Communication 009 (all RB-BHT services subject to post-payment review)