When Penguin flags a note, the finding points at a page in the state's manual, not a model's opinion. This page is the library itself: every state rule we run, under the same ID and name you see in the product, with the documents each pack is built on and the date we last verified it against them.
Ten added in October 2026 alone, from Florida to Minnesota.
State-specific rules153
On top of the production ABA set every organization starts with.
Source documents35
Manuals, bulletins, and policy pages, each one linked below.
Newest audit protocolJun 29, 2026
New York OMIG's dedicated ABA protocol, with a lookback to August 2021.
How it is built
Primary sources, read in full, watched for changes
Read in full
Each pack starts with the state's own documents: the manual, the bulletins, the policy clarifications. We read the originals, not summaries of them.
Cited rule by rule
Every rule carries its source and a verified date. When a reviewer asks why a note was flagged, the answer is a page in the state's manual.
Watched for revisions
States revise these documents on their own schedule. Georgia rewrote its note standard on October 1, 2026; North Carolina rewrote Policy 8F on August 1. We watch every cited document and re-verify the pack when one changes.
The packs
Sixteen states, 153 rules
Open a pack to see every rule in it. Fifteen packs sit in the rules library inside the product, where an org admin adds one with a single click; the Colorado pack is loaded during pilot setup. Each state's guide page walks through its rules in depth.
State rule pack. Click a state for its pack. Production ABA set, which runs everywhere.
Colorado
Colorado ABA · 12 rules · verified
Loaded during pilot setup
Twelve rules for Health First Colorado pediatric behavioral therapy, each with QA guidance by program code. Reads the note the way the OIG and a state postpayment reviewer read it: substance over headings.
Eleven rules for AHCA behavior analysis services, applied to notes billed to Florida Medicaid and its SMMC plans. The section 6.2.4 session-note elements, parent participation, unit rounding, group size, and the telehealth limit.
Date, time, location, and duration match the billing
FL-3
Maladaptive behaviors observed are documented
FL-4
Replacement or compensatory skills targeted are documented
FL-5
The recipient's response to the interventions is described
FL-6
97155 and 97158 document the protocol modification
FL-7
Participants present are listed
FL-8
Parent or guardian absence is explained
FL-9
Billed units are corroborated by the documented duration
FL-10
Group treatment has at most 6 participants
FL-11
Direct treatment is not delivered via telehealth
Georgia
Georgia Medicaid ABA · 9 rules · verified
In the rules library
Nine rules for the DCH ASD services manual, applied to notes billed to Georgia Medicaid and its Georgia Families plans. The October 2026 note standard (one-business-day deadline, required elements, goals with data, 97155 and 97156 content) plus group size and daily unit limits.
Specific goals with objective data, no vague summaries
GA-4
Individuals present and caregiver participation recorded
GA-5
97155 documents protocol modification with the member present
GA-6
97156 documents the caregiver training elements
GA-7
97154 groups have 2 to 8 participants
GA-8
0373T has the analyst on site; school 97156 has a parent present
GA-9
Units on the line are within the daily limit
Indiana
Indiana Medicaid ABA · 8 rules · verified
In the rules library
Eight rules for IHCP ABA, applied to notes billed to Indiana Medicaid managed care. Note elements, 97155 and 97156 content, the 2026 nap and telehealth bulletins, and the failure patterns from the federal audit of Indiana.
Participants listed, or the parent's absence explained
IN-3
97155 documents a protocol change with the technician directed
IN-4
97156 gives caregivers guidance to implement protocols
IN-5
Nap time is documented and deducted, and the child is not kept awake
IN-6
No recreational, academic, or group content billed as ABA
IN-7
Signed at or after the billed end time
IN-8
Telehealth only on 97155 and 97156
Louisiana
Louisiana Medicaid ABA · 8 rules · verified
In the rules library
Eight rules for LDH ABA services, applied to notes billed to Louisiana Medicaid. The daily documentation log, per-segment times with the 12-minute break rule, narratives over bare data, and the per-code 97153 and parent-training elements.
Eight rules for the new MaineCare Section 28 (April 29, 2026), applied to notes billed to MaineCare. The progress-note elements including family participation and staff ratio, the night-hours window, non-covered content, and units support.
Name, signature, and credentials of the delivering staff
ME-2
Date, time, location, and staff-to-member ratio match the billing
ME-3
The family-participation block is documented
ME-4
The treatment interventions provided
ME-5
The member's response, with progress and barriers against the ITP goals
ME-6
No services billed between 8:00 p.m. and 6:00 a.m. without justification
ME-7
No primarily academic, recreational, or custodial content, and no continuous non-therapy time
ME-8
Billed units supported by the note's documented time
Massachusetts
MassHealth ABA · 6 rules · verified
In the rules library
Six rules for MassHealth ABA under the MBHP/Carelon medical necessity criteria, applied to notes billed to MassHealth plans. The daily-note summary elements, non-therapeutic time, the school-setting exclusion, and barrier mitigation.
The note accounts for how treatment time was utilized
MA-3
The member's response to treatment is documented
MA-4
No unjustified non-therapeutic time in the billed window
MA-5
Services are not delivered in a school setting
MA-6
Lack of progress is met with documented barrier mitigation
Minnesota
Minnesota EIDBI · 9 rules · verified
In the rules library
Nine rules for Minnesota EIDBI, applied to notes billed to Minnesota Medical Assistance. The case-note elements including the documentation-added date, session times, the September 2026 observation-and-direction content, and session integrity.
The person's name and the type of service are on the case note
MN-2
Name, title or level, and signature of the delivering provider
MN-3
The date of service and the date the documentation was added
MN-4
Session start and stop times match the billing
MN-5
A summary of the person's progress or response, with any treatment or diagnosis changes
MN-6
O&D notes state the program observed, the assessment, and the direction given
MN-7
O&D protocol modifications carry a data-informed rationale
MN-8
No passive-observation-only O&D
MN-9
No non-ITP routine time inside the billed session
Missouri
Missouri Medicaid ABA · 8 rules · verified
In the rules library
Eight rules for MO HealthNet ABA, applied to notes billed to Missouri Medicaid. The five-business-day deadline, the section 1.3 note elements, exact per-service times, non-therapy time, unit thresholds, and supervisor signatures.
Documented within five business days of the service
MO-2
The manual section 1.3 note elements are present
MO-3
Exact start and stop times per service, matching the billing
MO-4
Non-therapy time is excluded from the billed window
MO-5
Billed units supported under the 8-minute unit threshold
MO-6
BT/RBT notes carry the licensed supervisor's review signature
MO-7
Clinical content ties the session to the diagnosis and plan goals
MO-8
Concurrent 97155 is documented as its own service
New York
New York Medicaid ABA · 8 rules · verified
In the rules library
Eight rules for New York Medicaid ABA, built against the OMIG audit protocol of June 2026 and the eMedNY policy manual. The four criterion-3 documentation elements, units support, goals with data, the school-setting exclusion, and 97155 direction.
Identifying patient information is on the documentation
NY-2
The service rendering provider is identified
NY-3
The services provided are documented
NY-4
The location of service is documented and matches the billing
NY-5
Billed units do not exceed what the note supports
NY-6
Goals and associated data to determine progress
NY-7
No ABA billed in a school setting
NY-8
97155 documents the analyst's in-session direction of the technician
North Carolina
North Carolina Medicaid ABA · 11 rules · verified
In the rules library
Eleven rules for Clinical Coverage Policy 8F as rewritten August 1, 2026, applied to notes billed to the NC Medicaid Tailored Plans. The service-note element list, the seven-business-day cutoff, telehealth place of service, and who may render each code.
Purpose, interventions, effectiveness, and times are documented
NC-3
Caregivers present and a credentialed signature are recorded
NC-4
97155 states whether the plan or protocol was modified
NC-5
97156 and 97157 document the guidance and who attended
NC-6
Every page carries the beneficiary name, ID, and record number
NC-7
Documented within seven business days of the service
NC-8
Telehealth is billed with the usual place of service, not 02 or 10
NC-9
97152, 97153, and 97154 are delivered in person
NC-10
No non-billable time inside the billed window
NC-11
The signer holds a credential allowed for the code
Pennsylvania
Pennsylvania IBHS ABA · 7 rules · verified
In the rules library
Seven rules for IBHS-delivered ABA under 55 Pa. Code Chapter 5240, applied to notes billed to Pennsylvania Medicaid HealthChoices plans. The per-service documentation elements, ITP goal linkage, signatures, and the manual-restraint record.
Date, time, duration, and setting match the billing
PA-2
The service is tied to a goal in the ITP
PA-3
The outcome of the service is described
PA-4
Signed by the staff person who provided the service
PA-5
The entry is signed and dated by its writer
PA-6
A manual restraint carries its full record
PA-7
The documented setting is consistent with the billed place of service
South Carolina
South Carolina ASD Services · 10 rules · verified
In the rules library
Ten rules for SCDHHS autism spectrum disorder services, applied to notes billed to South Carolina Medicaid. The clinical service note elements, dual signatures, the 97155 modification narrative, non-billable time, units support, and group documentation.
The member's name and Medicaid or organizational ID are on the note
SC-2
Date, service name, place, and start/end times match the billing
SC-3
A narrative justification of medical necessity
SC-4
Treatment performed, observations, and treatment planned
SC-5
Dual signatures: the rendering BT/RBT and the enrolled supervisor
SC-6
Treatment notes tie the session to an IPOC objective with interventions, response, and progress
SC-7
97155 narrates member-directed involvement and the protocol modification
SC-8
No non-billable time inside the billed window
SC-9
Billed units supported by the documentation
SC-10
Group notes are individualized, with 97158 groups of two to six
Texas
Texas Medicaid ABA · 10 rules · verified
In the rules library
Ten rules for THSteps-CCP autism services, applied to notes billed to Texas Medicaid. The handbook's per-code treatment-note elements, session data, signatures with credentials, direct-time-only billing, and team-meeting documentation.
The child's name and date of service are on the note
TX-2
Start and stop times match the billed times
TX-3
Treatment plan goals addressed and progress noted
TX-4
Session summary covers the interventions and time allotted
TX-5
Direct observation data is recorded for the session
TX-6
Every entry has a full signature with credentials
TX-7
Protocol-code notes document the modification and progress assessment
TX-8
Caregiver-training notes carry the required elements
TX-9
Only direct service time is inside the billed window
TX-10
Team-meeting notes carry the seven required elements
Virginia
Virginia Medicaid ABA · 11 rules · verified
In the rules library
Eleven rules for DMAS Cardinal Care ABA, applied to notes billed to Virginia Medicaid MCOs. Note elements, the one-business-day signature deadline, non-billable time, and code-specific requirements for groups, family training, 97155, school settings, and team codes.
Start and end times are documented and match the billing
VA-2
Required progress-note elements are present
VA-3
Signed within one business day of the service
VA-4
Activities, response, and progress on each objective
VA-5
No non-billable time inside the billed window
VA-6
Group notes state the number of participants, at most 8
VA-7
97154 documents licensed behavior analyst oversight on site
VA-8
No 97153 and 97154 billed in a school setting
VA-9
97156 has the child present or a clinical reason, and targets the child's goals
VA-10
97155 is tied to the child, not staff-only supervision
VA-11
0362T and 0373T document the full team and are in person
Wisconsin
Wisconsin ABA · 17 rules · verified
In the rules library
Seventeen rules for ForwardHealth behavioral treatment, each with QA guidance by program code. Per-code required elements, the 48-hour documentation deadline, and the supervisor visit and direction cadences the handbook sets.
97155 documents a resolved issue or protocol change
WI-3
Note signed within 48 hours of the date of service
WI-4
Note signed no earlier than 8 minutes before session end
WI-5
Billed units match the documented session time
WI-6
No concurrent 97153 and 97155 for the same minutes
WI-7
Rendering provider on the claim matches the note
WI-8
Recreation and daily-living activities carry goals and techniques
WI-9
Billed time excludes travel, breaks, and documentation time
WI-10
Narrative is individualized to the session
WI-11
Service limits by code
WI-12
Supervisor visit: one hour every 60 to 75 days
WI-13
Face-to-face direction: 1 to 2 hours per 10 hours of treatment
WI-14
Professional supervision: weekly and monthly contact documented
WI-15
Place of service matches the documented setting
WI-16
Group treatment size and composition
WI-17
Electronic signature is controlled by the renderer
Two notes on how the packs run. Each state pack applies only to notes whose CentralReach payer name carries that state's Medicaid label, so a commercial note is never held to a Medicaid manual. And business-day deadlines are approximated with calendar days: a one-business-day rule flags after four calendar days, a seven-business-day rule after twelve, so a flagged note is late under any reading.
Want these rules running on your notes?
Penguin reviews every RBT and BCBA session note after it is signed and before the claim goes out, read-only inside your CentralReach account. Findings land with your QA team, assigned and ready to work.