Penguin Health
South Carolina · Healthy Connections · ASD services
South Carolina rewrote its ASD manual three times in ten months
SCDHHS revised its Autism Spectrum Disorder Services manual in September 2025, May 2026, and again effective July 1, 2026, with each pass strengthening documentation. The current edition enumerates the Clinical Service Note, requires signatures from both the rendering RBT and the enrolled BCBA, and says in plain text that post-payment review will verify how 97155 was used. The matching rule set lives in the rules library in the Penguin Health app.
The third revision in ten months, announced by Medicaid Bulletin MB 26-015.
From member ID to treatment planned, each CSN capturing service and bill time.
The rendering BT/RBT and the enrolled BCBA, BCaBA, or LIP both sign.
With post-payment review verifying 97155 was not used for supervision.
The manual
What the July 2026 edition requires around the note
Each discrete service gets its own Clinical Service Note capturing service and bill time, documented "in accordance with ABA standards and guidelines," with content that justifies the level of service billed. The manual pairs that with an explicit enforcement posture: documentation failures "will result in termination from the Medicaid program and possible recoupment of payments," and post-payment review verifies that 97155 units were not used for BACB supervision or asynchronous telehealth.
- Member name and Medicaid or organizational ID; date of service; name of the service; place of service; duration with start and end times; a narrative justification of medical necessity; treatment performed; observation of any status changes; treatment planned; and signatures by the enrolled BCBA, BCaBA, or LIP and the rendering BT/RBT.
- The specific IPOC objective the session focused on, the structured activities, the specific interventions, the member's response, progress or lack of progress, and future plans.
- A detailed narrative of the BCBA's member-directed involvement and the resulting protocol modification, or an explanation of why no modification resulted. Supervision written up as 97155 is the pattern the review targets.
- Unstructured time including breaks, naps, and meals; documentation of service notes; recreational activities or their supervision; and educational services.
- "All documentation must support the number of units billed."
- Completed no later than the tenth business day after the assessment; signed, titled, and dated by the team including the caregiver.
The checklist
What a South Carolina CSN has to show
Each item below names its manual section and the Penguin rule that checks it. South Carolina sets no note-completion deadline, so none is claimed.
| The note shows | What that means in practice | Source | Rule |
|---|---|---|---|
| Member name and Medicaid or organizational ID | Identity on the note itself, with an ID, not initials alone. | CSN elements | SC-1 |
| Date, service name, place, and start/end times matching the billing | When, what, and where, agreeing with the claim. | CSN elements | SC-2 |
| A medical-necessity narrative | Why this service was necessary for this member, in narrative form. | CSN elements | SC-3 |
| Treatment performed, observations, and treatment planned | The clinical trio: what happened, what changed, what comes next. | CSN elements | SC-4 |
| Dual signatures | The rendering BT/RBT and the enrolled BCBA, BCaBA, or LIP both sign. The strictest signature rule of any state we cover. | CSN elements | SC-5 |
| An IPOC objective with interventions, response, and progress | Treatment notes tie the session to a plan goal and show the work and the result. | treatment documentation | SC-6 |
| The 97155 modification narrative | Member-directed involvement and the protocol modification, or why none resulted. Supervision-only fails. | 97155; review notice | SC-7 |
| No non-billable time | Breaks, naps, meals, documentation time, recreation, and academics stay outside the billed window. | non-covered list | SC-8 |
| Units supported by the documentation | The billed unit count against the documented duration. | CSN section | SC-9 |
| Individualized group notes, 97158 groups of two to six | A group note per participant, not one note copied across the group. | group definitions | SC-10 |
Authorization requests must show an in-person to telehealth delivery ratio of no more than 3:1.
Each RBT is supervised for at least 5% of ABA hours per month, with two face-to-face contacts.
South Carolina enumerates content, not timing: no note-completion deadline exists, so none is claimed or checked.
In the rules library
Ten South Carolina rules, ready to turn on
Open the rules library in the Penguin Health app, choose South Carolina ASD Services, 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 South Carolina Medicaid payers. Penguin checks the CentralReach payer name, so a South Carolina 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.
Ten rules for SCDHHS ASD services: the CSN elements, dual signatures, the 97155 narrative, non-billable time, units support, and group documentation.
- reviewed
- Oct 20, 2026
- runs on
- Notes billed to South Carolina Medicaid payers
- sources
- SCDHHS ASD Services Provider Manual, effective Jul 1, 2026
- watching
- The manual landing page, where each new edition appears
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 post-payment reviewer. Billing Medicaid in more than one state? The rules library covers sixteen, including North Carolina and Georgia.
Maintained by Penguin
We watch SCDHHS so the rules never go stale
A manual that changed three times in ten months is exactly the kind of document that outruns a template written once. The South Carolina set is tied to the manual and its landing page.
The ASD manual PDF and its landing page, where each new edition appears. Penguin fetches the sources on a schedule and archives every revision.
We rewrite the affected rule, cite the edition 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.
- A new ASD manual edition
The first of three revisions in ten months.
- A second edition
Followed six weeks later by the current one.
- The current manual takes effect
Strengthened plan-of-care and documentation requirements, updated telehealth guidance, and the post-payment review notice, announced by Medicaid Bulletin MB 26-015.
LibrarySC-1 through SC-10 are built against this edition.
- South Carolina set reviewed
Checked against the July 1, 2026 manual. Current.
- WatchingThe next edition
At the current pace, another revision is a matter of months. When it lands, the set is updated and every organization using it gets the change.
Next step
Run a month of South Carolina notes through Penguin
Bring one month of 97153 and 97155 notes. We add the South Carolina 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.