Penguin Health
Texas · THSteps-CCP · Autism services
Texas enumerates the ABA treatment note, code by code
Texas Medicaid added the ABA benefit in February 2022 and now carries the second-largest RBT workforce in the country. The policy lives in the TMPPM Children's Services Handbook, Section 2.3, and it is unusually concrete: treatment-note elements listed per CPT code, down to direct observation data the LBA can graph across time. There is no state audit program for ABA yet; CMS is pressing states to build one. The matching rule set lives in the rules library in the Penguin Health app.
Second only to Florida, per BACB certificant data, on a benefit live since February 2022.
The TMPPM is reissued monthly; Penguin watches each edition.
§2.3.7.13: one list for 97153/97154, additions for 97155/97158, a separate list for 97156.
Child and caregiver attendance gates recertification, §2.3.7.5.
The handbook
What Section 2.3 requires around the note
The Children's Services Handbook governs autism services for THSteps-CCP members 20 and younger, in fee-for-service and managed care alike. Its documentation chapter (§2.3.7) runs from authorization paperwork to the treatment note itself. Two things stand out against other states: the note elements are listed per CPT code, and session data is a required note element, recorded every session so the LBA can graph it. One thing is absent: Texas sets no note-completion deadline, so no deadline rule is claimed here.
- For 97153 and 97154: the child's name, date of service, start and stop time of each session, treatment plan goals addressed with progress, a summary of the interventions delivered with the time allotted, direct observation data, and a full signature with credentials on every entry.
- 97155 and 97158 add protocol-modification decision points, a progress assessment, and plan updates. 97156 has its own caregiver-training list.
- Reimbursement is for direct service time. Treatment planning, note writing, report writing, and chart updates are not separately reimbursable outside the assessment code.
- Attendance logs track scheduled versus completed sessions for the child and the caregiver separately, and recertification at the previous intensity expects 85% attendance from each.
- Submitted after the first 90 days of treatment, in the format of a treatment note, billed as 97155, signed and dated by the LBA and by the parent or caregiver.
- 99366 notes carry seven elements: start and stop times (minimum 30 minutes), the latest evaluation date, attendees with disciplines and affiliations, a narrative, decisions, action items, and a signed date.
- More than 20 hours per week is supportable when documentation shows two of: age 6 or younger, severity level 2 or 3, severely impairing elopement, aggression, or self-injury goals, or the first two years of ABA.
The checklist
What a Texas treatment note has to show
Each item below names its handbook section and the Penguin rule that checks it. The handbook is monthly; this page cites the October 2026 edition of the Children's Services Handbook, Section 2.3.
| The note shows | What that means in practice | Source | Rule |
|---|---|---|---|
| The child's name and a date of service matching the claim | Identity on the note itself, with the date agreeing with the billed date. | §2.3.7.13 | TX-1 |
| Start and stop times matching the billed times | Each session's start and stop, to the minute, against the claim. | §2.3.7.13 | TX-2 |
| Treatment plan goals addressed, with progress | The plan goals the session worked, and progress on them, not activity in the abstract. | §2.3.7.13 | TX-3 |
| A summary of interventions and the time allotted | What was delivered and how the session time was spent. | §2.3.7.13 | TX-4 |
| Direct observation data for the session | Recorded data the LBA can graph across time. A narrative with no data is a gap. | §2.3.7.13 | TX-5 |
| A full signature with credentials on every entry | Full signature plus credentials, with supervisory signatures per licensure standards. Initials are a gap. | §2.3.7.13 | TX-6 |
| Modification decision points on the protocol codes | For 97155 and 97158: the decision points, a progress assessment, and plan updates. Direct treatment written up under a protocol code is a finding. | §2.3.7.13 | TX-7 |
| The caregiver-training elements on 97156 | Name, date, times, goals addressed, a summary of the training, and a signed credential. | §2.3.7.13 | TX-8 |
| Only direct service time inside the billed window | Documentation, report writing, and chart updates are not billable outside the assessment code. | §2.3; 1 TAC ch. 354 | TX-9 |
| Seven elements on team-meeting notes | 99366 notes carry the meeting times, latest evaluation date, attendees, narrative, decisions, action items, and a signed date. | §2.3.7.11 | TX-10 |
For all ABA claims, including services delivered by LaBAs and behavior technicians under supervision, the enrolled LBA is the Medicaid rendering provider (1 TAC §354.5011).
The ASD diagnosis documentation must be current within three years of the ABA request, with a second diagnostic tool.
Texas sets no note-completion deadline. Notes are kept on file subject to retrospective review, so no deadline rule is claimed or checked.
In the rules library
Ten Texas rules, ready to turn on
Open the rules library in the Penguin Health app, choose Texas 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 Texas Medicaid payers. Penguin checks the CentralReach payer name, so a Texas 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 THSteps-CCP autism services: the per-code treatment-note elements, session data, signatures with credentials, direct-time-only billing, and team-meeting documentation.
- reviewed
- Oct 19, 2026
- runs on
- Notes billed to Texas Medicaid payers
- sources
- TMPPM Children's Services Handbook §2.3, Oct 2026 · 1 TAC ch. 354 subch. P
- watching
- Each monthly TMPPM edition
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. Billing Medicaid in more than one state? The rules library covers sixteen, including Louisiana and Colorado.
Maintained by Penguin
We watch the TMPPM so the rules never go stale
The TMPPM is reissued every month under a new URL, which is exactly how a documentation change slips past a busy practice. The Texas set is tied to the handbook, not to a template written once.
The TMPPM provider manuals page, where each monthly edition lands. 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.
- Texas Medicaid adds the ABA benefit
Autism services for THSteps-CCP members 20 and younger, with the LBA as the enrolled rendering provider.
- CMS publishes its ABA oversight toolkit
National Medicaid ABA spending grew 421% from 2021 to 2025, and CMS urges states to tighten documentation review. Texas has no ABA audit program yet; the toolkit is the template for the one it will build.
- Texas set reviewed
Checked against the October 2026 Children's Services Handbook and 1 TAC chapter 354. Current.
LibraryTX-1 through TX-10 live in the rules library.
- WatchingEvery monthly edition
The handbook URL changes each month, so Penguin watches the TMPPM landing page and archives each edition. When Section 2.3 changes, the set is updated and every organization using it gets the change.
Next step
Run a month of Texas notes through Penguin
Bring one month of 97153 and 97155 notes. We add the Texas set from the rules library, run it, show every finding beside the handbook 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.