Due Diligence: Provider Documentation Essentials for Being Audit Ready

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The new Category I Current Procedural Terminology (CPT) codes introduced in January of 2019 require providers to make significant changes when rendering billable applied behavior analysis (ABA) therapy services. The TRICARE military benefit allows for some of these new codes to be billed in their Autism Care Demonstration program. Providers must bring their rendering of services and documentation processes into alignment with the new Category I CPT code content. Distinct changes in the landscape of ABA services both in practice and in notation must occur to ensure the fidelity of code implementation. Not only does this enable providers to meet their contractual obligations, but also allows them to be prepared for audits. Sarah Schmidtz, President of Comprehensive Billing Consultants, and Rebecca Womack, Executive Director of the Behavior Analysis Advocacy Network (BAAN) will discuss ways to deliver and document services reflected in the Category I CPT codes. Providers will be educated about general auditing processes and how to be audit ready. All clinical recommendations will be aligned with the Behavior Analyst Certification Board (BACB) Professional and Ethical Compliance Code standards.

All participants will receive:

  • 2 Learning BACB® CEUs (1 of which is a Learning BACB® CEUs that counts towards ethics requirement)
  • Education about the Category I CPT codes approved for rendering in the ACD program
  • Strategies for rendering and documenting services associated with these codes
  • Information about general auditing processes
  • Recommendations on how to be audit ready


Sarah Schmidtz

Sarah Schmitz, CMRS-I, CPB, CPC, discovered her love for medical billing and coding over 15 years ago. She completed training at the top of her class and received Magna Cum Laude from the American Academy of Professional Coders. After her son was diagnosed with autism, she had to stop working full time to put all her energy into learning the most she could about the available therapies for autism. When a provider said they would no longer be taking her insurance, Sarah recognized the need for an advocate for ABA providers who had much heart and education but a gap in knowledge of the ins and outs of medical insurance. Putting her passion for billing and coding into practice, she founded Comprehensive Billing Consultants, a nationally recognized autism services billing, consulting, and credentialing company. Sarah has also created an ABA Billing Bootcamp and multiple onsite consulting opportunities for providers who are trying to ensure that they have the strongest team possible. Because Sarah and many members of her team have family members on the autism spectrum, the culture of Comprehensive Billing Consultants is providing the best support and service to ABA providers, knowing that THEY are providing the opportunity for children to grow and evolve in such a beautiful way. Sarah is coauthor of Revenue Cycle Management for ABA Therapy.

Rebecca Womack

Since graduating from her master’s program at North Dakota State University, Rebecca has been privileged to serve adults and children using applied behavior analysis (ABA) in a variety of capacities. From facility-based care, to working group homes, day centers, schools, and homes of families, her experience includes implementing evidence-based therapy across multiple settings. She has traveled across the United States and overseas to provide consultation for families with children who have autism. Additional experiences include administrative work, presentations, oversight of center and home-based services, staff and parent training, and supervision. As the Executive Director for the Behavior Analysis Advocacy Network (BAAN), she works closely with policy makes to preserve services and the continuity of care for children with autism. In addition to facilitating provider and family concerns, she also disseminates information on clinical and ethical practices relating to funding source requirements. Whatever the role, her ultimate goal is to always make a significant impact through effective and efficient services utilizing the science of behavior analysis.

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