Telehealth and ABA Service Delivery

What is Telehealth ABA?

Telehealth ABA is the delivery of applied behavior analysis services using secure video and digital tools to provide:

  • Assessment
  • Direct intervention
  • Caregiver training
  • Clinical oversight and supervision

During the COVID-19 crisis, practicing behavior analysts had the opportunity to demonstrate that essential, medically necessary behavior analytic services can be provided via telehealth in a manner that maintains treatment integrity and produces meaningful client outcomes. Although some of the policies around providing ABA via telehealth have changed, it is still considered a viable service model. With that said, it is important to follow these guidelines when considering delivering ABA services via telehealth.

  1. Behavior analytic principles still apply
  2. The service must be accessible (client has been assessed on readiness, has reliable technology, etc.)
  3. Individualization is critical, context is important
  4. Telehealth requires intentional monitoring of treatment fidelity
  5. Caregiver involvement is essential

 

What are the ethical obligations when providing ABA via Telehealth? 

  • All providers must be competent in telehealth delivery
  • Clients must provide informed consent
  • Measures to ensure confidentiality must be in place including a HIPPA compliant modality
  • Ongoing risk/benefit assessments must be conducted

 

What about documentation and billing? 

It is important to understand what is required by each payor, but generally the following documentation is required:

  • Modality
  • Location of client/provider
  • Session duration
  • Treatment goals addressed
  • Interventions used
  • Caregiver involvement
  • Justification for telehealth

Important: To provide telehealth services in Virginia, you must be licensed in Virginia. To provide telehealth to clients in other states, you must check with that state’s specific guidelines. Each state is different.

To see more about Virginia State Telehealth Laws, click here.

Can ABA be delivered via telehealth via Medicaid in Virginia?

The answer is yes, but only selectively and with restrictions. Virginia Medicaid (DMAS) does allow telehealth for ABA-related services, but it is not a blanket approval for all ABA treatment hours.

Generally allowed via telehealth (when clinically appropriate):

  • Caregiver training / family guidance (e.g., CPT 97156-type services)
  • Some behavior consultation activities
  • BCBA indirect services (e.g., treatment planning, supervision components in certain cases)
  • Certain protocol modification / consultation activities (case-dependent)

Typically, NOT appropriate for telehealth

  • Initial ABA assessments (must be in-person)
  • Many direct 1:1 skill acquisition services (97153-style treatment is generally expected in-person unless explicitly authorized)
  • Any service where safety, modeling, or hands-on prompting is required without caregiver capability in place

For more information see the following documents:

Telehealth Services Supplement (updated 1/5/2026) 

Provider Manual Part D (updated 7/17/2025) 

Where can I go to get more information and best practices?