The Centers for Medicare & Medicaid Services (CMS) recently released the proposed 2027 Medicare Physician Fee Schedule (MPFS), which includes updates relevant to adaptive behavior services and the CPT code set. Before diving in, it’s important to emphasize: these changes are not final. They are part of a proposed rule making process and are currently open for public comment and review.
What’s Being Proposed?
Within the proposed 2027 MPFS, CMS acknowledges the updated CPT code structure for adaptive behavior services, including the addition of six new CPT codes and revisions to the existing 97151–97158 code family. These updates stem from prior work by the AMA CPT Editorial Panel and are intended to better reflect the scope and complexity of services provided.
Additionally, CMS has proposed maintaining existing adaptive behavior CPT codes (97151–97158) on the permanent telehealth list for 2027, while not yet deciding about whether the newly developed codes will be included. (ABA Coding Coalition)
These proposals represent an important step forward—but again, they are subject to change based on stakeholder feedback during the comment period.
Why This Matters
Proposed changes to CPT codes and reimbursement structures can have significant implications for service delivery, billing practices, and access to care. The introduction of new codes may help more accurately capture the work of behavior analysts, while revisions to existing codes may influence how services are documented and reimbursed.
However, until the final rule is released, we should not implement any immediate changes to practice based solely on these proposals.
Stay Informed
We strongly encourage members to explore these updates in more detail and to hear directly from subject matter experts:
- Review the ABA Coding Coalition summary of the proposed rule- ABA Coding Coalition Proposed 2027 MPFS Overview
- Watch the webinar hosted by ABAI- ABAI Webinar on 2027 CPT Code Updates
- Watch the webinar hosted by APBA- A Practitioners Guide to the Proposed Adaptive Behavior Services CPT Changes
- Visit the ABA Coding Coalition website for ongoing updates and resources- ABA Coding Coalition Website
What’s Next?
CMS is currently accepting public comments on the proposed rule, with a deadline in mid-September. (Centers for Medicare & Medicaid Services) Feedback from providers, organizations, and other stakeholders plays a critical role in shaping the outcome.
VABA will continue to monitor developments and share updates as more information becomes available.