ABA practice telehealth requirements in Maryland start with an authorized practitioner, an adequate evaluation and a service suited to the technology. For Maryland Medicaid, 97155, 97156, 97156-U2 and 97157 require readiness review, two-way HIPAA-compliant audio-video and current GT billing. Since April 1, 2026, at least 25% of each listed service must be in person and no more than 75% may be remote. Enrollment, authorization, treatment-plan, rendering and claim rules still apply.

Two locations belong in every Maryland telehealth record

Confirm the participant's and clinician's physical locations at the beginning of each remote encounter. A Maryland mailing address does not prove that a family is in the state that day, and a clinician affiliated with a Baltimore office may be connecting from elsewhere. Location affects licensure, payer enrollment, emergency response and sometimes the claim.

Make the question feel routine rather than suspicious. Families usually understand when staff explain that remote-care rules follow the people. If either location is unexpected, pause the clinical portion and route the facts for review. A warm rescheduling conversation is far better than asking a clinician to make an uncertain interstate decision while treatment continues.

Confirm Maryland LBA authority before scheduling

Maryland's behavior analyst licensing page explains that people practicing behavior analysis must be licensed and describes the BCBA or BCBA-D and graduate-education path. COMAR 10.58.16 addresses practice responsibilities, service models, supervision and the LBA's ultimate responsibility for design and implementation in the client's best interest.

Maintain a person-level record showing Maryland license, national credential, role, employer, service location, client assignment, supervision, Medicaid enrollment and effective dates. A national credential, prior authorization or employer roster cannot substitute for an active license. Likewise, an LBA's remote appearance does not silently convert every technician activity into licensed professional service.

Apply the clinical-evaluation rule to the real service

Health Occupations 1-1003 requires a clinical evaluation appropriate to the patient and presenting condition before treatment through telehealth. That principle fits ABA well: the clinician needs enough current information to understand the goal, relevant environment, risks, communication needs and whether the available view supports responsible work.

A caregiver coaching conversation may be strong over video, while a complex assessment may require direct observation that one camera cannot supply. Document why remote delivery works for this component and what information remains limited. The existence of a video link is not evidence that the professional standard has been met.

Build the new 25/75 rule into operations

Maryland Medicaid's ABA Transmittal 9, PT 60-26 changed the planning math effective April 1, 2026. For 97155, 97156 and 97156-U2, and 97157, at least 25% of the service must be rendered in person and no more than 75% may be delivered through telehealth. The transmittal supersedes the older continuation guidance.

Track the applicable service, participant, authorization period, date, units and modality using a methodology the program or its reviewer confirms. Do not assume that one in-person visit satisfies the rule for every later authorization, sibling service or rendering person. Keep the source, calculation convention and any written payer clarification with the ledger so a reviewer can reproduce the result.

Use the Telehealth Readiness Checklist as a clinical tool

The February 2026 Maryland ABA Provider Manual requires the Telehealth Readiness Checklist in treatment plans requesting remote 97155, 97156 and 97157. The checklist should help determine whether telehealth suits the participant and family, not merely prove that someone completed a form.

Review communication, technology, environment, caregiver participation, privacy, safety and the work the clinician must perform. Revisit readiness when the treatment component, goals, household, platform or support person changes. If the answer becomes “not today,” preserve an in-person or rescheduled path rather than forcing the encounter to protect a utilization plan.

Do not borrow audio-only permission from a broader policy

Maryland's general Medicaid telehealth page describes synchronous audio-video and, for some services, audio-only care. Maryland's general statutory definition also distinguishes telehealth from care provided solely by audio-only call, email or fax. The ABA-specific manual and PT 60-26 point to two-way HIPAA-compliant audio-video and GT for these ABA services.

When a camera fails, do not assume the broader program language keeps the ABA service billable. Decide whether the remaining conversation is a supported clinical service, nonbillable coordination or a reschedule. Verify the current ABA manual and program instruction before using any audio-only path. The narrower service-specific source should control the operational decision.

Keep the authorization and treatment plan synchronized

Maryland ABA prior approval depends on the treatment plan and supporting materials. An authorization can list dates and units while leaving modality allocation, readiness, rendering staff or place of service unresolved. Compare the approval with the current plan, checklist, 25/75 ledger, provider enrollment and service-specific instruction.

If the family requests telehealth after authorization or the clinical team changes the mix, determine whether a revised plan or new approval is needed. Communicate the difference between a clinical recommendation and a payer decision. Families deserve to know what is approved, what the practice is verifying and what in-person care remains available.

Make consent an ongoing choice

The Maryland Medicaid policy guide requires participant consent for telehealth except a documented emergency that prevents obtaining it. A useful conversation explains the planned service, technology, participants, likely household view, privacy choices, limitations, charges and failure plan. Treatment consent, telehealth participation, information release and recording permission remain separate.

Ask again after a meaningful change. A caregiver who welcomed remote parent training may feel differently about an observation with additional staff. Record who consented, what was explained and any condition on participation. Consent supports autonomy; it does not excuse an unsuitable modality or eliminate the practice's duty to offer appropriate care.

Protect the information path from invitation to claim

HHS privacy guidance helps owners see beyond the video platform. Calendar invitations, waiting rooms, device notifications, chat, screen sharing, recordings, technical support, exports, notes and claims can all contain health information. Review vendor terms, business-associate duties, account permissions, device security, retention and incident response.

Ask who can hear at each location and give the family room to adjust. Offer headphones, a quieter time, a different room or an in-person option without judging the realities of home life. Document a privacy limitation when it matters to care or consent, not every ordinary detail visible behind the family.

Plan accessibility before the first link arrives

Cameras and microphones do not create effective communication by themselves. The HHS and DOJ nondiscrimination guidance addresses disability access and language assistance. A family may need captions, an interpreter, screen-reader support, visual schedules, sensory adjustments, a larger device or a slower demonstration.

Test the actual platform and materials with those needs in mind. Include interpreters and support people in consent and privacy planning. When remote delivery cannot be made effective, arrange another appropriate format rather than treating technology skill as a requirement for care. Readiness belongs to the practice as much as it belongs to the family.

Make remote supervision clinically visible

Maryland's behavior analyst rules place responsibility on the LBA for individualized plans, frequent direct observation, data analysis and supervision matched to a supervisee's training and competence. Remote supervision must give the LBA enough access to perform those duties. A logged-in supervisor who cannot see the target behavior or staff response is not meaningfully observing it.

Plan camera placement, participants, measures, feedback and the circumstances requiring an in-person view. Distinguish employment oversight, certification supervision and billable 97155 work. Record the actual observation and direction. The 25/75 requirement should not pressure the clinician to characterize routine management as a covered clinical service.

Prepare a local continuity and emergency route

Before the encounter, confirm the participant's live address, callback number and the responsible adult or support person expected when clinically appropriate. Know the local resources identified by the care plan. Decide what staff will do if the connection fails, privacy disappears, a participant leaves or risk exceeds what the clinician can assess remotely.

Most failures call for reconnection or rescheduling, not emergency dispatch. Still, roles should be clear: who makes the clinical decision, who contacts the family and how an in-person or local resource is reached. A generic instruction to call 911 is not a complete continuity plan, and a telehealth practice is not an emergency service simply because it responds online.

Make the note and claim agree about modality

A strong record identifies the participant, rendering professional and role, participants, both locations, modality, consent, readiness, service purpose, clinical rationale, observations, technology or privacy limits, interventions and follow-up. It should also connect the encounter to the treatment plan and support the in-person or telehealth entry in the 25/75 ledger.

The current ABA manual says two-way HIPAA-compliant audio-video claims use GT and place of service 11, while PT 60-26 expressly repeats GT. Verify the live instruction for the date of service rather than assuming an older form never changes. Correct fields cannot cure an unsupported provider, service, authorization, readiness decision or percentage.

A fictional Maryland case shows the percentage trap

Chesapeake Maple Behavior Center is fictional. The team obtains a readiness checklist and approval for parent training, then schedules nearly every 97156 unit by video because the caregiver prefers evenings. The notes are detailed and the claims use GT. At renewal, someone notices the April 2026 rule requiring at least 25% in-person service.

The practice pauses additional remote units, preserves the authorization, checklist, schedule, notes and claims and asks the program for a written calculation. It does not invent in-person units or assume that high-quality remote care overrides the limit. Qualified reviewers decide the applicable measurement period, whether a correction is required and how to preserve clinically appropriate care for the family.

Pilot a Maryland workflow that remains understandable

Begin with a narrow set of services supported by licensure, clinical review, authorization, readiness and the 25/75 plan. Rehearse locations, consent, access, privacy, caregiver preparation, technology failure, supervision, in-person scheduling, notes and claims. Ask families what made participation easier and what felt intrusive or exhausting.

That is the practical answer to ABA practice telehealth requirements in Maryland: each remote component should be clinically sound, within the percentage rule and accurately represented. A prepublication review should include Maryland LBA expertise, current Medicaid operations, a caregiver perspective, clinical supervision, privacy and accessibility, practice ownership and qualified legal counsel, with the source dates visible to everyone.

Related resources

Sources