When Should a Remote BCBA Use a Telehealth Place of Service Code?

A BCBA sits at her home office, she logs in remotely to an EHR for a client located several states away, she reviews data from the client's last few therapy sessions, and she updates several protocols. Two hours later, she signs the note and bills it with a telehealth place-of-service code, because she provided the service remotely. Similarly, another BCBA connects remotely to an ABA clinic where a client is receiving ABA therapy in person from a behavior technician. The BCBA observes how the client responds to the technician and the protocols, directs the technician as needed, and evaluates and modifies each protocol as needed. At the end of his service delivery, he completes his session note and indicates that the location of the service was "office" because that's where the client was located.

In each of these examples, the BCBAs selected incorrect place of service (POS) codes. Some of the confusion comes from adding telehealth into the mix, and some seems to come from not understanding the difference between direct and indirect services within ABA.

We've seen these types of mistakes in the session notes we audit for ABA agencies: indirect, no-client-present work labeled "telehealth" simply because the clinician wasn't in the building. It's an easy mental shortcut, "I was remote, so this must be telehealth." That's not (fully) how POS codes work.

What a POS code actually does on a claim

Every service line on an ABA claim submitted to a health plan carries at least two codes that work together, not one. The procedure code (like 97155 or 97156) tells the payer what service happened. The place-of-service code tells the payer where it happened. A payer reads them as a pair: this specific service, delivered in this specific setting.

That pairing matters for at least three reasons. First, it may affect the reimbursement rate. The same CPT code can pay differently depending on the POS, since telehealth and in-person delivery may come with different overhead costs. Second, it's a factual claim about the encounter, separate from the clinical content of the note. A payer or auditor can check whether the POS is even plausible for the service billed, independent of whether the note itself reads well. That's exactly the kind of mismatch that draws a second look: a code that describes a live client encounter, paired with a location that doesn't seem to match.

Two different rules, depending on the service

With Direct services the client or caregiver actively participates: a parent-training session, a BCBA modifying a protocol while directing a technician who's with the client. For these services, place of service follows the client. If the client's at home on video, that's POS 10. If they're at a clinic or school on video, that's POS 02. If everyone's in the same room, it's an in-person code (POS 11 for a clinic, POS 12 for the client's home).

With Indirect services, the client (or other service recipient such as a caregiver) doesn't have to be present at all: data analysis, protocol review, treatment planning. There's no client on the other end of anything, so there's no client location to reference. Telehealth POS codes don't apply, because there's no telehealth visit happening. Here, the place of service follows the provider: wherever the BCBA actually did the work determines the location code that goes on the claim.

Direct-service examples that hold up

• A parent-training session (97156) over video, family at home. POS 10.
• A BCBA joining by video to direct an in-person technician while watching the client and adjusting the protocol in real time, client at home. POS 10, because the client's home is what matters, not the BCBA's.
• A caregiver-guidance session (97157) with families dialing in from a clinic waiting room. POS 02.

Indirect-service examples, and where mistakes creep in

• A BCBA reviewing data and updating a protocol with no client present. Not telehealth. The correct code reflects where she actually was, likely an office code (11).
• A BCBA scoring an assessment or writing a report from their home office, no client involved. Same logic.

The part that needs real caution: is the indirect work billable at all?

Getting the POS code right solves half the problem. The other half is harder: many funders don't pay for indirect BCBA time the same way they pay for direct service, and the rules vary a lot from one payer to the next. Some Medicaid or commercial insurance programs may pay for protocol review and case management without the client present under certain conditions. Others pay for almost none of it.

This isn't a reason to assume indirect work is unbillable, and it isn't a reason to assume it's fine, either. It's a reason to check, in writing, before you bill it. If your team is billing indirect time and nobody can point to the specific funder policy that allows it or written communication from the funder approving it, that's worth a conversation with the payer.

FAQ

Does the place of service code always reflect where the client was located? No. For direct services, where a client or caregiver is actively part of the session, the POS code usually reflects the location of the service recipient. For indirect services with no client present, the code typically reflects the provider's location instead.

Can a BCBA use a telehealth POS code for data analysis or protocol review done alone? No. Telehealth POS codes describe a live encounter with a client. Without a client on the other end of the connection, there's no telehealth visit to code.

What's the difference between POS 10 and POS 02? POS 10 means the client (or parent for CPT code 97156) was in their own home during a telehealth visit. POS 02 means the client was somewhere else, like a clinic or school, during a telehealth visit.

Is indirect BCBA work like protocol modification ever billable? It can be, depending on the funder. Some insurance programs and payers do reimburse specific indirect activities under certain conditions. Whether a given service qualifies is a funder-specific question, not a general rule.

What should a BCBA do if they're unsure whether indirect time is billable? Get clarification from the funder in writing before billing it. Verbal guidance is hard to point back to later; a written answer (even an email) helps protect the agency and the clinician.

If your team's documentation blurs direct and indirect work, or an EHR default quietly assigns a place of service that nobody checks against what happened, that's exactly what our Session Note Frameworks courses address. They walk through what a defensible note needs, code by code, including how to document place of service instead of accepting whatever the system selects for you. They won't tell you what a specific funder reimburses for indirect time, since that answer has to come from the payer. But they'll help your notes accurately describe what happened, so a funder's written answer lines up with your documentation. Learn more about our Session Note Frameworks.