Keeping Compliant Progress Notes for TRICARE’s Autism Care Demonstration

Wednesday, January 31, 2024

Under TRICARE’s Autism Care Demonstration (ACD), applied behavior analysis (ABA) providers must keep progress notes (also called narrative summaries or session notes) for each rendered session. Although ABA providers do not have to submit progress notes with their claims, Health Net Federal Services, LLC (HNFS) may ask to see progress notes during an audit. Audits identifying progress notes as insufficient related to or noncompliant with any required content may result in payment recoupment.

Progress notes must:

Contain all TRICARE-required elements,
Support the respective claim, and
Relate to the beneficiary’s approved treatment plan goals.

Including Required Elements

Note: This list does not cover all required elements. Please refer to TRICARE Operations Manual, Chapter 18, Section 4 and TRICARE Policy Manual, Chapter 1, Section 5.1 for complete details.

Patient’s full name (no initials)
Date, time (start and end times), length of session
Location of rendered services
Names of session participants (do not include other individuals present during sessions that use Current Procedural Terminology [CPT®] codes 97157 and 97158)
Rendering provider’s name and license or certification
Dated signature (Important: This is the date the progress note was signed and may differ from the progress note's session date. The date of the session alone will not meet the dated signature requirement.)
Name of ABA supervisor authorized per the treatment plan (when different than the rendering provider)
Patient’s current clinical status as observed at the beginning of each session
Narrative summaries of session content to include details that support CPT codes
ABA techniques attempted, response to treatment, and progress toward treatment goals

Supporting the Claim

Progress notes must support services billed, such as: rendering provider name and license or certification, CPT code, units, place of service (location where services were rendered).

Tying to Treatment Plan and Permitted Services

Progress notes should relate to the approved treatment plan goal areas. Excluded areas (for example, academics, activities of daily living, vocational) should not be rendered during billed session time.

Visit our Progress Notes page and review our Medical Documentation Requirements guide for more information. Additional CPT code and exclusion-related content is available on our Billing and Exclusions pages.

Please note: This educational piece reflects existing process and requirements in effect since the implementation of the TRICARE Operations Manual (TOM) 85. There are no changes to these requirements in TOM 132.