Free Resource · ABA Compliance Solutions
Your Notes Pass Your Review. Would They Pass a Payer's?
There's a difference between documenting a session and proving the service you billed. Most clinically excellent notes can't do the second one. This free self-audit shows you exactly where your notes stand, the way a payer's reviewer would read them.
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Recent OIG Audit Activity
Audit findings are already common
Recent OIG reviews found that somewhere between 64% and 96% of the ABA service months they examined lacked sufficient documentation. These weren't agencies doing bad clinical work. They were getting paid right up until someone looked.
64–96%
of ABA service months examined lacked sufficient documentation
Paid ≠ Defensible
Claims get paid first and reviewed later. "We've always been paid" describes what hasn't happened yet — not whether your notes would hold up when someone finally looks closely.
Source: OIG Work Plan Reviews, HHS Audit Data
Does Any of This Sound Familiar?
The silence isn't reassurance.
"Our notes are thorough. Our clinicians are careful. We're not worried about documentation."
"We've never had a claim denied for documentation, so we must be fine."
"Our EHR generates the notes. Whatever it produces is what we go with."
"If there were a problem with our notes, someone would have told us by now."
Being paid isn't the same as being defensible. Claims get paid first and reviewed later. "We've always been paid" describes what hasn't happened yet — not whether your notes would hold up when someone finally looks closely.
What Nobody Trained You On
You're doing a lot of things right. This is the one nobody trained you on.
You've built a clinical team. Your BCBAs supervise with care. Your techs run good sessions and your kids make real progress. Running an ABA agency is hard, and you're doing it.
But documentation is its own skill, and it's a different one from delivering good care. A note can capture excellent therapy and still fail to prove the service that was billed — because the person reviewing it in an audit isn't asking whether the care was good. They're asking whether the note, on its own, substantiates the claim.
Nobody sat you down and explained that gap. It's not in BCBA coursework. It's not on the credentialing application. And it usually stays invisible right up until a records request arrives.
What Gets Found in Audits
Here's what the gap looks like in real notes
Time you can't defend
A three-hour session documented as a short list of activities gives a reviewer no way to judge whether the time was justified. If the note doesn't account for the hours, the hours are exposed.
Activities with no link to a goal
"Played board games" and "had lunch" aren't billable on their own. When notes describe pleasant activities instead of treatment tied to plan goals, they read like childcare, not medically necessary care.
Supervision work left invisible
A 97155 note that says "reviewed and modified 3 programs" leaves most of the BCBA's actual clinical judgment uncaptured, including every protocol they reviewed and decided to continue. Invisible work is unbillable work.
'The vendor's prompt wrote it' is not a defense
AI-generated summaries can introduce interpretation, unsupported claims, and even speculative content. Responsibility for the record stays with your organization, no matter what generated the draft.
The Session Note Self-Audit
Start here. Find out where your notes actually stand.
The Session Note Self-Audit is a one-page checklist that walks you through the exact checks a payer's reviewer applies, organized by CPT code. Pull a small sample of recent notes, read them with no clinical context, and pressure-test each one in about a minute.
What's inside the checklist
- The universal checks every note needs: exact start and stop times, everyone present named with their role, and visible medical necessity
- Direct therapy (97153): linking every activity to a treatment plan goal and justifying the time billed
- Protocol modification and supervision (97155): capturing continued protocols and the clinical reasoning behind them, not just modifications
- Assessment (97151): documenting clinical service rather than a summary of activities
- How to read a note the way a payer's reviewer does, so internal review reflects real external risk
What Comes Next
The checklist shows you the gaps. These help you close them.
ABA Session Note Frameworks · The Standard
CPT-Aligned Documentation Standards
A checklist tells you where a note falls short. Fixing it across your whole team takes a shared standard — one set of CPT-aligned expectations every clinician, supervisor, and reviewer writes and reviews against. That's the Frameworks: short, CPT-specific guidance with real examples and non-examples, built around what payer reviewers actually look for, before a records request arrives.
Learn More About the Frameworks →Membership · The ABA Compliance Collective
Expert Guidance for ABA Leaders Carrying Compliance
Some documentation questions don't have a tidy checkbox answer. An unusual client situation. A payer policy that just changed. A gap you suspect but can't size. The Collective is a membership community built specifically for ABA leaders carrying compliance without a formal compliance background, so you're not figuring those out alone.
- Expert-guided answers to your real documentation questions
- Regulatory updates you can act on before they catch you off guard
- A curated library of tools and templates for small and mid-sized ABA agencies
- Session Note Frameworks included, plus quarterly live sessions with Michael and Rose
Who's Behind This
Built by two people who have spent decades in the field.
30+
Years Michael in ABA
25+
Years Rose in Behavior Analysis
4
Compliance Credentials (Michael)
Michael Fabrizio
Michael is one of the only people in the ABA field who is both a Board Certified Behavior Analyst and a credentialed compliance professional. With over 30 years of experience in applied behavior analysis and deep expertise in healthcare compliance — including privacy, billing, auditing, and investigations — he built ABA Compliance Solutions to give small- and mid-sized ABA agencies the compliance support they've always needed but rarely had access to.
Rose Feddock
Rose brings over 25 years of experience in behavior analysis and more than a decade in healthcare compliance. She has served in clinical, administrative, and compliance roles across multiple organizations, including as Compliance Coordinator and Director of Standards for the Behavioral Health Center of Excellence. Rose specializes in policy development, clinical documentation, auditing systems, and ethics, and brings a clarity and practicality to compliance that ABA leaders find immediately useful.
Start Today
Know where your notes stand.
Download the free Session Note Self-Audit and take a few minutes to find out what your notes prove — and what they don't.
Get the Free Self-Audit