Colorado Medicaid: Parent Training (97156) Isn’t Billable

If you’re coming from another state, Colorado’s rules around caregiver training can feel surprising. Unlike many Medicaid programs, Colorado Medicaid does not reimburse CPT 97156 (Family Adaptive Behavior Treatment Guidance). This means you cannot bill standalone parent/caregiver training sessions under 97156 the way you might in other states.

Below is a simple breakdown of why, what this means for care delivery, and what compliant alternatives look like.

Why Colorado Medicaid Doesn’t Allow 97156

Colorado’s Health First Colorado program currently does not recognize 97156 as a billable ABA service. The state’s benefit design only includes:

• 97151 (Assessment)

• 97153 (Direct treatment by technician)

• 97155 (Treatment with protocol modification by a supervisor)

• 97154/97158 (Group codes)

Because 97156 isn’t part of the covered ABA procedure code set, any parent-only training, coaching, or caregiver-only work cannot be billed under the typical family-guidance structure.

This is not a documentation issue. It’s a structural rule of the benefit.

What This Means for Your Workflow

Caregiver training still matters, but the delivery model must follow Colorado Medicaid’s covered codes. This creates three important constraints:

1. No parent-only sessions.
   Sessions where only the caregiver is present — without the child — are not reimbursable.

2. Most caregiver support will fall under 97155 when conditions are met.

The Main Alternative: One-Tier 97155

In Colorado, most teams rely on one-tier 97155 (supervisor + no technician present) as the compliant path for caregiver involvement.

When 97155 Is Allowed

To bill 97155, all required conditions must be met:

• A BCBA/qualified supervisor is delivering the service.

• There is active modification of the treatment protocol, meaning the clinician is:

  • Running or modeling procedures, or

  • Adjusting prompting, reinforcement, or mastery criteria, or

  • Teaching the caregiver specific implementation steps that relate directly to the child’s treatment plan.

• The child must be present for the entire session.

Why the Child Must Be Present

Colorado Medicaid views 97155 as a treatment service, not a parent-only guidance service.
The child must be there so the supervisor can:

• Assess responding in real time

• Model strategies

• Observe generalization

• Make data-based modifications to the protocol

If the child is not present, the service does not meet Medicaid’s definition and cannot be billed.

What Caregiver Training Looks Like Under 97155

Here’s how teams typically adapt:

1. Embed caregiver coaching into supervised sessions

A typical session might include:

• The BCBA modeling a skill or routine

• The caregiver practicing it with the child

• The BCBA adjusting the protocol and providing feedback

• Documenting specific treatment-related modifications

2. Shorter, high-impact coaching

Since the service must remain tied to active protocol modification, Colorado BCBAs often:

• Use structured in-session role-play with the child present

• Coach families during naturally occurring routines

• Adjust targets, prompting strategies, or reinforcement plans live

3. Replacing 97156 objectives with in-the-moment, hands-on coaching

The outcomes are similar to caregiver training in other states, but the delivery is more integrated into direct treatment.

What You Cannot Do in Colorado Medicaid

To prevent denials, never bill:

• Caregiver-only sessions

• Zoom parent-training without the child visible and participating

• Psychoeducation without treatment modification

• “General support” or case management under 97155

• Supervision discussions with parents unrelated to specific treatment protocols

These are not reimbursable under the benefit.

Summary Table