Page updated: 8/31/26

CMS-approved state plan amendment – 2017 (PDF), CMS-approved state plan amendment – 2018 update (PDF), CMS-approved state plan amendment – 2019 update (PDF), Minn. Stat. §256B.0949

Observation and direction (i.e., adaptive behavior treatment with protocol modification): A component of clinical supervision delivered by a qualified EIDBI provider that focuses on the clinical direction and oversight of intervention services and active protocol modification of the person’s individualized treatment programming based on real-time observations.

Protocol modification: Ongoing clinical decision-making and adjustments made by a qualified EIDBI provider to ensure that treatment remains individualized, effective and responsive to the person’s progress or needs.

Observation and assessment: A component of protocol modification during which a qualified EIDBI provider observes service delivery with active evaluation of program component effectiveness for the person. The provider must:

Observation and direction:

A qualified EIDBI provider can only deliver observation and direction when they do either of the following:

1. Conduct direct intervention with protocol modification(s) with the person (with no other EIDBI provider present) to observe changes in the person’s behavior or troubleshoot treatment procedures.

2. Join the person and another EIDBI provider during an individual, group or higher intensity intervention session with protocol modification(s).

The following EIDBI providers can deliver and bill for observation and direction:

Scope of practice and experience requirements

Qualified level I and level II providers can only deliver observation and direction when clinically appropriate and within their scope of practice. A lower-level provider cannot deliver observation and direction to a higher-level provider.

A QSP must provide EIDBI observation and direction at least once per month to each person receiving services.

Telehealth requirements

If medically appropriate to the person’s condition and needs, providers may deliver observation and direction via two-way, interactive video.

Note: The QSP can only deliver the required observation and direction via telehealth for two consecutive months. They must deliver observation and direction in person in the third month.

For more information, refer to EIDBI – Telehealth services.

Multiple providers may deliver observation and direction services at the same time when:

Observation and direction progress notes for multiple providers

When multiple providers deliver observation and direction at the same time, each provider who bills for an EIDBI service must:

For more information, refer to the documentation section below.

Authorization and billing for multiple providers

When multiple providers deliver observation and direction at the same time, they may use the same billing code (i.e., 97155) to bill for observation and direction.

For example, a level I provider and QSP both deliver observation and direction (i.e., billing code 97155) while a level III provider delivers individual intervention services (i.e., billing code 97153). For more information, refer to the service authorization and billing section below.

Observation and direction includes the qualified EIDBI provider’s active oversight and direction during treatment. Observation and direction services must:

Observation and direction may include:

Observation and direction does not include:

For more EIDBI benefit-wide non-covered services information, refer to EIDBI – Services – Non-covered services.

EIDBI providers must not:

Providers must document observation and direction according to the requirements on EIDBI – Health service records.

Required documentation in the person’s progress notes

The provider also must document the following information in observation and direction progress notes:

Required documentation for authorization

When a provider requests authorization for observation and direction, they must document the following information in the person’s ITP:

Note: EIDBI providers must align observation and direction services with national best practices for autism service providers. If requested observation and direction exceeds 20% of direct treatment hours, the medical review agent or managed care organization (MCO) may request additional documentation, reduce authorized units or deny the request if the provider does not provide sufficient clinical rationale.

For authorization and billing information, including provider and service limits, refer to:

Authorization and billing requirements

Before delivering observation and direction, providers must have approved authorization in the person’s ITP. For more information, refer to MHCP Provider Manual – EIDBI – Service authorization.

EIDBI providers must authorize observation and direction:

To bill for observation and direction, providers must meet the observation and direction covered services requirements described in the section above.

For more information, refer to MHCP Provider Manual – EIDBI – Billing.

Modification of written protocol

If a provider determines that a program requires modification during observation and direction, they must modify the program outside of the observation and direction time. Modification of written protocols is an indirect service for which the provider cannot report or bill separately. The reimbursement rate for direct time with the person factors in time for a provider to complete administrative tasks (e.g., creating materials, modifying written protocols).