Clarification on observation and direction use in Early Intensive Developmental and Behavioral Intervention (EIDBI) services
Minnesota Department of Human Services (DHS) will require observation and direction (that is, CPT code 97155) authorization requests to include individual clinical justification that demonstrates medical necessity for EIDBI services requested on or after Jan. 1, 2026. We are working to clarify the expectations that observation and direction must be individualized and tied to the person’s documented clinical need to ensure consistent application across the program. These clarifications align with new clinical supervision standards we announced in a July 29, 2025, eList announcement and that are outlined in Minnesota Statutes, 256B.0949.
EIDBI provider actions
Observation and direction services may not receive authorization approval if requirements are not followed.
EIDBI providers must:
• Meet supervision requirements in Minnesota Statutes 256B.0949, subdivision 15-16 and ensure the qualified supervising professional (QSP) provides the minimum required oversight.
• Ensure observation and direction services requested in the individual treatment plan (ITP) reflect the person’s specific clinical need. Refer to the How to complete ITP and Progress Monitoring, DHS-7109 webpage for more information and instructions.
• Request observation and direction services in proportion to direct treatment (that is, CPT code 97153 and 97154) and document medical necessity in the ITP.
• Align observation and direction use with national guidance (that is, Council of Autism Service Providers [CASP], ABA Coding Coalition), which recommends 20% of the person’s direct treatment hours.
• Use the ITP to explain the need for observation and direction service authorization. If observation and direction services exceed 20% of direct treatment hours, the medical review agent may request unit reductions or additional documentation.
• Use observation and direction as a supervisory, supportive service that supplements direct treatment, as indicated in the Observation and direction EIDBI Benefit Policy Manual.
EIDBI providers must NOT:
• Provide observation and direction without prior authorization.
• Request observation and direction services equal to or greater than direct treatment hours.
• Assume the QSP must deliver all observation and direction services. Other qualified staff may provide observation and direction when clinically necessary.
• Use observation and direction as a substitute for direct treatment, to mirror treatment intensity, default authorization or routine agency practice without individual consideration.
Service authorization
DHS, its medical review agent and managed care organizations are actively working to consistently enforce the observation and direction requirements. This is part of a broader effort to establish consistent and equitable service limits. This approach aligns with Minnesota’s EIDBI program with national best practices and ensure high-quality, person-centered care across services.
More information
Email ASD.DHS@state.mn.us if you have questions about this message.
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