We Updated Our Criteria. Here's Why That Matters.

I lead product at Brellium. When a potential customer asks what sets us apart, I don't lead with features. I talk about our commitment to making sure Brellium’s criteria never stagnate.

We pressure test our criteria monthly to identify possible updates. In practice, that looks like our product, engineering, GTM, and customer success teams meeting regularly to review customer feedback, clinical advisor input, and new payor policy updates — then making changes that will best move the needle on audit outcomes.

This ranges from adding new criteria, adjusting verbiage of others, and ensuring the ones in our default sets are ensuring our customers are audit ready.

We invested in this workflow to ensure Brellium stays a step ahead of audit trends and revenue risk. You can trust that as your compliance partner we’re always vetting your charts against the most up-to-date standards.

Here are the most significant updates we made to our criteria in June.

1. ABA Direct Treatment: Nap and Sleep Documentation

We added a question to our ABA direct treatment codes (97153, 97154, 97155, 97158) that asks: Was the session note devoid of references to nap or sleep?

This update came as a direct response to audits and media reports suggesting ABA providers have been billing for non-therapeutic services.

Most payors will deny reimbursement for sessions during which the client was sleeping — even if real clinical care was also provided. Payors want ABA notes to demonstrate active client engagement. If a note mentions a nap period and the billed duration doesn't account for it, that documentation gap will typically trigger denials.

Nearly 85 ABA customers in our network already check for this using custom questions, and the data shows Brellium has been effective in helping teams root out language about sleep. In October 2025, 9% of notes flagged for nap or sleep references. As of June, that number has dropped to 2.5%.

We have seen firsthand that teams improve their documentation quality by checking for this language. So now we’re offering it as a default question to ensure all our ABA teams are prepared for heightened payor review.

2. ABA 97153: BCBA Co-Signature Requirement

We added a co-signature question to the 97153 set: Was this session note co-signed by a supervising BCBA?

This reflects a documented shift in payor policy. In 2024, Anthem updated its reimbursement policy to effectively require BCBA co-signature in nine states — Colorado, Connecticut, Indiana, Kentucky, Maine, Missouri, Ohio, Virginia, and Wisconsin. In recent months, additional payors have signaled movement in the same direction, so we recommend that ABA teams prepare their compliance processes now for this heightened standard.

This update helps providers stay ahead of the curve on compliance trends. Organizations are better protected having this question in their default set than discovering the requirement after an audit.

3. Therapy Notes: Tightening the Session Time Check

Our existing question asked whether start and end times were documented. We updated the logic to go further: Brellium now checks that at least one of those times does not fall on an exact hour, half-hour, or 15-minute increment.

We added this check after hearing concerns from compliance teams that many session notes were starting and ending exactly on half-hour intervals. They worried that the uniformity could raise flags to payors for possible fraud. Legitimate sessions tend to have natural variation. Documentation that consistently shows clean, templated times is an audit risk.

Therapists who are documenting accurately won't trip this question, or can override the flag. However, we want to make it easy for compliance teams to readily spot template-generated or populated notes that don't reflect the actual session length.

4. Psychiatric Notes: PDMP Verification for Controlled Substances

We added a question to Psych Intake and Follow-Up sets: Was the PDMP reviewed for this patient prior to prescribing a controlled substance?

Prescription Drug Monitoring Program checks are a state-mandated requirement in a growing number of jurisdictions. For psychiatric prescribers, that means they're increasingly a condition of clean documentation, not just good practice. When a payor audits a note that involves a controlled substance prescription and there's no documented PDMP review, that's an exposure.

The question is scoped to states that actually require it for now, so it won't create noise for customers operating where this isn't mandated. However, teams that are interested in proactively checking for this can add it to their question set with their customer success manager.

This Is How We Keep Our Promise

Routine criteria review keeps Brellium up to date on shifting payor policies, new state-specific requirements, and real world audit trends.

We are obsessive about being the most agile, adaptable compliance team on the market, because we know that our audits are only as strong as the criteria we check your documentation against.

Brellium pairs our criteria updates with continued product releases and updates, to ensure we are always progressing and providing first-class compliance protection for our healthcare partners.

To learn more about how we make changes or to see our question set applied to session notes in a live demo, book time with our team. We’d love to show you how we protect your revenue and help you maintain compliance, in this moment and the moments to come.