Operating ABA Clinics for Payment Scrutiny With Steve Antico – Partner Director Garfunkel Wild

In ABA, payment risk rarely begins with a formal audit. It begins quietly, through small operational decisions that drift over time.

In this episode of the ABA Compliance & Legal Series, Tzvi Weiser speaks with Steven Antico, Partner & Director at Garfunkel Wild and Chair of the firm’s Behavioral Health Practice Group, about what payers actually scrutinize and where clinics get exposed.

We cover:

• How audits start (warrants, subpoenas, admin demands, overpayment letters)
• Why payers flag clinics (duration of care, lack of documented improvement, billing patterns)
• EMR pitfalls and how “outputs” can fail even when the data exist
• Plan-by-plan rules you must track (diagnosis cadence, tools, credentials, modifiers)
• Time reporting traps (breaks, transportation, “impossible” sessions) and extrapolation risk
• Overlapping codes and why simultaneous billing gets attacked
• Clinic-based services and the “daycare” characterization risk
• What a compliance plan is (administrative), why plans ask for it, and what makes it real

About NUCO Filings NUCO Filings provides entity formation, registered agent service, and ongoing compliance nationwide. We serve ABA operators across the country, and these conversations help us stay sharp on what clinics face under payment scrutiny.

Disclaimer: This content is for educational and informational purposes only and does not constitute legal, tax, or medical advice. Nothing here creates an attorney-client relationship. For advice specific to your situation, consult qualified professionals.