Signature & Session Compliance Guardrails

This article outlines the Signature & Session Compliance Guardrails in Orbit. These guardrails ensure accurate provider signature, proper payer compliance, and consistency across documentation.

Orbit applies automated checks throughout the process to validate provider roles, enforce access permissions, align provider information when needed, and log any compliance issues for reporting and visibility. Together, these safeguards help maintain accuracy and integrity across all session documentation and completion workflows.

Note Entry Validation (97153 Sessions)

During 97153 session documentation, if a provider indicates that supervision occurred, they must select the supervising BCBA present.

• Selection of a supervising BCBA is required to proceed

• If no supervising BCBA is selected, the note cannot move forward

Provider Signature Guardrails

At the time of provider signature submission, the system enforces sequential validation checks:

• Identity Check: Signing user must match the rendering/provider associated with the note

• Signature Verification: Drawn signature may be validated against the provider’s master signature on file

• Provider Type Check: Signing provider must match the required provider type for the appointment

• Supervising Requirement: For supervision or parent-training notes, signer must be an assigned supervising BCBA (BCaBAs and BA-Candidates can be added to a kiddo’s Care Team, and they will still have access to sign notes as usual when the payer allows).

• Payer Enrollment Check: Supervising BCBA (and BCaBA or BA-Candidate)must be enrolled with the client’s primary payer for the date of service

• All conditions must pass prior to successful submission

Access Control for Providers

Providers not enrolled with a client’s primary insurance will be considered observing providers. They will have access restrictions, but will still retain visibility into clinical progress and treatment planning.

• Observing-team providers receive view-only access

• These providers are restricted from writing or signing notes

97153/97155 Paired Requirement

This update is designed to prevent mismatches between the BCBA selected for supervision on 97153 and the servicing provider on 97155, helping keep documentation consistent and audit-ready.

RBTs will be asked to select the BCBA who attended the supervision session that overlaps with the direct services session. To keep everything aligned, the BCBA selected on the 97153 session will need to match the BCBA who signs the corresponding supervision note.

To help ensure accuracy and compliance, note completion will be blocked unless:

• Both linked sessions (97153 and 97155) are present

• Each note independently meets all completion requirements

This update is designed to prevent mismatches between the BCBA selected for supervision on 97153 and the servicing provider on 97155, helping keep documentation consistent and audit-ready.

Cigna and Tricare plans are not subject to these 53/55 paired compliance requirements.