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The Compliance Agent automatically reviews your session notes against a library of rules before billing or audit. This article explains every default rule that ships with Hipp — what it checks, why it matters, and what triggers a flag.

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What are default rules?

When you first set up the Compliance Agent, Hipp provides a curated set of default rules based on common payor requirements, OIG audit patterns, and ABA billing standards. You can use these as-is, customize them, or build your own on top of them.

Rules are organized into eight categories. Each rule carries a severity tier:

1. Signature Verification

Checks whether the right people signed a session note, and whether they signed at the right time.

Rule Tier What it checks
Provider signature missing 1 day after session 🔴 Error Flags any note with no rendering-provider signature by the day after the session. Missing provider signatures are one of the most common audit recoupment triggers.
Caregiver signature missing 3 days after direct therapy 🟡 Warning Scoped to 97153. Many payors (e.g. Centene, Optum) require a caregiver attestation confirming the child attended. Flags if absent 3 days after the session.
BCBA co-signature missing 5 days after technician session 🟡 Warning Scoped to 97153. Tech-delivered services require documented supervisory sign-off within a short window. Flags if the supervising BCBA or QHP has not co-signed within 5 days.
Provider signed before the session ended 🔴 Error Flags any note where the provider's signature timestamp is earlier than the session end time. Signing in advance is treated as a falsified attestation and is a hard audit red flag.

2. Session Overlap

Compares a session's time window against other sessions for the same client. Rules can require sessions to overlap — or require they do not.

Rule Tier What it checks
No double-billing of the same service code 🔴 Error Two sessions for the same client billing the same code cannot overlap in time. This is a standard payor edit to prevent duplicate units being billed for one block of time.
97151 assessment must not overlap any other session 🟡 Warning Assessment time should not be billed concurrently with direct care, supervision, or parent training. Flags any 97151 session that overlaps another session for the same client.
97155 supervision should overlap a direct session 🟡 Warning 97155 is intended to be delivered alongside the direct-care session it is modifying. Flags if there is no concurrent session with at least 50% overlap.

3. Narrative Analysis

Scans the text of a session note for prohibited or required phrases. Useful for catching language that auditors flag or that payors require.

Rule Tier What it checks
Avoid non-therapeutic activity terms 🟡 Warning Flags terms like "nap," "iPad," "ate lunch," "watched TV." Documented non-therapy activity gives auditors grounds to strip billable units.
Avoid vague or subjective language 🟡 Warning Flags phrases like "seemed to," "a little," "good," "I think." Subjective phrasing weakens medical necessity and should be replaced with objective, measurable descriptions.
Avoid staff-inactivity phrasing 🟡 Warning Flags phrases like "staff sat," "staff watched," "RBT sat." These suggest the technician was not actively delivering the protocol — a frequent OIG citation.
Copy-paste indicators (boilerplate phrasing) 🟡 Warning Flags generic phrases like "session went well," "same as last session," "see previous note." Identical notes across sessions are a top OIG fraud indicator.
Telehealth platform mentioned in an in-person note 🔵 Info Scoped to in-person places of service. Flags mentions of Zoom, FaceTime, Doxy, etc. in a note that should have no telehealth component — usually a copy-paste error.
97155 must list all required session participants 🟡 Warning Scoped to 97155. The note should reference the Client, the Technician, and the BCBA, since the code requires the BCBA to be present and actively directing the technician.
97156 must reference caregiver participation 🟡 Warning Scoped to 97156. Parent-training notes must show that a caregiver actually participated. Notes lacking "caregiver" or "parent" typically fail audit.