TBS vs PSR in Ohio comes down to purpose, format, and who renders it. Therapeutic behavioral services (TBS, H2019) are goal-directed supports and solution-focused interventions tied to the treatment plan, delivered individually or in a group. Psychosocial rehabilitation (PSR, H2017 with the HM modifier) helps a person carry out treatment plan interventions to compensate for or eliminate functional deficits, and it is individual only.
Both services are defined in Ohio Administrative Code (OAC) rule 5160-27-08, effective March 1, 2022. Both bill in 15-minute units. Since July 1, 2026, they also share one utilization threshold with Ohio Medicaid managed care plans.
This guide reflects the rules in effect as of September 2026. It then covers the Ohio Department of Medicaid (ODM) proposal from July 2026, which would redraw the line between the two services. That proposal is not final.
TBS vs PSR at a glance
The table below compares current rules with the July 2026 proposal. QMHS means qualified mental health specialist, an unlicensed practitioner type. The "Proposed" row is not in effect.
| Therapeutic behavioral services (TBS) | Psychosocial rehabilitation (PSR) | |
|---|---|---|
| Current definition | Goal-directed supports and solution-focused interventions to reach treatment plan goals | Helps the person implement treatment plan interventions to compensate for or eliminate functional deficits |
| Typical activities today | Treatment planning, identifying strategies, evidence-based emotional and behavioral management, social skills, daily functioning, crisis prevention | Restoring daily functioning and routines, self-management of symptoms, skills to function in the community |
| Who can render today | Licensed practitioners, trainees and assistants, and QMHS with a bachelor's, master's, or three years of experience | Unlicensed practitioners: trainees, assistants, and high school or associate's level QMHS |
| Code | H2019 | H2017 with HM |
| Group | H2019 HQ | Not allowed |
| Unit | 15 minutes | 15 minutes |
| Threshold from July 1, 2026 | 200 units combined with PSR; group 120 units | 200 units combined with TBS |
| Proposed (not final) | Psychoeducation and evidence-informed supportive interventions; family training; crisis prevention; 200 units of its own | Functional skills and independent living; 200 units of its own; QMHS+3 could bill either service |
What OAC 5160-27-08 says each service is
TBS: goal-directed, solution-focused intervention
Paragraph (A) lists six TBS activities. They are treatment planning, identifying strategies or treatment options, and solution-focused interventions drawn from evidence-based psychotherapeutic treatments. They also include restoring social skills, restoring daily functioning, and crisis prevention and amelioration. TBS can include the family and other collateral supports, and paragraph (B) allows basic psychoeducation for those collaterals.
PSR: carrying out the plan in daily life
Paragraph (C) defines PSR around functional deficits. Its activities are restoring daily functioning to improve self-management of symptoms, supporting daily routines needed at home, school, work, and in the community, and restoring skills to function in a natural community environment.
Notice the overlap. TBS already covers "restoration of daily functioning," and PSR covers restoring daily routines. That overlap is why ODM wants to make the two services distinctly different.
Limits that apply to both
Paragraph (D) says TBS and PSR are not reimbursed while a person is enrolled in assertive community treatment (ACT) or receiving residential substance use disorder treatment. They are not paid separately during intensive home based treatment (IHBT) unless prior authorized. TBS may be individual or group. PSR must be delivered with the individual, not in a group.
Who can render TBS and who can render PSR
Rule 5160-27-08 sets the education floor. For TBS, the practitioner needs a bachelor's or master's degree in social work, psychology, nursing, or a related human services field. A high school diploma with three years of relevant experience documented by the agency also qualifies. For PSR, the practitioner is unlicensed, at least 18, and has at least a high school diploma plus mental health training.
The ODM Behavioral Health Provider Manual (version 1.28) turns this into rendering tables:
- TBS (Table 3-8): physicians, advanced practice nurses, physician assistants, psychologists, and licensed social workers, counselors, and marriage and family therapists. Also trainees and assistants at the bachelor's or master's level. Also qualified mental health specialists (QMHS) with a bachelor's (HN), a master's (HO), or three years of experience (UK).
- PSR (Table 3-11): social work, counselor, and marriage and family therapist trainees and assistants, plus QMHS at the high school or associate's level. Every PSR line carries HM.
In practice, a QMHS without a degree or three years of experience bills PSR only. A QMHS+3 bills TBS today. Enrolling as QMHS+3 requires a letter on agency letterhead, signed by the credentialing administrator, attesting to three years of relevant work experience. OAC 5160-27-01 requires unlicensed staff to work under general supervision of a listed licensed practitioner.
Compliance note: the education modifier must match the rendering practitioner's enrolled credential. A QMHS enrolled at the high school level who bills H2019 has billed a service the manual does not list for that credential.
How to bill TBS and PSR
Individual TBS is H2019. Group TBS is H2019 HQ. PSR is H2017 with HM, and the manual says HM is required to separate PSR from mental health licensed practical nurse (LPN) nursing, which also bills H2017. Practitioner modifiers (such as U-series trainee modifiers) and education modifiers (HM, HN, HO, UK) apply as the manual tables list them.
A few rules shape the units:
- Midpoint rule. A 15-minute unit needs at least 8 minutes of service.
- Crisis modifier. KX marks TBS or PSR delivered while the person is in crisis, within scope of practice.
- Office rate reduction. Under OAC 5160-27-03, paragraph (C), TBS and PSR delivered in an office setting for more than 90 minutes by the same billing provider to the same person on the same day are paid at 50 percent. The manual applies this after six units in place of service 11 or 53.
- Day treatment is separate. TBS group day treatment bills H2012 hourly or H2020 per diem under its own rule.
The July 2026 thresholds
ODM's May 12, 2026 bulletin set utilization management thresholds effective July 1, 2026. Individual TBS and PSR share 200 units (50 hours) combined per calendar year. Group TBS has 120 units (30 hours). TBS day treatment needs authorization after 30 units. Community psychiatric supportive treatment (CPST, H0036) has its own 200 units.
These are pass-through services. No authorization is needed to start, but one is needed to continue once the threshold is reached. Plans must authorize these services for at least 90 days, and use before July 1, 2026 does not count. The Ohio prior authorization thresholds guide covers the request process.
Documenting the choice between TBS and PSR
Because the current definitions overlap, an auditor may ask why a session was TBS rather than PSR. Rule 5160-27-08 points to the documentation rules in OAC 5160-01-27 and 5160-8-05. A defensible note usually shows three things:
- Plan linkage. Name the treatment plan goal or objective the session addressed.
- Intervention content. Describe what the practitioner did. Crisis planning or an evidence-based behavioral strategy reads as TBS. Practicing a daily routine or a community skill reads as PSR.
- Response. Record how the person responded and what comes next.
Audit tip: pull ten notes billed as H2019 and ten as H2017. If a reviewer cannot tell which is which from the note text alone, tighten the templates before an audit does it for you.
What the 2026 proposal would change
At its July 16, 2026 stakeholder office hours, ODM presented proposed changes to rule 5160-27-08. Comments were due July 22, 2026. As of September 2026, none of these changes is final.
| Topic | Current rule | Proposed (not final) |
|---|---|---|
| TBS purpose | Goal-directed, solution-focused interventions | Psychoeducation and supportive interventions informed by evidence-based practice to reduce symptom interference; family training; crisis prevention; treatment planning under a licensed supervisor; consultation with other providers |
| PSR purpose | Compensate for or eliminate functional deficits | Compensate for co-occurring functional deficits and promote independent living; symptom management, independent living, social and relationship skills, community integration |
| QMHS+3 | Listed for TBS | Could bill either, based on the content of the intervention |
| QMHS | Listed for PSR | Remains limited to PSR |
| Threshold | 200 units combined | 200 units each |
| 90-minute reduction | 50 percent in office settings | Removed |
| Other | None | More detail on exclusions, tie to assessment and treatment plan, "co-occurring capable," group services defined apart from day treatment |
ODM also proposed removing CPST from rule 5160-27-02. The Ohio CPST changes guide explains what that would mean for staff who bill H0036 today.
A caution for multi-state billers: H2017 is not one service
H2017 is a single Healthcare Common Procedure Coding System (HCPCS) code, but states attach different rules to it. In Ohio, H2017 with HM is PSR, individual only. In Minnesota, H2017 is billed for Adult Rehabilitative Mental Health Services (ARMHS), where HM identifies a mental health rehabilitation worker and HQ marks a group. The ARMHS H2017 billing guide lists the Minnesota modifiers. An H2017 HQ line that is valid in Minnesota has no Ohio PSR equivalent.
Keep a separate code and modifier map for each state. The claim format is the same 837P either way; the 837P field guide covers the fields that most often cause denials.
Common mistakes
- Billing a high school level QMHS on H2019.
- Billing PSR as a group, or dropping HM from H2017.
- Ignoring the 50 percent office reduction after 90 minutes.
- Tracking TBS and PSR thresholds separately when they share 200 units today.
- Treating the July 2026 proposal as current rules.
How Trustora helps
Trustora runs an Ohio Behavioral Health program on its configurable program runtime, alongside its Minnesota programs. Client records carry the Ohio Medicaid ID, and claims carry the National Provider Identifier (NPI) and taxonomy. Individual and group service records sit next to assessments, treatment plans, and progress notes, so each TBS or PSR note can point to the plan goal it addressed.
Readiness checks run before a service record becomes a claim, and claims are created only from signed service records. Trustora sends 837P claims, reads 277CA acknowledgments, and posts electronic remittance advice (ERA). See the Ohio behavioral health software page or contact us to walk through your TBS and PSR workflow.