Indiana Pauses ABA Provider Enrollment for Six Months

Indiana's Family and Social Services Administration (FSSA) announced Tuesday it will pause enrollment of new ABA therapy providers for at least six months, beginning June 7, 2026. The moratorium, which has been approved by CMS, also covers ownership changes for existing providers.

The moratorium runs through early December, with possible six-month extensions. Applications submitted before June 7 will be processed normally. Accredited providers in underserved areas may request an exception.

Leading up to today's news

This is the latest chapter in a year of significant policy action in Indiana.

In April, the state introduced phased rate reductions for ABA, a 4,000-hour lifetime cap on comprehensive services, an age cutoff eliminating reimbursement for patients over 21 starting this fall, and a new accreditation requirement.

Providers considered the changes introduced then to be sweeping, given they touched on care delivery concerns ranging from provider qualifications to discharge. However, the enrollment freeze announced Tuesday signals the state may not be finished reforming ABA administration.

Autism therapy has attracted scrutiny in part due to an increase in spending. In Indiana, the FSSA found ABA spending increased from $21 million in 2017 to $611 million in 2023. This year, spending exceeded $35 million in a single month this January, the agency said.

A federal OIG audit found the state has made at least $56 million in improper fee-for-service ABA payments in 2019 and 2020, with auditors flagging specific documentation failures that providers should take seriously.

Documentation errors at the heart of OIG concerns

The audit cited gaps in documentation supporting CPT codes 97155 and 97156, missing or incomplete state-required signatures, insufficient detail in session notes, and ambiguity around what the state considers billable ABA time.

These documentation gaps are solvable problems. For providers operating in Indiana — or providers watching the compliance landscape carefully — the practical checklist looks like this:

CPT 97155 (protocol modification by BCBA): Notes must document what was observed, what was changed, and why — in real time. Vague entries aren't sufficient; data alone doesn't fulfill documentation requirements. The BCBA's direct involvement and the specific protocol modification must be explicit.

CPT 97156 (caregiver training): Notes must demonstrate caregiver-focused training — who was present, what was taught, and evidence of caregiver skill uptake.

Signatures and credentialing: A missing signature or incomplete credential can invalidate a claim entirely. Every note should include the rendering provider's full name, credential, and a dated signature, with supervising BCBA information clearly documented when the rendering provider is an RBT.

Session notes and billable time: Start and end times must support the number of units billed. Any non-billable time within a session should be clearly separated.

Indiana isn't alone in moving toward increased oversight and tighter reimbursement logic. Georgia's primary Medicaid managed care organization recently announced it will reimburse at just 80% of the state fee schedule. Nebraska and North Carolina are weighing similar measures. The OIG has an active multi-state ABA audit initiative underway.

What this means for providers

Documentation quality and billing accuracy are increasingly the price of admission to Medicaid ABA programs — not just a safeguard against audits.

Providers who have invested in systematic chart review are better positioned to demonstrate compliance, pursue accreditation, and make the case to payers that they belong in a preferred tier.

Brellium's AI-powered audit platform helps ABA providers review every chart against current payer and quality requirements — so documentation gaps get caught before they become a liability. Book a demo to learn more.