Indiana Medicaid’s effort to rein in Applied Behavior Analysis (“ABA”) therapy costs has led to a proposed moratorium on provider enrollment. On May 7, 2026, the Indiana Health Coverage Programs (“IHCP”) announced it is seeking approval from the Centers for Medicare and Medicaid Services (“CMS”) to implement the statewide provider enrollment moratorium, beginning June 6, 2026, for both new ABA therapy group enrollments, as well as changes of ownership for existing ABA therapy agencies. If approved, the moratorium will last six months and can be extended in six-month increments. The proposed moratorium will not apply to any application received prior to June 6, 2026, or to groups attempting to add additional rendering providers for individuals providing ABA therapy services.
The requested moratorium follows on the heels of additional reforms, including new age limits for ABA therapy recipients, lifetime and weekly hour caps and billing rate cuts. These reforms follow a federal audit by the U.S. Office of Inspector General, which found that Indiana improperly paid an estimated $56 million for ABA services, prompting the State to initiate a thorough review of these programs.
The IHCP will consider limited exceptions to the moratorium, and requests for an exception may be submitted to OMPPProviderRelations@FSSA.in.gov.
If you have any questions or would like additional information on this topic, or if you would like assistance with submitting requests for an exception, please contact:
- Sarah Crosby at (317) 429-3663 or scrosby@hallrender.com;
- Liz Elias at (317) 977-1468 or eelias@hallrender.com;
- Lauren Hulls at (317) 977-1467 or lhulls@hallrender.com; or
- Your primary Hall Render contact.
Hall Render blog posts and articles are intended for informational purposes only. For ethical reasons, Hall Render attorneys cannot—outside of an attorney-client relationship—answer specific questions that would be legal advice.
