Indiana - Autism Service — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-08-15

In Indiana, Autism Services—specifically Applied Behavior Analysis (ABA)—are delivered under the Indiana Health Coverage Programs (IHCP) by credentialed behavior analysts and technicians. These services are billed under Provider Type 11 (Behavioral Health Provider) and are designed to provide adaptive behavior treatment and protocol modification for Medicaid-enrolled children diagnosed with Autism Spectrum Disorder (ASD).

The single biggest structural barrier to entry in Indiana is a strict, federally approved moratorium on new ABA agency enrollments and ownership transfers that took effect on June 6, 2026. Compounding this barrier is a new state mandate requiring all ABA agencies to obtain third-party accreditation from the Autism Commission on Quality (ACQ) or the Behavioral Health Center of Excellence (BHCOE) to maintain their Medicaid billing privileges, effectively outsourcing the facility approval gate to private accreditors.

1. Service Definition and Scope

Indiana Medicaid defines ABA services as behavioral health interventions designed to treat Autism Spectrum Disorder. These services include direct adaptive behavior treatment delivered by technicians and protocol modifications designed and overseen by master's or doctoral-level clinicians.

The state categorizes these practitioners under specific provider specialties within the broader Behavioral Health Provider classification, ensuring that only appropriately credentialed staff deliver and bill for these highly specialized interventions.

• Provider Type: 11 (Behavioral Health Provider) is the overarching classification for ABA agencies and clinicians in Indiana.
• Specialty 615: Applied Behavior Analysis (ABA) Therapist (Masters/Doctoral or HSPP) designates the lead clinical supervisors.
• Specialty 624: Applied Behavior Analysis (ABA) Therapist (Bachelors) designates mid-level supervisors or BCaBAs.
• Specialty 625: Applied Behavior Analysis (ABA) Therapist (Registered Behavior Technician [RBT]) designates the frontline staff delivering direct treatment.
• Covered Services: Includes direct treatment (CPT code 97153) and protocol modification/supervision (CPT code 97155).

2. Regulatory and Oversight Agencies

The Indiana Family and Social Services Administration (FSSA) is the primary state agency responsible for Medicaid. Within FSSA, the Office of Medicaid Policy and Planning (OMPP) directly administers the Indiana Health Coverage Programs (IHCP).

Because Indiana does not issue a traditional facility license for ABA clinics through its Department of Health, regulatory oversight is enforced through IHCP provider enrollment rules, federal audits, and mandatory third-party accreditation bodies.

• State Medicaid Agency: Indiana Family and Social Services Administration (FSSA) oversees all Medicaid operations.
• Medicaid Division: Office of Medicaid Policy and Planning (OMPP) sets the specific coverage and reimbursement policies for ABA.
• Fiscal Agent: Gainwell Technologies manages the IHCP Provider Healthcare Portal where all enrollment and claims activities occur.
• Accreditation Oversight: Autism Commission on Quality (ACQ) and Behavioral Health Center of Excellence (BHCOE) act as the state's designated quality gatekeepers.

3. Gatekeeping Prerequisites: Who Can Even Apply

Indiana currently has an impenetrable structural barrier for new ABA businesses. Following federal audits revealing massive improper payments, CMS approved a state-requested moratorium under 42 CFR 455.470. As of June 6, 2026, IHCP will not accept any new ABA agency enrollments or process ownership transfers.

Furthermore, Indiana has instituted a hard accreditation mandate. Any agency seeking to operate must be accredited by a specific private entity, shifting the prerequisite from a state-issued license to a costly, months-long private review process.

• Agency Enrollment Moratorium: Effective June 6, 2026, IHCP halted all new ABA agency enrollments and ownership changes for a minimum of six months, as announced in [Indiana Medicaid: Providers: IHCP Bulletins](https://www.in.gov/medicaid/providers/provider-references/bulletins-banner-pages-and-reference-modules/ihcp-bulletins).
• Rendering Provider Exemption: Individual BCBAs and RBTs may still enroll as rendering providers, provided they are linking to an already active, existing ABA agency.
• Accreditation Mandate: Agencies must be fully accredited by ACQ or BHCOE by October 1, 2027, and must prove they have initiated the process by August 1, 2026, to avoid deactivation, per [Indiana Will Require Accreditation for Medicaid ABA Agencies](https://breakingnewsaba.com/policy/indiana-require-accreditation-medicaid-aba-agencies).
• Access Exception: FSSA noted a potential, undefined exception to the moratorium for accredited providers in areas with limited access to care, though specific geographic criteria have not been published.

4. Licensure and Certification Requirements

Indiana does not license ABA clinics as healthcare facilities under the Department of Health. Instead, the state relies on the national Behavior Analyst Certification Board (BACB) for individual practitioner credentialing and private accreditation for agency-level quality assurance.

To bill Medicaid, the agency must be enrolled as a group, and every individual practitioner must hold the appropriate BACB certification or state psychology license.

• Facility Licensure: None exists; Indiana does not issue a distinct state facility license for standalone ABA clinics.
• Agency Accreditation: Mandatory ACQ or BHCOE accreditation serves as the de facto facility license for Medicaid participation.
• Lead Clinician Certification: Must hold active Board Certified Behavior Analyst (BCBA) or BCBA-D certification from the BACB.
• Psychology Alternative: Providers holding a Health Service Provider in Psychology (HSPP) license from the Indiana State Psychology Board may also direct ABA services.
• Technician Certification: Frontline staff must hold and maintain an active Registered Behavior Technician (RBT) credential from the BACB.

5. Medicaid Provider Enrollment

Provider enrollment is conducted entirely online through the IHCP Provider Healthcare Portal, operated by Gainwell Technologies. ABA agencies enroll as a group (Provider Type 11), and individual clinicians enroll as rendering providers linked to that group.

Because of recent fraud and overpayment findings, ABA providers are subject to heightened scrutiny, and all individual practitioners must maintain updated credentialing profiles in CAQH ProView.

• Enrollment Portal: Applications must be submitted through the IHCP Provider Healthcare Portal managed by Gainwell Technologies.
• Credentialing Database: Individual practitioners must complete and maintain a profile in [CAQH ProView](https://proview.caqh.org/), which is pulled by Medicaid Managed Care Entities.
• NPI Structure: The agency must obtain a Type 2 (Organization) NPI, while every rendering BCBA and RBT must obtain a Type 1 (Individual) NPI.
• Specialty Selection: Agencies must explicitly select specialties 615, 624, and 625 during enrollment to bill for the full spectrum of ABA staff, as detailed in [Indiana Medicaid: Providers: 11 – Behavioral Health Provider](https://www.in.gov/medicaid/providers/provider-enrollment/complete-an-ihcp-provider-enrollment-application/11-behavioral-health-provider).
• Application Fee: Institutional providers are subject to the CMS-mandated application fee (adjusted annually) unless waived by Medicare enrollment.

6. Staffing, Training and Background Checks

Staffing requirements in Indiana strictly follow the BACB's supervisory frameworks. Agencies must ensure that RBTs receive adequate, documented supervision from a qualified BCBA or HSPP.

Because ABA providers work extensively with vulnerable pediatric Medicaid populations, comprehensive background checks and ongoing training are mandatory for all clinical staff.

• Supervision Ratios: Agencies must adhere to BACB standards, requiring BCBAs to supervise a minimum of 5% of the hours RBTs spend providing direct services per month.
• RBT Training: Technicians must complete a 40-hour training sequence, pass a competency assessment, and pass the BACB RBT exam before rendering services.
• Background Checks: National criminal history background checks are required for all owners, managing employees, and clinical staff prior to employment.
• Roster Linkage: Every rendering provider must be formally linked to the agency's IHCP group profile; services provided by unlinked staff will be denied.

7. Documentation, Policies and Records

Following a federal audit that found a 100% error rate in a sample of Indiana ABA claims, OMPP has drastically tightened documentation standards. Providers must maintain flawless clinical and timekeeping records.

For services delivered in the home or community, Electronic Visit Verification (EVV) is strictly enforced. Any mismatch between EVV data, clinical notes, and billed claims is grounds for immediate recoupment.

• EVV Mandate: Electronic Visit Verification is mandatory for in-home ABA services, requiring GPS-stamped time-in, time-out, and location data.
• Session Notes: Must be generated for every encounter, detailing the specific interventions used, patient response, and exact start/stop times matching the claim.
• Supervision Documentation: When billing CPT 97155, notes must explicitly prove the BCBA was present, observing the RBT, and actively modifying the treatment protocol.
• Treatment Plans: Must be based on standardized ASD assessments, individualized to the patient, and updated at least every six months.
• Self-Auditing: Agencies are strongly advised to conduct internal audits of 97153 and 97155 claims against EVV records to prevent state clawbacks, as noted in [Indiana Pauses New ABA Provider Enrollment](https://www.cubetherapybilling.com/indiana-pauses-new-aba-provider-enrollment).

8. Billing, Rates and Claims

ABA services in Indiana are billed in 15-minute increments using standard CPT codes. While some members are covered under fee-for-service Medicaid, the majority are enrolled in managed care programs.

Providers must secure Prior Authorization (PA) for all treatment hours beyond the initial assessment. Billing rates are set by OMPP but administered by the Managed Care Entities (MCEs).

• Direct Treatment Code: CPT 97153 is used for adaptive behavior treatment delivered by an RBT.
• Protocol Modification Code: CPT 97155 is used when a BCBA is present to modify the treatment protocol or supervise the RBT.
• Billing Units: Services are calculated and billed in 15-minute increments.
• Prior Authorization: Mandatory for ongoing therapy; providers must submit the comprehensive treatment plan to the member's MCE to secure approved hours.
• MCE Contracting: After IHCP enrollment, agencies must separately credential and contract with Indiana's MCEs (e.g., Anthem, CareSource, MDwise, MHS) to be paid for managed care members.

9. Approval Sequence and Timeline

For new agencies, the timeline is currently frozen indefinitely due to the June 2026 moratorium. No new agency applications are being accepted or processed.

For individual rendering providers joining an existing, active agency, the process remains open and typically takes 60 to 120 days from initial CAQH setup to final MCE network loading.

• Step 1 (Agency): Paused indefinitely due to the IHCP moratorium on new ABA provider enrollments.
• Step 2 (Individual Credentialing): Rendering provider obtains BACB certification, NPI, and completes CAQH ProView profile (1-3 weeks).
• Step 3 (IHCP Enrollment): Agency submits a rendering provider linkage application via the Gainwell portal (30-45 days).
• Step 4 (MCE Credentialing): Once active with IHCP, the agency submits the rendering provider to contracted MCEs for network loading (60-90 days).
• Step 5 (Accreditation): Existing agencies must submit proof of initiating ACQ or BHCOE accreditation by August 1, 2026, to avoid deactivation.

10. Common Denials and Survey Findings

Indiana ABA providers are currently operating in a high-risk audit environment. A recent HHS OIG audit flagged tens of millions of dollars in improper payments, leading to aggressive state enforcement.

Most denials and recoupments stem from administrative mismatches, failure to utilize EVV correctly, or billing for services rendered by uncredentialed or unlinked technicians.

• EVV Discrepancies: Claims are frequently denied or recouped when EVV time/location data does not perfectly align with the billed units and clinical notes.
• Supervision Deficiencies: Recoupments occur when agencies bill 97155 but lack clinical documentation proving the BCBA was actively modifying the protocol.
• Unlinked Providers: Denials occur when an RBT provides services before their IHCP rendering provider application is fully approved and linked to the group.
• Missing Accreditation: Agencies face total enrollment deactivation if they fail to meet the state's strict ACQ/BHCOE accreditation milestones.

11. Key Contacts and Resources

Providers must rely on official state portals and bulletins to navigate the rapidly changing regulatory landscape, especially regarding the moratorium and accreditation mandates.

The IHCP Provider Healthcare Portal and the official accrediting bodies are the primary touchpoints for maintaining compliance and active enrollment.

• IHCP Provider Portal: Managed by Gainwell Technologies; the central hub for all Medicaid enrollment and claims submissions.
• FSSA OMPP: The Indiana Office of Medicaid Policy and Planning, responsible for overarching Medicaid policy and rate setting.
• IHCP Bulletins: The official source for policy changes, such as BT202691 which announced the ABA moratorium.
• Autism Commission on Quality (ACQ): One of the two state-mandated accrediting bodies for ABA agencies.
• Behavioral Health Center of Excellence (BHCOE): The second state-mandated accrediting body (now operating under the same parent organization as ACQ).

See all Indiana services · Indiana Medicaid consulting · book a consultation.