Indiana - Autism Service — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-09-10
The Indiana Family and Social Services Administration (FSSA) covers Applied Behavior Analysis (ABA) and related autism-specific interventions primarily through the Early and Periodic Screening, Diagnostic and Treatment (EPSDT) benefit for members under age 21, and as Behavioral Support Services under the Family Supports Waiver (FSW) and Community Integration and Habilitation (CIH) Waiver. The Indiana Professional Licensing Agency (IPLA) Behavioral Health and Human Services Licensing Board issues the mandatory state license required for all Board Certified Behavior Analysts (BCBAs) operating in the state.
Approval requires individual practitioners to hold this active IPLA licensure before submitting a Type 11 Behavioral Health Provider enrollment application via the Indiana Health Coverage Programs (IHCP) Provider Healthcare Portal. Group practices must subsequently secure credentialing and contracts with individual Managed Care Entities (MCEs) to receive reimbursement for the majority of Medicaid beneficiaries enrolled in Hoosier Healthwise, Hoosier Care Connect, or the Healthy Indiana Plan.
1. Service Definition and Scope
In Indiana, ABA therapy is defined as the design, implementation, and evaluation of environmental modifications, using behavioral stimuli and consequences, to produce socially significant improvement in human behavior. For Medicaid members under 21, these services are authorized under EPSDT when deemed medically necessary following a Comprehensive Diagnostic Evaluation (CDE).
For adult waiver participants, similar interventions are billed as Behavioral Support Services under the FSW or CIH waivers, focusing on training, supervision, and behavioral intervention plans to integrate individuals into the community.
- Target Population: Medicaid members under age 21 with an autism spectrum disorder diagnosis (for EPSDT ABA) or individuals on the FSW/CIH waivers.
- Covered Services: Behavioral identification assessment, observational behavioral follow-up assessment, adaptive behavior treatment by protocol, and family adaptive behavior treatment guidance.
- Excluded Services: Academic tutoring, vocational training, and services that are strictly custodial or respite in nature.
- Delivery Settings: Services may be delivered in the member's home, a clinic, or community settings, provided the setting is conducive to the treatment plan.
- Telehealth: Permitted for specific billing and group providers under a "telehealth-only" designation if they meet IHCP criteria and maintain Indiana licensure.
2. Regulatory and Oversight Agencies
The Indiana Family and Social Services Administration (FSSA) Office of Medicaid Policy and Planning (OMPP) administers the Medicaid program and oversees provider enrollment. The Indiana Professional Licensing Agency (IPLA) regulates the professional practice of behavior analysts.
Managed Care Entities (MCEs) handle the day-to-day administration, prior authorizations, and claims processing for the majority of Medicaid members receiving ABA services.
- FSSA Office of Medicaid Policy and Planning (OMPP): https://www.in.gov/fssa/ompp/
- Indiana Professional Licensing Agency (IPLA): https://www.in.gov/pla/
- IHCP Provider Healthcare Portal: https://portal.indianamedicaid.com/hcp/provider
- Anthem Indiana Medicaid: https://providers.anthem.com/indiana-provider
- Humana Indiana Medicaid: https://www.humana.com/provider/medical-resources/indiana-medicaid
- UnitedHealthcare Community Plan of Indiana: https://www.uhcprovider.com/en/health-plans-by-state/indiana-health-plans/in-comm-plan-home.html
3. Gatekeeping Prerequisites: Who Can Even Apply
Indiana does not require a Certificate of Need (CON) or a Request for Proposals (RFP) procurement process to become an ABA provider. The state operates an open enrollment model for IHCP.
The absolute structural precondition for enrollment is that the supervising provider must hold an active Behavior Analyst license issued by the IPLA. Without this license, the IHCP Provider Healthcare Portal will automatically reject a Type 11 Behavioral Health Provider application for ABA specialties.
- Professional Licensure: Must possess an active Behavior Analyst license from the IPLA.
- National Provider Identifier (NPI): Must obtain an NPI from the NPPES registry matching the exact legal name and taxonomy of the applicant.
- Physical Location: Must have a physical service location address (no PO Boxes or UPS stores), unless applying under the specific "Telehealth-Only Attestation".
- W-9 Form: Must possess a current IRS W-9 form that exactly matches the legal business name or registered DBA.
- Secretary of State Registration: Corporate entities must be registered and in good standing with the Indiana Secretary of State.
4. Licensure and Certification Requirements
The IPLA's Behavioral Health and Human Services Licensing Board issues the Behavior Analyst license. Applicants must demonstrate current certification by the Behavior Analyst Certification Board (BACB).
Out-of-state providers seeking to provide telehealth services to Indiana Medicaid members must also obtain this IPLA license and may apply for a Telemedicine Provider Certification.
- BACB Certification: Must hold current, active certification as a Board Certified Behavior Analyst (BCBA) or BCBA-D.
- Criminal Background Check: Must complete a fingerprint-based national criminal history background check.
- Application Fee: Must pay the IPLA application fee (typically $50, subject to legislative updates).
- Jurisprudence Examination: Must pass the Indiana jurisprudence examination covering state laws and rules.
- License Renewal: Licenses must be renewed biennially, requiring proof of ongoing BACB certification.
5. Medicaid Provider Enrollment
Providers enroll through the IHCP Provider Healthcare Portal. ABA providers typically enroll as Type 11 (Behavioral Health Provider).
Group practices must enroll the group entity first, and then link individual licensed rendering providers to the group's IHCP profile.
- Provider Type: Type 11 (Behavioral Health Provider).
- Application Fee: Providers with certain specialties (e.g., 611 group only, 615 group and billing only) must pay an application fee during enrollment or revalidation.
- Interactive PDF Option: While the portal is preferred, IHCP offers an interactive PDF provider packet that can be mailed to PO Box 50443, Indianapolis, IN 46250-0418.
- Telehealth-Only Attestation: Billing or group providers performing only telehealth may enroll under a "telehealth-only" designation if they maintain Indiana licensure.
- Out-of-State Questionnaire: Out-of-state providers must complete this section to justify in-state enrollment status if not in a designated border area.
6. Staffing, Training and Background Checks
ABA services are typically delivered in a tiered model. The licensed BCBA designs and supervises the treatment plan, while Registered Behavior Technicians (RBTs) implement the direct line therapy.
All staff with direct member contact must undergo criminal history checks in accordance with Indiana Administrative Code (460 IAC 6-10-5 for waiver services).
- Supervising Professional: Must be an IPLA-licensed Behavior Analyst.
- Direct Care Staff: Must hold active RBT certification from the BACB and receive ongoing supervision per BACB standards.
- Criminal History: Documented proof of a limited criminal history investigation from the Indiana central repository is required.
- CPR/First Aid: Direct care staff must maintain current CPR and First Aid certifications.
- Abuse Registry Check: Providers must check the Indiana State Department of Health (ISDH) abuse registry prior to employment.
7. Documentation, Policies and Records
IHCP requires rigorous documentation to support the medical necessity of ABA services. A Comprehensive Diagnostic Evaluation (CDE) by a qualified healthcare professional is required to initiate services.
Treatment plans must be individualized, data-driven, and updated at least every six months to demonstrate measurable progress or justify modifications.
- Comprehensive Diagnostic Evaluation (CDE): Must confirm the autism spectrum disorder diagnosis and recommend ABA therapy.
- Treatment Plan: Must include baseline data, specific measurable goals, transition/discharge criteria, and parent/caregiver training goals.
- Session Notes: Must document the date, start/stop times, specific interventions used, member response, and signature of the rendering provider.
- Supervision Logs: Must document the BCBA's supervision of RBTs in accordance with BACB requirements.
- Record Retention: Records must be maintained for a minimum of seven years and made available to FSSA or its agents upon request.
8. Billing, Rates and Claims
ABA services are billed using standard Category I and Category III CPT codes (e.g., 97151-97158). Reimbursement rates are established by OMPP and published on the IHCP Fee Schedule.
Because most members are enrolled in managed care, claims are submitted directly to the member's MCE, which may have specific billing guidelines and prior authorization requirements.
- CPT Code 97151: Behavior identification assessment, administered by a physician or other qualified healthcare professional.
- CPT Code 97153: Adaptive behavior treatment by protocol, administered by a technician under the direction of a qualified healthcare professional.
- CPT Code 97155: Adaptive behavior treatment with protocol modification, administered by a physician or other qualified healthcare professional.
- Prior Authorization: Almost universally required by MCEs prior to the initiation of treatment and for ongoing authorization periods.
- IHCP Fee Schedule: Baseline fee-for-service rates are available via the IHCP Provider Reference Materials webpage.
9. Approval Sequence and Timeline
The end-to-end process from licensure to billing can take several months. Providers must sequence their applications correctly, as IHCP enrollment cannot begin without IPLA licensure.
MCE credentialing is a separate, subsequent step that cannot be initiated until the provider has an active IHCP Provider ID.
- IPLA Licensure: Typically takes 4-8 weeks after submission of all required documents and background checks.
- IHCP Enrollment: Processing via the Provider Healthcare Portal generally takes 15-30 business days if the application is complete.
- MCE Credentialing: Can take 60-90 days per health plan after IHCP enrollment is active.
- MCE Contracting: Follows credentialing and may take an additional 30-60 days to finalize the participating provider agreement.
- Waiver Certification (if applicable): BDDS/BQIS approval for waiver services can add 30-60 days to the initial timeline.
10. Common Denials and Survey Findings
Enrollment applications are frequently rejected for administrative errors, particularly mismatches between IRS documentation and the application.
During audits or revalidation, providers often face recoupments for failing to maintain adequate session notes or failing to report changes in ownership or service locations within the required timeframe.
- W-9 Mismatch: The DBA or legal name on the application does not exactly match line 1 or 2 of the submitted IRS W-9 form.
- Missing License: Failure to attach a copy of the active IPLA professional license.
- Outdated Forms: Submitting an older version of the W-9 instead of the most current IRS version.
- Failure to Notify: Failing to notify FSSA within 10 calendar days of a change in license status or 60 days for a change in ownership/address.
- Inadequate Documentation: Session notes lacking start/stop times or failing to clearly link interventions to the approved treatment plan.
11. Key Contacts and Resources
Providers should utilize the IHCP Provider Healthcare Portal for enrollment and updates. The IHCP Provider Enrollment unit handles application processing and can be reached for status inquiries.
For licensure questions, the IPLA Behavioral Health and Human Services Licensing Board is the primary contact.
- IHCP Provider Enrollment Helpdesk: 800-457-4584
- IHCP Provider Healthcare Portal: https://portal.indianamedicaid.com/hcp/provider
- IPLA Behavioral Health Board: https://www.in.gov/pla/professions/behavioral-health-and-human-services/
- FSSA OMPP HCBS Certification: https://www.in.gov/fssa/ompp/hcbs-certification-process/
- Indiana Medicaid Provider Reference Materials: https://www.in.gov/medicaid/providers/provider-references/provider-reference-materials/
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