Indiana - Behavioral Health Services — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-09-09
The Indiana Family and Social Services Administration (FSSA) Office of Medicaid Policy and Planning (OMPP) certifies Behavioral Health Services and Behavior Management providers through the PathWays for Aging, Health & Wellness (H&W), and Traumatic Brain Injury (TBI) waivers. Providers must navigate a strict three-step sequence: obtaining OMPP HCBS Certification, enrolling with the Indiana Health Coverage Programs (IHCP), and finally completing waiver-specific enrollment by either contracting with Managed Care Entities (MCEs) or joining the Division of Disability and Rehabilitative Services (DDRS) pick list.
Applicants must secure an active professional license from the Indiana Professional Licensing Agency (IPLA) or agency-level certification from the Division of Mental Health and Addiction (DMHA) before initiating the OMPP HCBS Certification Portal application. Once IHCP-enrolled, providers serving the PathWays for Aging program cannot bill the state directly; they must successfully execute network contracts with Anthem, Humana, or UnitedHealthcare to receive reimbursement.
1. Service Definition and Scope
In Indiana, behavioral health services under Medicaid encompass assessment, therapy, positive behavior support, and crisis response. Under the HCBS waivers, this is often categorized under specific service lines such as Caregiver Coaching and Behavior Management (Waiver Service A22) or traditional behavioral health therapy.
These services are designed to support individuals in their homes or community settings rather than institutional environments, adhering strictly to the CMS Final Settings Rule. Services may be delivered by independent licensed practitioners, Community Mental Health Centers (CMHCs), or specialized ABA therapy groups.
- Service Categories: Behavioral Health Services, Caregiver Coaching and Behavior Management (A22), and ABA Therapy.
- Scope of Practice: Includes mental health counseling, behavioral assessments, crisis intervention, and positive behavior support plan development.
- Target Population: Medicaid members enrolled in the PathWays for Aging, Health & Wellness (H&W), or Traumatic Brain Injury (TBI) waivers.
- Delivery Setting: Must be provided in home and community-based settings that comply with the HCBS Final Settings Rule.
- Provider Types: Licensed independent practitioners, CMHCs, and Opioid Treatment Programs (OTPs).
2. Regulatory and Oversight Agencies
The Indiana Family and Social Services Administration (FSSA) serves as the umbrella agency for Medicaid and behavioral health oversight. Within FSSA, the Office of Medicaid Policy and Planning (OMPP) manages HCBS certification and Medicaid policy.
The Division of Mental Health and Addiction (DMHA) certifies mental health agencies, while the Indiana Professional Licensing Agency (IPLA) issues individual clinical licenses. The Indiana Health Coverage Programs (IHCP) handles the actual Medicaid provider enrollment and claims processing.
- Indiana Family and Social Services Administration (FSSA): https://www.in.gov/fssa/
- Office of Medicaid Policy and Planning (OMPP): https://www.in.gov/fssa/ompp/
- Division of Mental Health and Addiction (DMHA): https://www.in.gov/fssa/dmha/
- Indiana Professional Licensing Agency (IPLA): https://www.in.gov/pla/
- Indiana Health Coverage Programs (IHCP): https://www.in.gov/medicaid/providers/
3. Gatekeeping Prerequisites: Who Can Even Apply
Indiana enforces strict sequential prerequisites for behavioral health providers. An applicant cannot begin the Medicaid enrollment process without first holding the appropriate underlying clinical license from IPLA or facility certification from DMHA.
For HCBS waiver services, providers must pass the OMPP HCBS Certification process before applying to IHCP. Furthermore, access to the PathWays for Aging waiver population is entirely gated by managed care contracting; providers must secure network agreements with specific MCEs to operate.
- Professional Licensure: Active IPLA license (e.g., HSPP, LCSW, LMHC) or BACB certification required prior to application.
- Facility Certification: Agency providers must hold DMHA certification as a Community Mental Health Center (CMHC) or Opioid Treatment Program (OTP) if operating at the facility level.
- OMPP HCBS Certification: Mandatory prerequisite step via the OMPP Certification Portal before IHCP enrollment is permitted.
- Managed Care Contracting: PathWays for Aging providers must secure network contracts with Anthem, Humana, or UnitedHealthcare to serve members.
- Heightened Scrutiny Review: Settings located inside or adjacent to institutional facilities must pass CMS Settings Rule heightened scrutiny before OMPP certification is granted.
4. Licensure and Certification Requirements
Individual practitioners must obtain their clinical licenses through the Indiana Professional Licensing Agency (IPLA). Agencies providing comprehensive mental health services must be certified by the Division of Mental Health and Addiction (DMHA).
Providers delivering services via telehealth must also hold a Telemedicine Provider Certification from IPLA. All HCBS waiver providers must maintain active OMPP certification.
- Individual License: Issued by IPLA for psychologists (HSPP), clinical social workers (LCSW), and mental health counselors (LMHC).
- Agency Certification: Issued by DMHA for Community Mental Health Centers (CMHCs) and Opioid Treatment Programs (OTPs).
- HCBS Certification: Issued by OMPP via the OMPP Certification Portal for waiver service provision.
- Telemedicine Certification: Required from IPLA if providing behavioral health services remotely.
- Application Fee: Required for certain IHCP provider enrollments, which can be satisfied by paying the fee to Medicare or requesting a financial hardship waiver.
5. Medicaid Provider Enrollment
Providers enroll through the IHCP Provider Healthcare Portal. Behavioral health professionals typically enroll under Provider Type 11 (Behavioral Health Provider), while waiver-specific services may require enrollment under the Waiver provider classification.
The enrollment packet requires a signed Provider Agreement, a Federal W-9 form, and proof of the underlying IPLA license or DMHA certification.
- Enrollment Portal: IHCP Provider Healthcare Portal.
- Provider Classification: Provider Type 11 (Behavioral Health Provider) or Waiver Provider.
- Required Forms: IHCP Provider Agreement and Federal W-9 form.
- National Provider Identifier (NPI): Required for each specific service location.
- Medicare Enrollment: Required to be reported on the IHCP application if the provider is enrolled in Medicare.
6. Staffing, Training and Background Checks
Direct care staff and clinicians must meet strict qualification standards set by IPLA or the Behavior Analyst Certification Board (BACB). Interns may provide services only within a CMHC setting and must bill under the CMHC's NPI.
All HCBS providers must complete fingerprinting and background checks through the Indiana Central Repository. Direct support professionals must also complete Tuberculosis (TB) testing.
- Clinical Qualifications: Must hold active status as an HSPP, LCSW, LMHC, LMFT, BCBA, or BCBA-D.
- Intern Provision: Allowed exclusively in CMHC settings (provider type 11, specialty 111) when billed under the facility NPI.
- Background Checks: Fingerprint and limited criminal history check through the Indiana Central Repository required within 60 days of hire.
- Health Screening: Tuberculosis (TB) testing required for staff providing direct, in-person services.
- Specialized Training: DATA 2000 waiver training provided by SAMHSA required for providers prescribing buprenorphine.
7. Documentation, Policies and Records
The OMPP Certification Portal requires the upload of specific, targeted policy documents. Uploading massive, full operational manuals multiple times will result in application rejection.
Providers must ensure that all uploaded policies, organizational charts, and insurance quotes exactly match the agency name listed on the application.
- Liability Insurance: Quotes or templates for the Liability Insurance Policy must be uploaded during OMPP certification.
- Organizational Chart: A completed, non-blank organizational chart is required.
- Targeted Policies: Specific policies required by the OMPP Certification Portal must be uploaded individually; full manuals are rejected.
- Name Consistency: Policies containing a different agency's name from the associated application will cause immediate denial.
- Settings Rule Compliance: Documentation proving the service setting integrates individuals into the greater community.
8. Billing, Rates and Claims
Reimbursement for behavioral health services is governed by Indiana Administrative Code 405 IAC 5-20-1 and the Indiana Medicaid State Plan. Claims for traditional Medicaid are submitted via the IHCP portal, while PathWays claims go to the respective MCE.
Services such as crisis response or ABA therapy utilize standard HCPCS codes (e.g., H2011) and often require prior authorization based on the member's level of care assessment.
- Billing System: IHCP Provider Healthcare Portal for fee-for-service; MCE portals for PathWays members.
- Regulatory Authority: Subject to limitations specified in Indiana Administrative Code 405 IAC 5-20-1.
- Procedure Codes: Standard CPT/HCPCS codes (e.g., H2011 for crisis response) as listed in the IHCP fee schedule.
- Prior Authorization (PA): Required for extended therapy or specific behavioral interventions as dictated by the IHCP or MCE.
- ABA Billing: Services rendered by a BCaBA or RBT must be billed under the NPI of the IHCP-enrolled supervising ABA therapist.
9. Approval Sequence and Timeline
The approval process follows a strict three-step sequence: OMPP Certification, IHCP Enrollment, and Waiver Program Enrollment. Providers receive feedback during the initial OMPP review if document corrections are needed.
IHCP enrollment processing takes at least 15 business days. After IHCP approval, providers must complete MCE credentialing or contact BDS Provider Services to be added to the waiver pick list.
- Step 1: OMPP Certification via the OMPP Certification Portal.
- Step 2: IHCP Provider Enrollment (allow at least 15 business days for processing before checking status).
- Step 3 (PathWays): Credentialing and contracting with Anthem, Humana, or UnitedHealthcare.
- Step 3 (H&W/TBI): Addition to the DDRS pick list by contacting [email protected].
- Background Check Timeline: Must be completed within 60 days of hire for new staff.
10. Common Denials and Survey Findings
OMPP frequently rejects certification applications due to administrative errors in the document upload process. The most common issues involve mismatched agency names or expired documentation.
During surveys, failure to demonstrate compliance with the HCBS Final Settings Rule, particularly for facilities subject to heightened scrutiny, will result in decertification or denial.
- Mismatched Names: Uploading policies that contain a different agency's name from the application.
- Expired Documents: Submitting expired licenses, background checks, or insurance quotes.
- Blank Uploads: Submitting blank organizational charts or required forms.
- Document Dumping: Uploading full operational manuals multiple times instead of the specific requested policy.
- Settings Rule Violations: Operating in a setting that isolates individuals or functions as an institution.
11. Key Contacts and Resources
Providers must interact with multiple portals and help desks throughout the certification and enrollment lifecycle. The IHCP Provider Enrollment Unit and the OMPP Certification Portal are the primary technical interfaces.
For waiver-specific placement, providers must coordinate with BDS Provider Services or the credentialing departments of the three PathWays MCEs.
- IHCP Provider Enrollment Unit: 800-457-4584, https://www.in.gov/medicaid/providers/
- OMPP Certification Portal: https://omppproviders.fssa.in.gov/
- BDS Provider Services: [email protected]
- Anthem Indiana Medicaid: https://providers.anthem.com/indiana-provider/patient-care/pathways-aging
- Humana Indiana Medicaid: https://www.humana.com/provider/medical-resources/indiana-medicaid
- UnitedHealthcare Indiana Community Plan: https://www.uhcprovider.com/en/health-plans-by-state/indiana-health-plans/in-comm-plan-home/how-to-join-indiana.html
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