Indiana - Case Management Service — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-08-16

In Indiana, Case Management Services are a critical component of the state's Medicaid Home and Community-Based Services (HCBS) waiver programs, including the Community Integration and Habilitation (CIH), Family Supports Waiver (FSW), Traumatic Brain Injury (TBI), and the PathWays for Aging program. Approved providers deliver comprehensive assessments, person-centered service planning, referral coordination, and ongoing monitoring to ensure participants receive the full package of supports necessary to thrive in community settings.

The single biggest structural barrier to entry for prospective case management providers in Indiana is the strict enforcement of the federal and state Conflict-Free Case Management (CFCM) mandate. An agency cannot be enrolled or approved to provide case management if it also provides direct HCBS waiver services (such as residential habilitation or personal care) to the same individuals. Additionally, access to the 60+ demographic is heavily gated; providers must secure network contracts with designated Managed Care Entities (MCEs) under the PathWays for Aging program, meaning standard Medicaid enrollment alone does not guarantee the ability to bill for these services.

1. Service Definition and Scope

Case Management Services in Indiana are designed to assist Medicaid HCBS waiver participants in gaining access to needed medical, social, educational, and other services. The service is rooted in a person-centered approach, ensuring that the participant directs the planning process and that services align with their specific goals and health needs.

Providers act as the central hub for the participant's care, bridging the gap between state agencies, direct care providers, and community resources. They are responsible for continuous oversight to ensure that the services authorized are actually delivered and remain effective.

• Comprehensive Assessment: Conducting initial and annual evaluations of the participant's needs, risks, strengths, and preferences.
• Service Planning: Developing and updating the Person-Centered Service Plan (PCSP) or Individualized Support Plan (ISP) based on assessment data.
• Resource Referral: Connecting participants to both Medicaid-funded waiver services and non-waiver community resources like housing and food assistance.
• Ongoing Monitoring: Conducting required face-to-face visits (typically every 90 days) to evaluate the quality and effectiveness of the services being delivered.
• Advocacy: Educating participants on their rights, supporting informed decision-making, and assisting with grievance processes.
• Transition Support: Coordinating safe transitions for individuals moving from institutional care (like nursing facilities) into home and community-based settings.

2. Regulatory and Oversight Agencies

Oversight of Case Management Services in Indiana is divided among several divisions within the state's umbrella health agency, depending on the specific waiver population being served. Providers must interact with both programmatic divisions for certification and the central Medicaid office for billing.

Federal oversight ensures that Indiana's programs comply with national standards, particularly regarding the HCBS Settings Rule and conflict-of-interest protections.

• Indiana Family and Social Services Administration (FSSA): The umbrella state agency that oversees all Medicaid and HCBS programs in Indiana (https://www.in.gov/fssa/).
• Division of Disability and Rehabilitative Services (DDRS): The FSSA division that manages the CIH and FSW waivers through its Bureau of Disabilities Services (https://www.in.gov/fssa/ddrs/).
• Division of Aging (DA): The FSSA division responsible for older adult programs, including oversight of the PathWays for Aging managed care program (https://www.in.gov/fssa/da/).
• Office of Medicaid Policy and Planning (OMPP): The FSSA division that administers Medicaid reimbursement, manages the IHCP provider enrollment process, and oversees HCBS certification (https://www.in.gov/fssa/ompp/).
• Centers for Medicare & Medicaid Services (CMS): The federal agency providing oversight to ensure Medicaid-funded Case Management meets the HCBS Settings Rule and conflict-free requirements (https://www.cms.gov/).

3. Gatekeeping Prerequisites: Who Can Even Apply

Indiana imposes strict structural preconditions that block applicants before an application is even reviewed. The state does not accept applications from entities that cannot prove structural independence from direct service provision.

Furthermore, access to specific waiver populations is gated by managed care contracting requirements or state certification limits, meaning a provider cannot simply enroll as a Medicaid provider and immediately begin billing for all case management services.

• Conflict-Free Case Management (CFCM) Mandate: An applicant is structurally blocked from approval if they intend to provide both case management and direct HCBS waiver services (e.g., personal care, residential habilitation) to the same participant.
• PathWays for Aging MCE Contracting: To serve the 60+ waiver population, providers must successfully contract and credential with designated Managed Care Entities (Anthem, Humana, or UnitedHealthcare); IHCP enrollment alone is insufficient.
• BDS Case Management Organization (CMO) Certification: To serve the CIH and FSW waivers, agencies must be explicitly approved as a designated Case Management Organization by the Bureau of Disabilities Services, which may utilize Request for Services (RFS) or specific certification windows.
• Business Registration: The applicant must be a legally formed business entity registered and in good standing with the Indiana Secretary of State.
• Federal Identifiers: The agency must possess a Type 2 National Provider Identifier (NPI) and a federal Employer Identification Number (EIN) prior to initiating the state application.

4. Licensure and Certification Requirements

Indiana does not issue a traditional facility license for Case Management agencies. Instead, providers must obtain HCBS Waiver Certification from the applicable FSSA division (OMPP, Division of Aging, or DDRS) before they are permitted to enroll in Medicaid.

This certification process acts as the state's quality assurance gate, requiring agencies to prove they have the operational policies, insurance, and financial stability to manage vulnerable populations safely.

• HCBS Waiver Certification: Required approval obtained via the OMPP HCBS Certification Portal or DDRS provider approval process prior to Medicaid enrollment.
• Targeted Policy Submission: Applicants must submit specific, standalone operational policies (e.g., incident reporting, person-centered planning) rather than a single massive operational manual.
• Liability Insurance: Submission of active policies or official quotes for general and professional liability insurance.
• Financial Status Compliance: Demonstration of financial stability in accordance with Indiana Administrative Code 460 IAC 6-11.
• Settings Rule Attestation: A signed document certifying the agency's compliance with the federal HCBS Settings Rule and conflict-free care coordination requirements.
• Secretary of State Documentation: Proof of active business status, such as Articles of Incorporation or a Certificate of Existence.

5. Medicaid Provider Enrollment

Once HCBS Waiver Certification is granted by FSSA, the agency must formally enroll in the Indiana Health Coverage Programs (IHCP). This step establishes the agency's ability to bill the state's Medicaid Management Information System (CoreMMIS).

Enrollment is conducted entirely online through the IHCP Provider Healthcare Portal, and providers must link their FSSA certification to their Medicaid profile.

• Enrollment System: Applications must be submitted through the IHCP Provider Healthcare Portal (https://portal.indianamedicaid.com).
• Provider Type and Specialty: Agencies typically enroll under Provider Type 32 (Waiver Provider) or Provider Type 13 (Case Manager), depending on the specific waiver taxonomy.
• Application Fee: Applicants are subject to the federal Medicaid institutional application fee (approximately $709) unless they provide proof of payment to Medicare or another state's Medicaid program.
• Out-of-State Providers: While IHCP allows out-of-state enrollment for some specialties, strict documentation requirements and prior authorization limits apply if the agency is not physically located in Indiana.
• EFT Enrollment: Mandatory setup of Electronic Funds Transfer for direct deposit of Medicaid reimbursements.
• Revalidation: Providers must revalidate their IHCP enrollment every 3 to 5 years to maintain active billing privileges.

6. Staffing, Training and Background Checks

Indiana Administrative Code (e.g., 460 IAC 6-14-5) sets strict minimum qualifications for individuals employed as Medicaid case managers. Agencies are responsible for maintaining comprehensive credentialing files for every staff member.

Before any client contact occurs, staff must clear state and national background checks and complete mandatory state-sponsored training modules.

• Educational Minimums: Case managers must hold a Bachelor's degree in a human services field (such as social work, psychology, or sociology) or possess a valid Indiana Registered Nurse (RN) license.
• Criminal Background Checks: Mandatory Indiana State Police limited criminal history check and national sex offender registry check prior to employment (460 IAC 6-10-5).
• OIG Exclusion Screening: Agencies must screen all staff monthly against the federal List of Excluded Individuals/Entities (LEIE) to ensure they are not barred from Medicaid participation.
• CPR and First Aid: All client-facing staff must maintain valid, unexpired certification in CPR and First Aid.
• State-Mandated Training: Completion of required FSSA/BDS training modules on person-centered planning, incident reporting, and waiver service standards.
• Tuberculosis (TB) Testing: Staff must provide proof of a negative TB test or appropriate medical clearance prior to conducting face-to-face participant visits.

7. Documentation, Policies and Records

During the HCBS Certification process, FSSA requires agencies to upload specific, clearly labeled policies. Failure to separate these policies or uploading generic templates with another agency's name will result in immediate rejection.

Once operational, agencies must maintain rigorous participant records that tie directly to billed claims, ensuring all services are documented in accordance with state standards.

• Person-Centered Planning Policy: Written procedures detailing how the agency develops, updates, and monitors the PCSP/ISP based on participant-driven goals.
• Incident Reporting (IR) Protocol: A strict policy for reporting allegations of abuse, neglect, and exploitation to the state's automated IR system within 24 hours of discovery.
• Conflict-Free Mitigation Plan: Documented safeguards demonstrating exactly how the agency prevents conflicts of interest in service planning and referral.
• Grievance Procedure: A formal, written process provided to participants explaining how to file complaints against the agency without fear of retaliation.
• Record Retention Policy: Procedures ensuring that all participant records, case notes, and billing documentation are securely retained for a minimum of 7 years.
• HIPAA Compliance Plan: Comprehensive policies safeguarding Protected Health Information (PHI) during field visits, electronic communications, and record storage.

8. Billing, Rates and Claims

Reimbursement for Case Management Services in Indiana depends on the waiver program. DDRS waivers typically utilize a fee-for-service model billed through the state's CoreMMIS, while the PathWays for Aging program requires billing through the respective Managed Care Entities.

All billed units must be explicitly authorized on the participant's Notice of Action (NOA) and supported by detailed, signed case notes.

• Fee-for-Service Billing: Claims for CIH and FSW waivers are submitted directly to the state via the IHCP Provider Healthcare Portal or an approved clearinghouse.
• Managed Care Billing: Claims for PathWays for Aging participants must be submitted to the specific MCE (Anthem, Humana, or UnitedHealthcare) that the participant is enrolled with.
• Unit Measurement: Services are typically billed in 15-minute increments (using specific HCPCS codes like T1016) or as a monthly capitated milestone, depending on the waiver's rate schedule.
• Prior Authorization Requirement: Providers cannot bill for services that exceed the units authorized on the participant's approved state Notice of Action (NOA).
• Documentation Tie: Every billed claim must be backed by a dated case note that includes the start and stop time, the specific waiver goal addressed, and the signature of the case manager.
• Third-Party Liability (TPL): Providers must verify if the participant has other insurance that might cover care coordination before billing Medicaid as the payer of last resort.

9. Approval Sequence and Timeline

Becoming a fully approved and billing Case Management provider in Indiana is a multi-step process that spans several state systems. Agencies should expect the end-to-end process to take between 3 to 6 months.

Providers cannot skip steps; Medicaid enrollment cannot begin until FSSA certification is secured, and managed care contracting cannot begin until Medicaid enrollment is active.

• Step 1: Corporate Formation: Register the business with the Indiana Secretary of State and obtain an EIN and NPI (1 to 2 weeks).
• Step 2: FSSA HCBS Certification: Submit required policies, insurance quotes, and attestations to the OMPP Certification Portal or DDRS for waiver approval (30 to 60 days).
• Step 3: IHCP Enrollment: Submit the Medicaid provider enrollment application via the IHCP Portal, attaching the approved FSSA certification (30 to 45 days).
• Step 4: MCE Contracting (If Applicable): Apply for network participation and credentialing with Anthem, Humana, and UnitedHealthcare for the PathWays program (60 to 90 days).
• Step 5: Readiness Review: Complete any final state or MCE readiness reviews and system trainings before accepting participant referrals.

10. Common Denials and Survey Findings

The Indiana OMPP HCBS Certification Portal utilizes a strict initial review process. Applications are frequently set to expire or are outright rejected due to administrative carelessness rather than a lack of qualifications.

Post-enrollment, state surveys and audits frequently penalize agencies for failing to maintain continuous documentation or missing mandatory face-to-face monitoring timelines.

• Document Dumping: Uploading full, unindexed operational manuals multiple times instead of the specific, requested policy document (results in automatic application expiration).
• Name Mismatches: Submitting policies that contain a different agency's name (due to copying templates) or having a DBA on the application that does not match the IRS W-9.
• Expired Documents: Uploading background checks, professional licenses, or insurance quotes that have expired by the time the application is reviewed.
• Blank Forms: Submitting blank organizational charts or unsigned attestation forms into the certification portal.
• Missing Face-to-Face Visits: Audit findings for failing to conduct and document the required 90-day in-person monitoring visits with waiver participants.
• Conflict of Interest Violations: Survey citations for steering participants toward direct care agencies where the case management agency has an undisclosed financial or familial relationship.

11. Key Contacts and Resources

Prospective providers must navigate several state portals and should rely on official state guidance for the most current forms and manuals. The IHCP Provider Relations consultants are available to assist with enrollment hurdles.

For managed care contracting, providers must reach out directly to the network relations departments of the respective MCEs.

• IHCP Provider Healthcare Portal: The central hub for Medicaid enrollment and fee-for-service claims (https://portal.indianamedicaid.com).
• FSSA OMPP HCBS Certification Process: Guidelines and portal access for initial waiver certification (https://www.in.gov/fssa/ompp/hcbs-certification-process/).
• FSSA Division of Disability and Rehabilitative Services (DDRS): Information on CIH and FSW waiver standards (https://www.in.gov/fssa/ddrs/).
• Indiana PathWays for Aging: Official state page for the 60+ managed care waiver program (https://www.in.gov/pathways/).
• IHCP Provider Customer Assistance: Phone support for enrollment and billing questions at 800-457-4584.
• Anthem Indiana Medicaid Provider Network: Contracting and credentialing for PathWays (https://providers.anthem.com/indiana-provider/home).

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