Indiana Imposes Six-Month Enrollment Freeze for New ABA Providers, Seeks to Control Costs

The Moratorium

INDIANAPOLIS – Indiana’s Family and Social Services Administration froze enrollment of new ABA provider agencies starting June 6, 2026, for at least six months, according to an FSSA announcement on June 2. CMS formally approved the state’s request after determining that new ABA agency enrollments represent “a significant potential risk for fraud, waste, or abuse,” FSSA said.

The moratorium was authorized under 42 CFR 455.470, the federal regulation under which a state Medicaid agency, with CMS concurrence, may impose a temporary enrollment freeze on provider types they deem a significant risk of fraud. CMS used the same legal framework on May 13 to freeze home health agency and hospice enrollments nationwide, according to a Federal Register notice published May 15.

The freeze covers new ABA provider agencies and changes of ownership for existing agencies. Individual rendering practitioners, including registered behavior technicians (RBTs) and BCBAs, may still enroll. Applications received before June 6 will be processed, according to FSSA.

“Indiana has seen an incredible surge in ABA spending over the past several years, a trend that raises concerns about sustainability and program integrity.” – Eric Miller, Deputy Secretary, Indiana FSSA (June 2026)

The Spending Surge That Drove It

The moratorium caps a year of escalating enforcement. Indiana’s Medicaid ABA spending grew from $21 million in 2017 to $611 million in 2023, according to the state’s ABA Working Group report, according to figures FSSA provided to the Indiana Capital Chronicle. The state paid providers 40% of whatever they billed, a reimbursement structure that incentivized high charges. Piece by Piece Autism Centers, one provider highlighted in a March 2026 Wall Street Journal investigation, billed $640 per hour and collected $29 million for 84 patients in 2023 alone, approximately $340,000 per child, according to WSJ data reported by the Indiana Capital Chronicle.

After the Holcomb administration set lower reimbursement rates, spending dropped to $445 million in 2024, the Indiana Capital Chronicle reported. But as of January 2026, FSSA slides showed the program still cost upwards of $35 million per month, serving more than 6,000 Medicaid enrollees.

A December 2024 HHS Office of Inspector General audit found that Indiana made at least $56.6 million in improper fee-for-service Medicaid ABA payments and an additional $76.7 million in potentially improper payments for 2019 and 2020, according to the OIG report. All 100 sampled enrollee-months contained payments for at least one claim line the OIG classified as improper or potentially improper.

The number of ABA provider agencies in Indiana grew 25% from Q1 2023 to Q1 2025, reaching more than 320 locations, according to ABA Working Group data reported by the Indiana Capital Chronicle in November 2025.

Reform Package and Access Concerns

The moratorium is one element of a broader overhaul. Governor Mike Braun’s Executive Order 25-31, issued in February 2025, created an ABA Working Group led by FSSA Deputy Secretary Eric Miller and Indiana 211 Director Tara Morse. The group’s recommendations fed into IHCP Bulletin BT202627, which took effect April 1, 2026, and imposed a 6% rate cut on all non-group ABA services, with an additional 4% cut on all ABA procedure codes, including group services, scheduled for April 2027, according to Hall Render.

The bulletin also set a 4,000-hour lifetime cap on comprehensive ABA therapy (16,000 billing units), weekly hour caps by ASD level (30, 32, and 38 hours for Levels 1, 2, and 3 respectively), and an age restriction ending Medicaid ABA reimbursement for members over 21 on October 1, 2026, according to FSSA and Hall Render. Under a separate bulletin (BT202646), Indiana requires all ABA agencies to obtain accreditation from a CASP-affiliated body, ACQ or BHCOE, by October 1, 2027; providers must submit documentation that they have started the accreditation process by August 1, 2026.

Kim Dodson, CEO of the Arc of Indiana, said in a March 12 statement that “certain bad actors have taken advantage of weak oversight and flawed reimbursement structures to generate extraordinary payments through excessive or inappropriate billing practices.” She also warned that the ABA crackdown broadly “could hurt services for those who really need it.” FSSA left an exception for accredited providers in areas with demonstrated need.

Indiana’s action lands as other states tighten ABA Medicaid controls. Nebraska cut rates by 28% to 79% depending on the service, while New York enacted a phased 25% reduction.

AT A GLANCE

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