Issue 1: FBA now required, peer-to-peer reviews ended, and the moratorium clock

Issue 1 · Indiana Medicaid ABA · sources checked Oct 31, 2026

Welcome to the first issue. Every item below links to the official IHCP bulletin, plan notice or board page it came from. I checked IHCP's bulletin list on Oct 31, 2026: the newest ABA-specific bulletins are dated Sep 29, and none has been published since.

What to act on

1. Peer-to-peer reviews ended Nov 1 for Traditional Medicaid prior authorization. Scheduling ended Oct 31. From Nov 1, fee-for-service PA determinations go through administrative review and appeal only. Existing review and appeal processes and timelines are unchanged. IHCP asks providers to update internal workflows and tell staff. IQ criteria in the Acentra workflow do not guarantee approval. BT2026161 (Sep 29)
2. A complete functional behavior assessment (FBA) is required for every behavior targeted by a BIP, effective Oct 29. Required: at least one function-based indirect assessment (QABF, FAST, MAS, MARS, PBQ or FAI) with the parent/guardian and/or RBT, compiled in a visual graph with the original responses included; ABC data for the target behavior; triggers and precursors if applicable; and a hypothesized function statement that references both. The FBA must be refreshed with new indirect-assessment results, recent ABC data and an updated function statement at each reauthorization. Whether a functional analysis is needed is the provider's call; if one is done, tools and results go in the treatment plan. BT2026162 (Sep 29)
3. "Statement of need" and "referral" now mean the same thing. Required at the start of services if the diagnostic evaluation (CDE) is more than a year old; at reauthorization when it turns a year old; and with a new PA after a six-month gap in services (each time gaps repeat). It does not need to be resubmitted once provided, and is not needed every six months, though reassessment and an updated treatment plan are still due at least every six months. It must come from a doctoral-level HSPP psychologist, licensed physician, APRN or physician assistant. A BCBA or BCaBA cannot write it. BT2026160 (Sep 29)
4. Naps: age-appropriate nap time must be in the treatment plan. Providers must follow American Academy of Pediatrics sleep guidance for the member's age, in coordination with parents/guardians, and cannot prevent a nap because it is nonbillable time. If naps become necessary mid-authorization, the plan must record nap duration, the date naps became a consistent need, any titration dates and the date they stop, and explain lower 97153 utilization. Members may not be kept awake, or woken by being physically moved, forced to engage or tickled. BT2026159 (Sep 29)
5. Caregiver coaching: ask for 12 to 18 hours per six-month authorization. The 12-hour minimum is prorated for shorter authorizations. You may request fewer only with documented barriers (for example custody or foster placement, serious medical circumstances, hardship, emergencies, legal restrictions) and evidence of reasonable efforts such as flexible scheduling and telehealth. A barrier alone does not justify a reduction. Hours above 18 can be requested when medically necessary. BT2026136 (Aug 18)
6. BASC-4 only for the parent questionnaire since Oct 1. BASC-3 PRQ and BASC-4 were both accepted until Oct 1, 2026. After that only BASC-4 is accepted. IHCP also set a general rule: when a clinical assessment tool is updated, both versions are allowed for six months from the release date, then the current version is expected. BT2026123 (Jul 23)

Already in force since April: audit against these

• Supervision at 1:8, measured monthly per member. At least one hour of clinical case supervision per eight hours of technician-delivered 97153/97154 services for each member each month, subject to claim audit and postpayment review. Member-specific, not pooled across technicians or members. Billable and nonbillable case supervision count; general staff management does not. Proportional if a member gets fewer than eight hours. Synchronous telehealth supervision (modifier 95) is allowed but should supplement in-person oversight. BT202662 (Apr 28)
• Rates and billing since Apr 1, 2026. 6% max-fee cut on nongroup ABA codes. Group codes 97154/97157/97158 stratified by group size with modifiers U4 (2), U6 (3) and U8 (4 to 8). 97153 can now be rendered by RBTs (U1), BCaBAs (U2), and BCBAs, BCBA-Ds and HSPPs (U3). BT202627 (Feb 26)
• 4,000-hour lifetime cap on comprehensive ABA, with modifier UA. Up to 4,000 hours (16,000 units) of comprehensive ABA per member for dates of service from Apr 1, 2026, then up to 15 hours a week of targeted ABA; further comprehensive care is reviewed for medical necessity under EPSDT. Comprehensive services need modifier UA on the PA and the claim (not on 97155/97156). BT202627
• Members 21 and older: no longer covered for dates of service on or after Oct 1, 2026. ABA is covered exclusively through EPSDT. A transition window ran Apr 1 to Sep 30, 2026. BT202627

Calendar

Managed care

MHS (Managed Health Services) received OMPP approval, effective Mar 26, 2026, to close its ABA network statewide; its notice was posted Jul 23. That notice is about prior authorization requirements for non-participating providers, so check MHS's network-status page before scheduling a member. I have not verified the status at other managed-care plans. If you have a notice from one, reply and I will check it for a future issue. MHS notice

What should Issue 2 cover? Reply with the question your billing or clinical team keeps asking.

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