Indiana's ABA agency enrollment moratorium, as of October 2026
What Indiana Medicaid's moratorium on new ABA group enrollments and ownership changes covers, who it leaves out, and what is still open before December.
- Jurisdiction:
- Indiana
- Takes effect:
What changed, with the status first
Indiana Medicaid's moratorium on enrolling new applied behavior analysis (ABA) agencies is in effect. Indiana Health Coverage Programs (IHCP) Bulletin BT202692, dated June 4, 2026, says the Centers for Medicare & Medicaid Services approved the state's request, that the moratorium took effect June 6, 2026, and that it runs for "an initial period of six months," which the IHCP "may continue to extend" in six-month increments. It blocks brand-new ABA group enrollments and changes of ownership for existing ABA therapy agencies. It does not apply to individual rendering providers.[1] The federal authority is 42 CFR 455.470.[2] As of October 10, 2026, the IHCP bulletins page lists bulletins through October 8, 2026, and I found none there that extends, ends, or changes the moratorium.[3] Six months from June 6 is early December. None of the documents prints an end date.
Why the state could do this
The federal rule lets a state Medicaid agency impose a temporary moratorium on new providers that the state identifies as a significant risk for fraud, waste, or abuse and that the HHS Secretary has identified as high risk. Before it does, the state must determine that the moratorium would not adversely affect beneficiaries' access to medical assistance, notify the Secretary in writing, and obtain the Secretary's concurrence.[2] FSSA's press release says CMS approved Indiana's request "after determining that new ABA agency enrollments represent a significant potential risk for fraud, waste, or abuse."[4]
Who it affects
New agencies. The moratorium "will prevent enrollment for brand-new ABA group enrollments."[1]
Agencies changing hands. It also covers "changes of ownership for existing ABA therapy agencies."[1] If a sale or merger in progress involves an IHCP change of ownership, this is the sentence to read with counsel.
Not individual clinicians. "The moratorium will not apply to rendering provider enrollment requests for individuals providing ABA therapy services."[1]
A narrow way back in. The IHCP "will consider limited exceptions" to ensure member access "to areas in need," and an agency seeking one "must be accredited per the requirements described in IHCP Bulletin BT202646."[1] That bulletin recognizes two accrediting bodies, the Autism Commission on Quality (ACQ) and the Behavioral Health Center of Excellence (BHCOE).[5] Exception requests go by email to [email protected].[1]
What none of it touches. These are IHCP enrollment documents and say nothing about commercial plans.
Where two of the documents disagree
The proposal bulletin, BT202667, dated May 7, 2026, now carries an update banner: "The moratorium will apply to applications received prior to June 6, 2026."[6] FSSA's June 2 press release says the reverse: "applications received before June 6, 2026, will be processed as usual."[4] The approval bulletin does not mention pending applications at all.[1]
To be clear, I cannot tell you which statement governs. The banner is undated, so the documents alone do not show which came later.
What to check this month
The calendar. Put early December on it. Under the federal rule, the state may extend a moratorium in six-month periods and "must document in writing the necessity for extending the moratorium."[2] That is not a promise of a public notice on a set date, so subscribe to IHCP email notices.
Any pending application. Find the submission date and the confirmation for any agency enrollment or change of ownership filed before June 6, then ask IHCP Customer Assistance at 800-457-4584, in writing where you can, which of the two statements applies to it.[1]
Expansion plans. The bulletins do not say whether an existing, enrolled agency opening a new location counts as a "brand-new ABA group enrollment." Ask IHCP before that answer gets built into a lease or a hiring plan. If the location was already announced on social media, check that the posted timeline still matches the enrollment one. The posts in our earlier piece on what a clinic can post without showing clients do not depend on an opening date.
Accreditation records. BT202646 required every currently enrolled ABA group to send documentation by August 1, 2026 showing it had started the accreditation process, says that failure "will result in the enrollment being deactivated," and requires accreditation to be complete by October 1, 2027. A previous BHCOE accreditation "will be accepted until an agency's reaccreditation with ACQ."[5] Check that the submission is on file and confirmed, and where the agency stands against the 2027 date.
The other ABA bulletins. The index lists BT2026123 on documentation and behavior assessment for treatment plans (July 23), BT2026136 on caregiver coaching and training requirements (August 18), and three bulletins dated September 29 on functional behavior assessments, statement of need and referrals, and sleeping and naps during therapy.[3] Those are separate instruments, and this post does not describe them.
What is still open
Extension. Whether the IHCP extends the moratorium past the first six months, and for how long. FSSA said it "may request moratorium extensions as necessary."[4]
Exceptions. How they are decided. The bulletin says "limited exceptions" and "areas in need," and publishes no criteria and no decision timeline.[1]
New locations. Whether an enrolled agency adding a site is a new group enrollment.
For what it's worth, each of these turns on a document I could not find published as of the date above.
Confirm before acting
This post describes the documents listed below as of October 10, 2026. It is not legal advice, and it does not say whether any particular agency is affected. Confirm with IHCP or FSSA Provider Relations, with your Medicaid health plans where they apply, and with your counsel before acting on any of it.
Primary sources
Questions clinic owners ask
- Can an individual BCBA or RBT still enroll with Indiana Medicaid during the moratorium?
- The approval bulletin says the moratorium does not apply to rendering provider enrollment requests for individuals providing ABA therapy services. Confirm a specific enrollment with IHCP.
- When does the Indiana ABA moratorium end?
- It took effect June 6, 2026 for an initial six months, and the IHCP may extend it in six-month increments. As of October 10, 2026 no extension notice appeared on the IHCP bulletins page.
Sources
- 1.IHCP Bulletin BT202692, IHCP receives approval for an ABA provider enrollment moratorium (June 4, 2026)Indiana Health Coverage Programs, Indiana Family and Social Services Administration. Accessed .
- 2.42 CFR 455.470, Temporary moratoria (revised as of October 1, 2025)U.S. Government Publishing Office. Accessed .
- 3.IHCP bulletins indexIndiana Health Coverage Programs, Indiana Family and Social Services Administration. Accessed .
- 4.Indiana Announces Temporary Moratorium on New ABA Provider Agency Enrollments (press release, June 2, 2026)Indiana Family and Social Services Administration. Accessed .
- 5.IHCP Bulletin BT202646, IHCP to require ABA agencies to be accredited (March 26, 2026)Indiana Health Coverage Programs, Indiana Family and Social Services Administration. Accessed .
- 6.IHCP Bulletin BT202667, IHCP seeks approval for an ABA provider enrollment moratorium (May 7, 2026, with update banner)Indiana Health Coverage Programs, Indiana Family and Social Services Administration. Accessed .
Hans Jaeger
Co-founder, Technical Lead, Virida
Hans is a software engineer in Indianapolis who has been building software since 2014, and he builds Virida end to end. His background is software, not behavior analysis, so the clinical vocabulary Virida draws from belongs to Aaron Beasley, M.A., BCBA, LBA, co-founder and Clinical Lead. The writing here keeps to the rule the product does: only what has been checked, with the limits stated as plainly as the capabilities. Read more about both founders on the About page.