Indiana ABA statement of need and referral rules after BT2026160

What changed, with the status first

Indiana Medicaid now treats a "statement of need" and a "referral" for applied behavior analysis (ABA) therapy as one document. Indiana Health Coverage Programs (IHCP) Bulletin BT2026160, dated September 29, 2026, says the two terms "may be used interchangeably, meaning the same thing: a referral for ABA therapy" from one of four kinds of practitioner. It names the three points at which one is required, says when it is not, and lists who cannot complete one, including BCBAs and BCaBAs.^[1] The bulletin prints no separate effective date and describes the policy as applying "moving forward," which is why the box above reads pending: the policy is published and undated, not proposed. As of November 2, 2026, the IHCP bulletins index lists bulletins through October 29, 2026, and none of them changes BT2026160.^[3]

Before this, the statement of need contained the referral. BT202562, from May 2025, said that if the comprehensive diagnostic evaluation (CDE) is more than one year old, "an updated statement of need must be submitted," and that it "must include a referral from an appropriate referring practitioner and an up-to-date behavior assessment completed by the ABA therapy provider."^[2]

Who it affects

Who may write it. BT2026160 names four practitioner types, each with specialized training in the most recent DSM autism spectrum disorder criteria: a doctoral-level licensed clinical psychologist "endorsed as a health service provider in psychology (HSPP)," a licensed physician, a licensed advanced practice registered nurse (APRN), and a licensed physician assistant.^[1]

Who may not. The bulletin says a statement of need or referral "cannot be completed by" a BCaBA, a BCBA, a physical therapist, a speech-language pathologist, or an occupational therapist.^[1] For staffing, that means the document comes from outside the ABA team, and the work of getting it sits with whoever handles intake and authorizations.

When it is required. At three points, in the bulletin's terms:^[1]

• At the onset of ABA therapy, if the CDE is more than one year old.
• At reauthorization, when a member is receiving ABA therapy and the CDE becomes more than one year old.
• With a new prior authorization (PA), if the member has had a six-month gap in ABA therapy. Repeated six-month gaps mean a new one with each new PA.

When it is not. It "does not need to be provided with every reauthorization or annually," and once submitted for any of those scenarios "it does not need to be resubmitted." It is also not required every six months, though "reassessment and an updated treatment plan must be completed at least every six months."^[1] The bulletin lists optional contents and requires none of them. What goes into the document is the referring practitioner's call.

What it does not say. BT2026160 does not mention managed care. The May 2025 bulletin said IHCP documentation requirements apply "to both FFS and managed care," and that each managed care entity (MCE) establishes and publishes "their own billing and reimbursement requirements."^[2] Nothing in these documents touches commercial plans.

What to check this month

CDE dates. For every current IHCP client, put the CDE date and the next reauthorization date side by side. A CDE that will pass one year old before the next reauthorization is one of the bulletin's three trigger points.^[1]

Gaps in service. Look for members returning after six months or more without ABA therapy, including families on a hold or a waitlist. Under the bulletin, their new PA needs a referral with it.^[1]

Where the referral comes from. For each family that will need one, know which physician, APRN, PA, or HSPP psychologist is likely to write it. Our earlier piece on building a referral relationship with pediatricians covers the outreach side of that.

Your own checklist. If an intake or authorization checklist still lists the statement of need and the referral as two documents, or asks families for a fresh referral every year, read it against the bulletin's "when it is not" language above.^[1]

Each MCE. Ask each MCE you bill whether its ABA prior authorization process follows BT2026160.^[2]

Same-day bulletins. The index lists two other ABA bulletins on the same date: BT2026162 on functional behavior assessments and BT2026159 on sleeping and naps during therapy.^[3] This post does not describe them, and our post on Indiana's ABA agency enrollment moratorium covers a different instrument.

What is still open

The behavior assessment. BT202562 tied an up-to-date behavior assessment to the statement of need.^[2] BT2026160 does not repeat that language. To be clear, I cannot tell from the two documents whether IHCP still expects the assessment to travel with the referral at those three points, or only on the six-month cycle.

Module updates. The bulletins index says new information in bulletins "is later incorporated" into provider reference modules during scheduled updates.^[3] I did not check whether the module has been updated yet.

Requests already in flight. BT2026160 does not say how it applies to PA requests submitted before September 29.^[1]

For what it's worth, each of these is a question for IHCP Customer Assistance at 800-457-4584, the number the bulletin gives.^[1]

Confirm before acting

This post describes the documents listed below as of November 2, 2026. It is not legal advice, and it does not say whether any particular clinic's records meet the requirement. Confirm with IHCP, with the MCEs you bill, and with your counsel before acting on any of it.

Primary sources

1. IHCP Bulletin BT2026160, September 29, 2026.^[1]
2. IHCP Bulletin BT202562, May 15, 2025.^[2]
3. IHCP bulletins index, read November 2, 2026.^[3]