FSSA Bulletin BT202627 takes effect in four phases. The 6% rate cut on nongroup ABA codes is live as of April 1, 2026. A further 4% cut is scheduled for April 1, 2027. The 30-hour weekly maximum is operational immediately. The 4,000-hour lifetime cap applies prospectively from April 1, 2026. The most consequential phase, the restriction of ABA to EPSDT-eligible members under age 21, kicks in October 1, 2026.
FSSA also mandated a self-reporting deadline of April 3, 2026 for any provider with fraud, waste, or abuse concerns to come forward. The trigger was the WSJ March 10 investigation into Piece by Piece Autism Centers, which billed Indiana Medicaid $29 million for 84 children in 2023. FSSA terminated Piece by Piece on March 24, 2026.
What changes operationally on April 1
- Rate cut. 97153 and other nongroup codes drop 6%. Many chains were already operating at 5-7% net margin on Indiana Medicaid. The cut puts marginal clinics underwater.
- 30-hour weekly cap. Children currently receiving 35-40 hours per week need a clinical justification on file by April 1 or hours are clawed back at audit. The cap is hard, not negotiable.
- 4,000-hour lifetime cap. A child who started at 30 hours per week at age 3 hits the cap in 2.6 years. That is the actuarial constraint Indiana built the policy around. Family conversations need to start now.
- Provider self-reporting. FSSA expects every provider in the state to have used the April 3 window. Anyone who did not and gets flagged later faces tougher enforcement.
What changes operationally on October 1
The age-21 cliff is the second shock. Indiana ABA Medicaid will no longer cover members 21 and over. Transition-age clients (18-25) who relied on Indiana Medicaid for ABA need a different funding source by Q4. Most will not find one. Indiana commercial parity coverage for adults is limited and many transition-age clients aged out of parent commercial plans.
If your Indiana caseload includes meaningful 18-25 age-band volume, model the attrition now. We are seeing chains with 8-15% of clinical hours concentrated in that band. That revenue line goes to zero on October 1 unless replaced by commercial or self-pay.
Why Indiana is the bellwether
Indiana is not a high-spend ABA state in absolute dollars. But the policy template (rate cut + weekly cap + lifetime cap + age cliff + forced self-reporting) is operationally clean and politically defensible. Illinois, Ohio, Michigan, and Kentucky each have ABA spend curves that look like Indiana's in 2022. State legislators in those states have already requested briefings on BT202627.
What this means for your practice
Indiana proves that even blue-chip Medicaid spend lines can be rewritten in one bulletin. Hard hour caps, age-21 cliffs, and forced self-reporting are now in the regulatory toolkit and will surface in other state bulletins through 2026 and 2027.
If your IN exposure is meaningful, model the adult-21 attrition now. It lands October 1. The chain that has a documented transition pathway for transition-age clients will hold the families. The chain that does not will lose them to whoever does.
✓ This week
Pull every Indiana client aged 17-21. Compute their projected hour totals against the 4,000-hour lifetime cap. Run an attrition model for the October 1 age cliff. Build the family conversation script before September.
What to watch next
FSSA is expected to publish 2027 implementing rules in Q3 2026. The lifetime-cap operational guidance (specifically how the 4,000 hours are counted, whether retroactively or only prospectively) is the single most consequential ruling. The Indiana ABA provider association has formally requested clarification. The answer will determine whether some currently-treating children hit the cap in 2027 or 2030.
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